In The Matter of Miriam Carey v. United States of America, Et Al.

CLAIM FOR DAMAGE,
INJURY, OR DEATH
INST
RUCTIONS: Please read carefully the instru

ctions on the
reverse side and supply information reque
sted on both sides of this
form. Use additional sheet(s) if necessary.
See reverse side for
additional instructions.
1. Submit to Appropriate Federal Agency:
2. Name, address of claimant, and claima

nt's personal representative if any.
(See instructions on reverse). Number, Street,
City, State and Zip code.
United States of America; United States Secr

et Service and
United States Capitol Police
3. TYPE OF EMPLOYMENT
MILITARY
4. DATE OF BIRTH
FORM APPROVED
OMB NO. 1105-0008
Eric Sanders, Esq., of THE SANDERS FIRM

, P.0 1140 Ave
of the Americas New York, NY 10036 o/b/o
Estate of Miriam
Carey, !della Carey, Minor Child EF and Vala
rie Carey
5. MARITAL STATUS
6. DATE AND DAY OF ACCIDENT
CIVILIAN
7. TIME (A.M. OR P.M.)
09/05/2014
8. BASIS OF CLAIM (State in detail
the known facts and circumstances attend
ing the damage, injury, or death, identifying
the cause thereof. Use additional pages
persons and property involved, the
if necessary).
place of occurrence and
Claimants filed and presented previous fede

ral tort claims surrounding the death of Miria
m Iris Carey, those claims were
DENIED. The United States Secret Service
and United States Capitol Police in conjunctio
n with the United States Attorney
General for the District of Columbia and Metr
opolitan Police Department actively and fraud
ulently concealed both agencies role,
as well as a FULL and complete disclosur
e of the facts and circumstances leading to
the shooting death of Miriam Iris Carey,
directly impeding claimants' ability to asse
rt their constitutional, civil, statutory and relat
ed common law rights.
9.
NAME AND ADDRESS OF OWNER, IF
PROPERTY DAMAGE
OTHER THAN CLAIMANT (Number, Street,
City, State, and Zip Code).
NONE
BRIEFLY DESCRIBE THE PROPERTY,
NATURE AND EXTENT OF THE DAMAGE
AND THE LOCATION OF WHERE THE
(See instructions on reverse side).
PROPERTY MAY
BE INSPECTED
NONE
10.
PERSONAL INJURY/WRONGFUL DEATH
STATE THE NATURE AND EXTENT OF
EACH INJURY OR CAUSE OF DEATH,
WHICH FORMS THE BASIS OF THE CLAIM
OF THE INJURED PERSON OR DECEDENT.
. IF OTHER THAN
CLAIMANT, STATE THE NAME
The Estate of Miriam Iris Carey - Emotiona

l Distress, etc. $50,000,000.00
Idella Carey - Emotional Distress, etc. $50,
000,000.00
Minor Child EF - Emotional Distress, etc.
$50,000,000.00
Valarie Carey - Emotional Distress, etc. $50,
000,000.00
11.
WITNESSES
NAME
ADDRESS (Number, Street, City, State,
12. (See instructions on reverse).

12a. PROPERTY DAMAGE
AMOUNT OF CLAIM (in dollars)

12b. PERSONAL INJURY
0.00
and Zip Code)
12c. WRONGFUL DEATH
12d. TOTAL (Failure to specify may cause

forfeiture of your rights).
200,000,000
200,000,000
I CERTIFY THAT THE AMOUNT OF CLAIM
COVERS ONLY DAMAGES AND INJUR
IES CAUSED BY THE INCIDENT ABOV
FULL SATISFACTION AND FINAL SETTL
E AND AGREE TO ACCEPT SAID AMOU
EMENT OF THIS CLAIM.
NT IN
13a.
ATURE F
a )
A MANT (S
IV
vib
instructions on rever e side).
,.
--OK
13b. PHONE NUMBER OF PERSON SIGNIN
G FORM 14. DATE OF SIGNATURE
NZ
888-892-8952
CIVIL PENALTY FOR PRESENTING

FRAUDULENT CLAIM
The claimant is liable to the United States
Government for a civil penalty of not less
than
$5,000 and not more than $10,000, plus
3 times the amount of damages sustained
by the Government. (See 31 U.S.C. 3729).
Authorized for Local Reproduction

Previous Edition is not Usable
95-109
04/20/2015
CRIMINAL PENALTY FOR PRESENTING

FRAUDULENT
CLAIM OR MAKING FALSE STATEMENT
S
Fine, imprisonment, or both. (See 18 U.S.C.
NSN 7540-00-634-4046
287, 1001.)
STANDARD FORM 95 (REV. 2/2007)
PRESCRIBED BY DEPT. OF JUSTICE

28 CFR 14.2
INSURANCE COVERAGE
In order that subrogation claims may be adjudica
ted, it is essential that the claimant provide the followin

g information regarding the insurance coverage
of the vehicle or property.
15. Do you carry acciden
t Insurance? X Yes If yes, give name and addres
s of insurance company (Number, Street, City,
State, and Zip Code) and policy number. El No
NONE
13. Have you filed a claim with your
insurance carrier in this instance, and if so, is it full
coverage or deductible?
Yes
X No
14. If deductible, state amount
NONE
16. If a claim has been filed
NONE
with your carrier, what action has your insurer taken
17. Do you carry public liability and property
NONE
damage insurance?
or proposed to take with reference to your claim?
(It is necessary that you ascertain these facts).
Yes If yes, give name and address of insuran

ce carrier (Number, Street, City, State, and Zip
Code). X No
INSTRUCTIONS
Claims presented under the Federal Tort Claim

s Act should be submitted directly to the "appr
opriate Federal agency" whose
employee(s) was involved in the incident. If
the incident involves more than one claimant,
each claimant should submit a separate
claim form.
Complete all items - Insert the word NONE where
applicable.
A CLAIM SHALL BE DEEMED TO HAVE BEEN

PRESENTED WHEN A FEDERAL
DAMAGES IN A SUM CERTAIN FOR INJURY TO
AGENCY RECEIVES FROM A CLAIMANT, HIS
OR LOSS OF PROPERTY, PERSONAL
DULY AUTHORIZED AGENT, OR LEGAL
INJURY, OR DEATH ALLEGED TO HAVE OCCUR
REPRESENTATIVE, AN EXECUTED STANDARD
RED BY REASON OF THE INCIDENT.
FORM 95 OR OTHER WRITTEN
THE
CLAIM
MUST BE PRESENTED TO THE APPROPRIATE
NOTIFICATION OF AN INCIDENT, ACCOMPANIED
FEDERAL AGENCY WITHIN
BY A CLAIM FOR MONEY
TWO YEARS AFTER THE CLAIM ACCRUES.
Failure to completely execute this form or to
supply the requested material within
The amount claimed should be substantiated by
two years from the date the claim accrued may
competent evidence as follows:
render your claim invalid. A claim
is deemed presented when it is received by the
appropriate agency, not when it is
(a) In support of the claim for personal injury or
mailed.
death, the claimant should submit a
written report by the attending physician, showing
the nature and extent of the injury, the
nature and extent of treatment, the degree of perman
ent disability, if any, the prognosis,
and the period of hospitalization, or incapacitation,
If instruction is needed in completing this form, the
attaching itemized bills for medical,
agency listed in item #1 on the reverse
hospital, or burial expenses actually incurred.
side may be contacted. Complete regulations pertaini
ng to claims asserted under the
Federal Tort Claims Act can be found in Title 28,
Code of Federal Regulations, Part 14.
Many agencies have published supplementing regulati
ons. If more than one agency is
(b) In support of claims for damage to property, which
involved: please state each agency.
has been or can be economically
repaired, the claimant should submit at least two
itemized signed statements or estimates
by reliable, disinterested concerns, or, if paymen
t has been made, the itemized signed
receipts evidencing payment.
The claim may be filled by a duly authorized agent
or other legal representative, provided
evidence satisfactory to the Government is submitte
d with the claim establishing express
authority to act for the claimant. A claim present
ed by an agent or legal representative
(c) In support of claims for damage to property which
must be presented in the name of the claimant.
is not economically repairable, or if
If the claim is signed by the agent or
the property is lost or destroyed, the claimant should
legal representative, it must show the title or legal
submit statements as to the original
capacity of the person signing and be
cost of the property, the date of purchase, and the
accompanied by evidence of his/her authority to
value of the property, both before and
present a claim on behalf of the claimant
after the accident. Such statements should be by
as agent, executor, administrator, parent, guardia
disinterested competent persons,
n or other representative.
preferably reputable dealers or officials familiar
with the type of property damaged, or by
two or more competitive bidders, and should be
certified as being just and correct.
If claimant intends to file for both personal injury
and property damage, the amount for
each must be shown in item number 12 of this form.
(d) Failure to specify a sum certain will render your
claim invalid and may result in
forfeiture of your rights.
PRIVACY ACT NOTICE
This Notice is provided in accordance with the Privacy
Act, 5 U.S.C. 552a(e)(3), and
B. Principal Purpose: The information requested is
concerns the information requested in the letter
to be used in evaluating claims.
to which this Notice is attached.
C. Routine Use: See the Notices of Systems of Records
A. Authority The requested information is solicited
for the agency to whom you are
pursuant to one or more of the
submitting this form for this information.
following: 5 U.S.C. 301, 28 U.S.C. 501 et seq., 28
U.S.C. 2671 et seq., 28 C.F.R.
D. Effect of Failure to Respond: Disclosure is voluntary.
Part 14.
However, failure to supply the
requested information or to execute the form may
render your claim "invalid "
PAPERWORK REDUCTION ACT NOTICE
This notice is solely for the purpose of the Paperw
ork Reduction Act, 44 U.S.C. 3501. Public reportin
g burden for this collection of information is estimat
response, including the time for reviewing instructi
ed to average 6 hours per
ons, searching existing data sources, gathering
and maintaining the data needed, and completing
information. Send comments regarding this burden
and reviewing the collection of
estimate or any other aspect of this collection of
information, including suggestions for reducing
Branch. Attention: Paperwork Reduction Staff, Civil
this burden, to the Director, Torts
Division, U.S. Department of Justice, Washington,
DC 20530 or to the Office of Management and
form(s) to these addresses.
Budget. Do not mail completed
STANDARD FORM 95 REV. (2/2007) BACK
EXHIBIT 1
SANDERS FIRM,
1140 Avenue of the Americas,

9th Floor, New York, NY 10036
Phone:
Fax:
Email:
Facebook: thesandersfirmpc
November 25, 2013
The Honorable Eric Holder

Attorney General of the United States
U.S. Department of Justice
950 Pennsylvania Avenue, NW
Washington, DC 20530
RE: Request for Investigation of the Shooting Death of Miriam I. Carey,
An Unarmed AfricanAmerican Female in the District of Columbia As A Civil Rights Violat
ion
Dear Mr. Holder:
On behalf of the entire Carey Family and the international community,
I am writing to
respectfully request that the Department of Justice investigate the Octob
er 3 shooting death of
Miriam I. Carey, an unarmed African-American Female in the Distric
t of Columbia as a civil
rights violation and the disturbing response of government officials.
I apologize for the lengthy letter, but, I need to address the sketchy
fact and circumstances
surrounding the shooting of Miriam I. Carey that has not been vigoro
usly challenged
investigated. Now that we have the sworn affidavit filed in this case
by the Metropolitan Police
Department in federal court, we are more confident than ever that these
police officers'
completely mishandled this simple "street encounter" and one or more
of them should be
criminally prosecuted for violating Miriam I. Carey's civil rights.
Basic common sense tells you that things should have been done differe
ntly. Quite frankly, any
properly trained professional law enforcement person, such as I (retire
d NYPD) or Valarie Carey
(retired NYPD) will tell you that moving vehicles are not defined as
"deadly weapons" under
department Use of Force guidelines.
Quite frankly, just about every major police agency in the United States
including the District of
Columbia "strictly prohibits discharging service weapons towards
moving vehicles" for a host of
philosophical and safety reasons, unless the person operating the movin
g vehicle is using "deadly
physical force by means other than a moving vehicle." See, the onerou
s is on the United States
Secret Service Uniformed Division, the United States Capitol Police
or any other involved law
enforcement agency to justify their use of force against Miriam I. Carey. If their legal
argument
is that they were protecting the United States Capitol, White House or any other "proper
ty"...
Well, you know the result, their actions are not justified. Remember, the use of force
guidelines
value life over property.
Certainly, from a law enforcement point of view, the Miriam I. Carey case is not "compl
ex" from
a police science perspective to understand.
These law enforcement officials completely mishandled at best, a simple "suspicious
vehicle" car
stop, such car stops are handled professionally by law enforcement officials all over
the world
every day without incident including in other cities with so-called "high value targets.
" Using the
term "high value target" is nothing other than an emotionally charged red herring to
distract the
public from demanding relevant answers from government officials who obviously
violated
Miriam I. Carey's civil rights under the guise of protecting society from "Terrorism."
I
sarcastically call it the new civil rights Qualified Immunity defense.
There are some publically reported suggestions that somehow in the District of Columb
ia there
should a different legal standard, is intellectually disingenuous.
The Department of Homeland Security was established with the passage of Public Law
107-296
which in part, transferred the United States Secret Service from the Department of the
Treasury,
to the new department effective March 1, 2003.
Under the old guidelines, while part of the United States Treasury, the United States
Secret
Service discharge of their service weapons would NOT be justified... Read the old regulati
ons.
As soon as I find some reference to the new guidelines, while part of the Department
of
Homeland Security, I am quite confident the result would be the same, NOT justified
.
http://www.treasury.gov/about/role-of-treasury/orders-directives/Pages/to105-12.asp
x
The sworn affidavit for a Search Warrant clearly says on Page 1 "A USSS-UD (meanin
g United
States Secret Service Uniformed Division) officer attempted to block the vehicle with
a bicycle
rack, however, the vehicle pushed over the bicycle rack, knocking the officer to the
ground."
Note Miriam I. Carey's actions occurred after she allegedly "refused to stop" at the
vehicle
checkpoint and made a U-turn and allegedly began to "flee." There were no laws violated
as she
was under no legal obligation to enter the checkpoint, turning around and leaving is
also not
violative of any laws. The question is: Why did the police pursue her? Later as the
Carey family
continues with its own independent investigation, we will reconcile each sworn fact
with the
surveillance video, other police records and Google Maps. On the surface, the sworn
facts are
internally inconsistent but, we will know more later on.
Further, in the sworn affidavit, there is NO MENTION that Miriam I. Carey struck
any officers
either.
An innocent unarmed United States Citizen with a toddler was killed

right in front of the entire
international community in the Nation's capital.
We in this country deserve to be treated better than as "mere chattel
," where personal legacies are
much more important than human life. The framers of the United States
Constitution fought for,
died for and demanded it. We should expect no different in today's
society either.
We look forward to your timely response.
Sincerely,
Eric Sanders
ES/es
Exhibit 1
change.org
Recipient:
Letter:
Greetings,
Conduct a Swift and Independent Investigation into the MURDER of Miriam
Carey
by Capitol Police and Secret Service
Comments
Name
Location
Date
Jacqueline Smith
Brooklyn, NY
2013-11-14 Justice is right in Gods eye sight.
Cynthia Bryan
Brooklyn, NY
2013-11-14 Did this woman really have to be gunned down as she was? With
Comment
a full
investigation how can there be certainty in the thought that she was a threat?
Why was she not subdued but killed? This could have been my mother, my
sister or me! Change is needed now. We need to know what hapened nowt
Joshua Ventress
Marina, CA
2013-11-14 If it becomes acceptable for police officers to open fire upon unarmed
civilians,
I feel it will slowly become accepted as the norm and more and more innocent
people will be murdered.

Latisha McDougal
Richmond, VA
2013-11-14 I am a friend of the family, I would like to see that true justice is done.
Ree Williams
San Diego, CA
2013-11-14 This is important to me because as a Veteran and an American, I
want to
ensure that our law enforcement officers understand and are trained properly,
not from a fear based training, but from a logic rendering training. We can't
have a repeat of this!

Ayana Miller
Brooklyn ny, NY
2013-11-14 To many people are dying at the hand of the govt. We all have family
that care.
They need explanations just like anyone else would.

Grady Fuller
Hurleyille, NY
2013-11-14 that could have been my sister
CAROL SIMS
Manhattan, NY
2013-11-14 Because that could have been my sister.
Ricky Scott
New York, NY
2013-11-14 I'm sending this petition, for a complete investigation into the murder
of this
young lady. It didn't have to end with a death. There was plenty of opportunities
for officers to take other measures.

Barney Terrell
Johnson city, TN
2013-11-14 There is to much senseless killing going on in the US...we need more
patience,
and concern for the Human Life

Zainab Bola Akinola
brooklyn, NY
2013-11-14 It could have been my family member or friend. Clarity is needed.
Betty Miller
Valley Stream, NY
2013-11-14 I wouldn't want something like that to happen to one of my family
Judy Florentine
Carson City, NV
2013-11-14 First because I know and care for someone in Miriam's family, second
members!
because
I don't like the way justice is being abandoned in America.

Dian Taitt
Miami, FL
TAWONNA WILSON
BROOKLYN, NY
2013-11-14 I FEEL THIS COULD HAVE BEEN HANDLE DIFFERENTLY
ashley peake
columbus, OH
2013-11-14 I believe us tax payers should get what we deserve. ALL cases should
2013-11-14 The family is a pain and this will help to ease their pain
be
investigated properly.
Gail Johnson
Bronx, NY
KIMBERLY JONES
new bern, NC
2013-11-14 she was a friend of my cousin and she, her child and family deserves
MAYA FREEMAN
san diego, CA
2013-11-14 Most police officers are shooting first and asking questions later when
2013-11-14 We need to seek justice as to why the D.C. officers were allowed
to use
EXCESSIVE force that resulted in an UNARMED women being killed. We
need to bring those who are responsible for this crime to Justice
justice!
it a
colored person involved. I question if she was Caucasian, would they have shot
her, or the tires? The Jim Crow Laws need to end officially, Eric Holder is our
only help as people of color to end this senseless shot first policy toward black
people. Even if she was driving erratically, she did not deserve to die, a
wrecked car yes, not death. Truly another United States Tragedy. :-(
Charles McCray
Queens Village, NY
2013-11-14 An abuse of authority resulting in the killing of an unarmed women
Karen McKee
Antelope, CA
2013-11-14 This was wrong. This lady had a young baby in her car and was scared.
was ambushed. What a shame.
She
Name
Location
Tara Finch
Canton, MI
2013-11-14 This is a Shocking and Sad case that I cant stop thinking
michaelno bruno
bklyn, NY
2013-11-14 supporting a old friend
Kisha Jackson
Willingboro, NJ
2013-11-14 I believe that justice needs to be served.
Iris Fitzgerald
Roanoke, VA
2013-11-14 I felt that incident was reenacted. In the beginning I
MONIQUA WILSON
SICKLERVILLE, NJ
2013-11-14 Miriam is my was and still my best friend and I would
cherise gittens
brooklyn, NY
2013-11-14 Justice for this unjustified murder of Miriam Carey
Carol Johnson
Brooklyn, NY
2013-11-15 They didn't have to kill her!
CORNELIUS PERRY
JAMAICA, NY
2013-11-15 This can happen to any one of us in any city in the U.S.
Date
Comment
about.
watched as the police held

the car at gunpoint. Why would someone be held at gun point for
hitting a
gate?
like for her name to be

cleared and to have some justice served and that her family can
some peace
with this unforeseen incident
The police need to be
stopped DEAD in their tracks

Ramona Hamm
New York, NY
2013-11-15 For change in way shootings are handled in our country
Lynn Thompson
Commerce City, CO
2013-11-15 Excessive force was not warranted in this case and
because it could happen to
any of us, it is very important to me.

Akeema Bryan
Brooklyn, NY
2013-11-15 I do not feel that she was particularly innocent due to
Malik Grimes
Indianapolis, IN
2013-11-15 Make sure Justice is served properly.
Tonya Williams
Maxton, NC
2013-11-15 Could have been my family member. I'd like to know
the fact that the video

shows that she evidently was leading a chase from the police but
the officers
taking her life especially while a baby was in the car is definitely unjustifiab
le.
if there is more to this
than the media is telling us.

Oseye Mchawi
Brooklyn, NY
2013-11-15 This is important to me because I am sick and tired
Ella Rucker
Bronx, NY
2013-11-15 We need accountability in the streets to keep the people
Craig Coggins
Phoenix, AZ
2013-11-15 It was reported that there was some mental illness but
Kendra Scott
Indianapolis, IN
2013-11-15 knows what it's like to lose a sister
Juliette Merritt-Bailey
Brooklyn, Barbados
2013-11-15 Because I feel a full investigation is needed, our sisters
of the lack of respect, lack

of justice and the lack of value for Black peoples' lives.
safe. There are other

ways to stop a person...stopping their life should be the last possible
resort
especially if they are unarmed.
even from the footage, it

didn't appear that all was done correctly to avert the police from killing
her.
Non-Lethal methods could have been deployed and I just can't understan
d how
could they not see that there was a Baby in the back seat. And she
was shot
pretty much at point blank range multiple times. Investigation should
be
extensive, thorough, and totally objective.
should not be gun
down on the streets

willa strong
Charlotte, NC
2013-11-15 Her sister is a friend of mine. I am supporting her family.
Nahisha McCoy
Brooklyn, NY
2013-11-15 Fight for justice.
Darryl Jenkins
Atlanta, GA
2013-11-15 good friend
Jamal Baker
Baltimore, MD
2013-11-15 Miriam's family deserves a complete & through investigat
Nellie Williams
Greer, SC
2013-11-15 I believe there need to be an investigation answerin
denise daniels
Marietta, GA
2013-11-15 Because i beleive in justice .
Natalie Miller
scarborough, Canada
2013-11-15 I hate the misuse of power...it truly has to stop
Val Johnson
New York, NY
2013-11-15 Could've been a family member. She harmed no one,
ion
g all questions
options but chose murder!
therefore, they had
Name
Location
Date
NOEL LEADER
BROOKLYN, NY
2013-11-15 JUSTICE SHOULD BE IMPORTANT TO EVERYO
STEVEN MASON
Brooklyn, NY
2013-11-15 Accountability
MICHAEL BELLO
United Kingdom
2013-11-15 BLACK LIFE COUNTS TOO.
Peter HOLOMAN
BROOKLYN, NY
2013-11-15 BECAUSE THE FAMILY SHOULD HAVE CLOSUR
Connie Charles
Locust Grove, GA
2013-11-16 I don't believe this unarmed woman with her yound
clayton hudson
Middle Island, NY
2013-11-16 Incident is very suspicious.
Patricia Smith
NY, NY
2013-11-16 Because she was a baby, just needed someone to
caytoya sharpe
Beverly Hills, CA
2013-11-16 Justice!
Jennifer Brannon
ozone Park, NY
2013-11-16 Friend that would like to see investigation done
Andrew Benson Greene
Freetown, Sierra Leone
2013-11-16 This is important to me because murder of any human
Audreya Perry
Jamaica, NY
2013-11-16 Cops can do better.
Sabrina P
Portland, OR
2013-11-16 You can't just shoot unarmed citizens.
Nancy Vega
Marina Del Rey, CA
2013-11-17 Why did six officers pull their guns on one unarmed
Comment
NE
E.
child in the car was a threat

to the white house. In addtion, I feel execessive force used was unwarran
ted.
hear her.
being is a serious crime

nd must not be encouraged. There must be a stop to it because an
authority
with a gun can continue murdering innocent civilians at their whim
mother with her baby
present? How was she a threat?

John Kern
Charlotte, VT
2013-11-17 Why are so many facts surrounding this case still unknown
? Without a
thorough and independent investigation, we may never know if protocols
were
disobeyed or laws were broken.

Jacqueline Dennis
North Babylon, NY
2013-11-17 It could happen again to anyone of us!!
Tana McDonald
Nashville, TN
2013-11-17 Based on camera footage, I cannot see a reason why this

woman was killed.
Time to reign in the police who seem to kill more people than they
protect and
serve. Executing people whose behavior is puzzling should not be
the first
order.
Edmund Diego
Suffolk, VA
2013-11-17 THIS IS MY FAMILY!!
Suzan Hutchinson
Nashville, TN
2013-11-18 I saw news reports on this and it simply didn't make
isralah rivers
atlanta, GA
2013-11-18 the killing of this young woman was senseless and
kern Mitchell
Euless, TX
2013-11-19 To prevent this from happening to other innocent people
Monique Burks
Dallas, TX
2013-11-19 Justice will be served Val..
sandy jean-louis
brooklyn, NY
2013-11-20 Valerie is a dear friend of mine, and i do believe her
carlaff campbell
brooklyn, NY
2013-11-20 I want to see justice done
Alexandra Bruce
SAG HARBOR, NY
2013-11-20 Murder requiring investigation for justice to be served.
Carmen Del Valle
Broolyn, NY
2013-11-20 I believe there was wrong doing...
Kym Hampton
Brooklyn, NY
2013-11-20 Some police officers are too quick to shoot and kill.
Andrea Battle
Amherst, MA
2013-11-20 Want to know all circumstances around this tragic incident.
Timica Roach
Brooklyn, NY
2013-11-20 She was a special person a friend to me. She did not
sense. What I saw didn't

seem to match what I was hearing. And, when I learned she was
Val's sister, I
felt certain something was missing and needed to be addressed.
more needs to be done to

make for certain no other family goes through what the Carey family
has
experienced.
get justice.
Lise Nicolas
Elmont, NY
2013-11-20 This matter is dear to my heart.
sister deserves justice
deserve this and should
Name
Location
Date
Comment
Von Doane
Coram, NY
2013-11-20
I want to know why an unarmed women with a toddler in her car was
shot and
killed by capital police & secret service agents. in Washington D.C. on
Oct. 3rd,
2013 and why the capitol police officiers have not been identify to the
American public.
Andrew DeCarlo
staten island, NY
2013-11-20 too much excessive force exercized
Angela Stewart
Brandywine, MD
2013-11-20 I believe it's more to this story and I also believe the young
lady is innocent
and was wrongfully killed .

toni bradshaw
atlanta, GA
2013-11-21 One word, JUSTICE!
Kisha Olug
Brooklyn, NY
2013-11-21 I am an advocate of justice for all.
Veronica Thomas
Stone Mountain, GA
2013-11-21 Because the murder of Miriam Carey is a terrible injustice
that could have
happened to me.
Theodore Collier
dalzell, SC
2013-11-21 Because of injustice.
Grover Reed Jr
Brooklyn, NY
2013-11-21 Justice needs to be served
Lureatha Crosby
chicago, IL
2013-11-21 A woman of a young child was murdered unnecessarily.
Richard Lippincott
Newmanstown, PA
2013-11-21 Murdering an unarmed woman with a baby for erratic driving
James Hendon
Dunlap, TN
2013-11-21 They blew her head off, she was no danger. Do your job
Dada Carter
East St. Louis, IL
2013-11-22
& fleeing the

police is criminal. No excuse whatsoever. Those responsible need to
be
brought to justice. They r thugs, not hero's to be applauded by congress.
for once Mr. Holder
I feel there was no reason for shooting this Woman, especially when
a
Child
was inside the vehicle she was driving. There were other measures to
have
taken place. Road block, throwing spikes down to stop the vehicle, then
take
the person out and question to find out what was going on. That was
a
barbaric act and totally un-called for!
Kathy Tribble
Elizabethton, TN
2013-11-22 I am very upset that the Police murdered Miriam Carey
Michael Jackson
Morton, IL
2013-11-22 It's the difference between truth and lies. It's the difference
Sarah L. Freeman
Cumby, TX
2013-11-22 This is too sad, tragic & just plain wrong! This should never
when there was no

need to kill her. This beautiful young mother is gone now and her blood
is on
many hands. I pray for her family and I pray that God brings the truth
to light.
between liberty and

a police state. Miriam Carey did nothing amiss to warrant such action
and then
to have members of Congress applaud her being gunned down in cold
blood.
ever have
happened to anyone & this young woman deserves justice to be served
did happen to her & because that her poor little innocent daughter will
since it
now
suffer from this injustice being done to her mother for the rest of her entire
life!
I believe that when any officers who have sworn to uphold the law & protect
all
our citizens from any & all harm commits a serious crime like murdering
one of
those innocent citizens that it should be taken extremely serious as we
would
address any attack from any foreign or homeland terrorist, because that's
exactly what this is, an act of terrorism against our citizens, namely Miriam
Carey & her infant daughter Erica! I hope my signature, input & passing
this
along to others will indeed help see justice served for them, because
this
breaks my heart!
Joy Guglielmino
Kansas City, MO
2013-11-22 Justice is always important, but that this ils a possible President
Obama
travesty makes it multiply by exponenticially.

PATRICK KILLLILEA
HEMET, CA
2013-11-22 It seems odd that she was shot and kill, after she exited
understand.
her vehicle, as I
Name
Location
Date
Gussie Stuffs
Ridgeland, MS
2013-11-22 This is important because life is a gift from God not
Comment
man. None of the shooters
were God or of His teachings. It was illegal, wrong, sinful and outright
disgusting that lawlessnes is on rise. May God have mercy on the

USA.
There has to be an investigation for the good of the nation. USA
is a God
blessed nation. A country of light on the hill, a Judeo-Christain Republic,
one
nation under God.
doreen shaver
pleains, PA
2013-11-22 justice
Lisa Nydoske
Albuquerque, NM
2013-11-22 Why is there no public outrage about the death of this
John Gilds
Duncannon, PA
2013-11-22 ditto to what Richard Lippincott
beautiful young woman!

The family deserves justice. My prayers go out to the family.
posted:
Murdering an unarmed woman with a baby for erratic driving & fleeing
the
police is criminal. No excuse whatsoever. Those responsible need
to be
brought to justice. They r thugs, not hero's to be applauded by congress!
Melvin Crager
Delta, CO
2013-11-22 Many things are not right about what happened to this
Sondra Young
Lakeside, MT
2013-11-22 This women was murdered for a traffic violation. This
young woman.
never should have
happened ever.
Kamala Chunn
Smyrna, TN
2013-11-22 Justice for Miriam Carey and her daughter.
Marlyce Downen
Louisburg, KS
2013-11-22 I am tired of all the cover ups of this administration!
Rudy Davis
Forney, TX
2013-11-22 I want the TRUTH!
Marvin Stewart
Long Beach, CA
2013-11-22 I have zero tolerance for this kind of conduct.
James Morgan
Denver, CO
2013-11-22 Justice
charlene Jackson
Upper Darby, PA
2013-11-22 The killing of this young woman unjust and the result
of excessive force.
Samuel Elson
Glen Dale, WV
2013-11-22 The injustice of the death and subsequent silence by
officials
Jamie Sullivan
Albuquerque, NM
2013-11-22 This beautiful lady was murdered in cold blood. She
The shooting of this young

woman hasn't made sense since I first read about I in the news she was
unarmed - why was she shot?
into her murder.
deserves a investigation
Mary Menefee
Waterloo, SC
2013-11-22 Miscarriage of justice
James Maclnness
West Islip, NY
2013-11-22 An unarmed woman was gunned down.
James Manning
New York, NY
2013-11-22 The truth must be revealed to the American people.
Jacqueline Parris
San Diego, CA
2013-11-22 wanting justice
John White
Tucson, AZ
2013-11-22 I need to know the TRUTH and I'm to angry to comment
Verdell Bennett
New York, NY
2013-11-22 We need to ensure that justice is done for Miriam Carey
more . I will said this ,

I'm so very sorry for Miriam Carey and her family , God blessing on
Miriam
Carey and her family Amen
with an investigation
into this Capitol police and Secret Service incident.

ronn remai
Evelyn Parham
2013-11-22
Greenville, GA
I am a white male believer in Jesus Christ, and I want answers

and may the
truth be told. Jesus Christ will return and bring justice to this earth;
though
there be none now. Revelations 19:11-21 please read.
2013-11-22 This important to me because this was a senseless
murder that needs to be
investigated.
Luis Duque, Jr.
Houston, TX
2013-11-22 Seeking truth.
Peter CHVOSTOVSKY
San Antonio, TX
2013-11-22 IF THIS WAS AN EXECUTION THERE NEEDS TO
BE JUSTICE.
Name
Location
Date
FRED WILSON
CHAPEL HILL, NC
2013-11-22 THIS WAS NOT ONLY AN INNOCENT WOMAN, BUT ALSO MY
Comment
BEST
FRIEND'S SISTER. I AM ALSO A WITNESS TO EXCESSIVE FORCE BY
LAW ENFORCEMENT. I KNOW THAT OFFICERS ARE TRAINED TO USE

EXCESSIVE FORCE AS A LAST RESORT BECAUSE I'VE HAD AND STILL
HAVE FAMILY MEMBERS ON THE FORCE. FURTHERMORE, I DONT
BELIEVE SHE HAD TO BE SHOT AND KILLED, SHE POSED NO
IMMEDIATE THREAT. THIS HAS TO STOP NOW!
Maryam Jamilah
clute, TX
2013-11-23 Highly significant because I am an American citizen committed to
justice being
done.
Kenneth Senese
Hodgkins, IL
2013-11-23 It is important because assassinations of innocent people cannot
be tolerated
any longer and the nefarious evil that is in control of our government has to be
stopped.
Ali James
Fort Lauderdale, FL
2013-11-23 We want justice for miriam carey.
Darlene Rowe
West Covina, CA
2013-11-23 Because I do think she was murdered, for reason unknown to us.
Nancy Smith
Redding, CA
2013-11-23 This was an unjustifiable homicide and cover up.This must not stand
JoAnn Bjorkman
Sylvania, GA
unchallenged.
2013-11-23 Because a woman died needlessly from the excessive force used
by the
Capitol Police
Dania Bermudez
Corona, NY, NY
2013-11-23 Miriam Carey was the sister of a friend of mine (Valerie Carey) so
this cause is
near & dear to my heart. A beautiful & young spirit gone too soon, an innocent
life cut down, extinguished. We as a people must speak up & out against
atrocities such as this to prevent others from occurring.
My condolences to the Carey family
R.I.P.
Miriam Carey
Mary Spence
Vikki Kennedy
2013-11-23 "The Truth shall make you free!"

Washington, DC
2013-11-23 If it was my sister I would want answers...REAL answers not the tom
foolery we
hear on the news. They did NOT have to kill or shoot her. They easily could
have shot out her tires like they "usually" do in cases like this.
Magnus Johansson
Stockholm, Sweden
2013-11-23 The tragic death of Miriam Carey has to get a proper investigatio
Magnus Johansson
Stockholm, Sweden
2013-11-23 Is it really true that this petition has not reached 500 signatures yet?
Shelbia Whitfield
Newark, DE
2013-11-23 I just feel that before a life is taken we must look at the Situation as
n.
I thought I
would be perhaps number 468 000 signing the petition, not 468. Incredible.
if it was our
personal family member and then make a judgement call.

Kim Hipps
Nashville, TN
2013-11-23 There's clearly a cover up going on here! She deserves justice!
DAVID VALENTINE
glendale heights, IL
2013-11-23 because police shoot and could have tazered instead to much foolishness
and
we wonder why this society is going to shit

Stoney Star Anderson
Huntsville, AR
2013-11-24 Justice the her, her sister & the baby.
Trinity Anderson
Huntsville, AR
2013-11-24 Because the family deserves justice.
kathy hines
Baltimore, MD
2013-11-24 she is a black woman that had alot on her mind with a daughter that
Gregory Mitchell
North Chesterfield. VA
2013-11-24 This is one of my close friend's relative.
Rita Cooney
foothill ranch, CA
2013-11-24 this is a coverup and disgrace to all humankind!
will never
see her mother again please help us to stop this police the police from killing
innocent people
EXHIBIT 2
FTCA Administrative Claims

X
IN RE: MIRIAM IRIS CAREY

Claimant,
-againstUNITED STATES OF AMERICA; UNITED STATES SECRET
SERVICE and UNITED STATES CAPITOL POLICE
Respondents
To:
Respondents' UNITED STATES OF AMERICA; UNITED STAT

ES SECRET SERVICE and
UNITED STATES CAPITOL POLICE
United States of America
do United States Department of Justice
900 Pennsylvania Avenue NW
Washington, DC 20530-0001
United States Secret Service
do United States Department of Homeland Security
Office of the General Counsel
245 Murray Lane
Mail Stop 0485
do Chief Kim Dine
119 D Street NE
do The Capitol Police Board
S-151 The Capitol
CLAIMANTS'
1.
The Estate of Miriam Iris Carey by and through her personal
representative
Valarie Carey on behalf of decedent's mother Idella Carey.

2.
Idella Carey, the decedent's mother and grandmother of minor
decedent's daughter.
3.
EF, the minor child of decedent Miriam Iris Carey
grandchild EF, the
AMOUNTS OF CLAIMS
Each claimant seeks $25,000,000.00 (Twenty-five million dollars).
The aggregate sum certain sought by all claimants is $75,000,000.00 (Seventy-five
million dollars)
BASIS OF CLAIMS
1.
These claims for the wrongful death of decedent Miriam Iris Carey arise under
the Federal Tort Claims Act (28 U.S.C. 1346(b), 2401(b), 2674, 2675(a), 2679, and
2680(h)); the Wrongful Death Act of the District of Columbia (D.C. Code 16 2701
et seq.);
the Fourth Amendment (Unlawful Search of the Person, Unlawful Search of Propert
y,
Unlawful Seizure of Person, Excessive Force, Unlawful Seizure of Property); Fifth

Amendment (Due Process and Equal Liberty) and other related local and common
2.
law claims.
The claims arise from the numerous intentional, grossly negligent and reckless
actions of police officers, supervisors, managers and other related employees' assigne
d to the
United States Secret Service Uniform Division and United States Capitol Police, their
collective actions caused the avoidable wrongful death of decedent Miriam Iris Carey.
3.
The decedent Miriam Iris Carey was born from the loving union of Leon Faules
(deceased 1987) and Idella Carey on August 12, 1979 in Brooklyn, N.Y., the fourth
of their
five daughters.
4.
Mother, Daughter, Sister and Friend, decedent Miriam Iris Carey held an
important place in the lives of many.

5.
Decedent Miriam Iris Carey grew up in East New York, Brooklyn, where she
learned to face life's challenges with a spirit of self-determination.

6.
Decedent Miriam Iris Carey was an achiever who consistently sought to reach
her life goals.

7.
Decedent Miriam Iris Carey had a passion for cooking and loved life.
8.
Decedent Miriam Iris Carey's greatest joy was spending time with her
minor
child EF, as well as family and friends.

9.
Decedent Miriam Iris Carey, RDH, was a licensed dental hygienist.
10.
Decedent Miriam Iris Carey graduated from Brooklyn College with a
Bachelor's of Science Degree in Health and Nutrition Services.

11.
Decedent Miriam Iris Carey aspired to teach others in the field of dentist
12.
At the time of decedent Miriam Iris Carey's death, 34, her minor child
ry.
Mother Idella Carey and Sisters Franchette R. Carey, Valarie Carey, Amy
EF;
M. Carey-Jones,
Andrea D. Carey and Cordelia Denise Jones-Hayden; Brother Kenne
th Leon Jones and a host
of other family members and friends survived her.

ALLEGED FACTS OF THE CLAIMS1
13.
Decedent Miriam Iris Carey was traveling in her 2010 Infiniti G37XS
near the vicinity of 15th Street NW and E Street NW, which is one
Coupe
of the White House gate
entrances.
14.
Decedent Miriam Iris Carey was legally operating the vehicle, her minor
child
EF was seated in a child safety seat in the rear of the vehicle.

15.
Decedent Miriam Iris Carey being unfamiliar with the area, mistakenly
past the first guard post at the White House gate entrance because the
drove
entrance was negligently
maintained, covered and supervised by police officers, supervisors, manag
ers and other related
This administrative claim details information available at the time of

filing. Claimants' reserves the right to
amend this administrative claim for consideration during the present
ment and investigation phase to the United
States of America; United States Secret Service Uniform Division and
United States Capitol Police.
employees' assigned to the United States Secret Service Uniform Division.

16.
After realizing her innocent mistake, decedent Miriam Iris Carey made a U-turn
to leave the area heading a short distance eastbound on E Street NW back towards 15th Street
NW.
17.
For some inexplicable reason, instead of simply allowing decedent Miriam Iris
Carey to leave the area, a police officer assigned to the United States Secret Service Uniform
Division without provocation or legal justification, inconsistent with his or her police training,
intentionally, negligently and recklessly threw a bicycle rack at the vehicle striking it.
18.
At the time, decedent Miriam Iris Carey had committed no crime or violation of
any other law, thus, the police had no legal basis to stop her or use any amount of physical
force against her.
19.
The police officer's actions slightly damaged her vehicle, more importantly,
startled her which endangered her safety, her minor child EF and public.
20.
In the process of seeing the bicycle rack being thrown towards her vehicle, to
protect herself and her minor child EF, decedent Miriam Iris Carey panicked and headed
eastbound on Pennsylvania Avenue NW.
21.
Numerous police officers, supervisors, managers and other related employees'
in government motor vehicles began to pursue decedent Miriam Iris Carey and her minor child
EF endangering their lives and the public.
22.
Police officers, supervisors, managers and other related employees'
inconsistent with their police training and department policies, failed to terminate pursuing
decedent Miriam Iris Carey and her minor child EF as the risk to them, the public, the police
officers, supervisors, mangers and other related employees' outweighed the benefit of
investigating a harmless mistaken entrance through the White House entrance gate.
23.
Police management and radio dispatchers, inconsistent with their police
training and department policies, failed to order police officers, supervisors, manage
rs and
other related employees' immediately to terminate pursuing decedent Miriam Iris Carey
her minor child EF, as the risk to them, the public, the police officers, supervisors,
and
mangers
and other related employees' outweighed the benefit of investigating a harmless mistake
entrance through the White House entrance gate.

24.
In complete fear, decedent Miriam Iris Carey continued traveling eastbound on
Pennsylvania Avenue NW, then at the corner of 3"1 Street SW, made a right heading
southbound on 3rd Street SW, still pursued by numerous police officers, supervi
sors, managers
and other related employees in government motor vehicles.

25.
At the corner of Maryland Avenue SW, decedent Miriam Iris Carey made a left
turn heading eastbound on Maryland Avenue SW and struck a curb near 10 Maryla
nd Avenue
SW after being forced over by numerous police officers, supervisors, managers and
other
related employees' in government motor vehicles.

26.
Police officers, supervisors, managers and other related employees' on foot
assigned to the United States Secret Service Uniform Division and the United States
Capitol
Police surrounded decedent Miriam Iris Carey and her minor child EF.
27.
The immediate area moderately populated with vehicular and pedestrian traffic.
28.
The police officers, supervisors, managers, and other related employees' on
foot approached decedent Miriam Iris Carey's vehicle with their service weapons drawn,
pointed in the ready position to be fired.
29.
The senior police officers, supervisors and managers never established firearms
control consistent with their police training and department policies.

30.
Decedent Miriam Iris Carey noticing these police officers, supervisors,
managers and other related employees' approaching with their service weapons drawn,
pointed in the ready position to be fired, in an attempt to protect herself and her minor
child
EF, panicked, placing her vehicle in reverse accidentally striking a marked police vehicle
31.
Police officers, supervisors, managers and other related employees' from the
United States Secret Service Uniformed Division and United States Capitol Police
without
establishing firearms control or legal justification, inconsistent with their police training
department policies discharged their service weapons at decedent Miriam Iris Carey's
and
moving
vehicle.
32.
Claimants' believe one or more of the discharged rounds entered decedent
Miriam Iris Carey's vehicle striking her body, mortally wounding her.
33.
Claimants' believe decedent Miriam Iris Carey experienced shock and
substantial pain throughout her body.

34.
At the time of the firearm discharges, the police officers, supervisors, managers
and other related employees' from the United States Secret Service Uniformed Divisio
n and
United States Capitol Police already knew decedent Miriam Iris Carey did not use
any firearm
or other form of deadly physical force against them or others.

35.
n and
United States Capitol Police already knew decedent Miriam Iris Carey had commit
ted no
crime or violation of any other law that would justify discharging their service weapon
towards her.
36.
n and
United States Capitol Police already knew decedent Miriam Iris Carey's minor child
EF was
in the rear passenger area of the vehicle but fired anyway.

37.
Despite having actual and/or constructive knowledge as indicated in Allegation
Nos.: 1 through 34, the police officers, supervisors, managers and other employees
from the
United States Secret Service Uniformed Division and United States Capitol Police
discharged
their firearms anyway endangering decedent Miriam Iris Carey, her minor child EF
and the
public.
38.
The firearms discharge occurred as decedent Miriam Iris Carey headed
eastbound on Maryland Avenue SW towards the Garfield Memorial, then northbound
on 1st
Street NW past the Peace Circle.

39.
Police officers, supervisors, managers and other related employees' from the
United States Secret Service Uniformed Division and the United States Capitol Police
continued to pursue now mortally wounded decedent Miriam Iris Carey in numerous
government motor vehicles.
40.
Despite sustaining a mortal wound, decedent Miriam Iris Carey continued
traveling northbound on 1st Street NW, then at the corner of Constitution Avenue
NW, made a
right heading eastbound on Constitution Avenue NW, still pursued by numerous governm
ent
motor vehicles.
41.
Decedent Miriam Iris Carey stopped her vehicle near the corner of 2nd Street
NE and Constitution Avenue NE.

42.
Decedent Miriam Iris Carey noticing even more armed police officers panicked
abruptly turning left over a median, quickly reversing her vehicle where numero
us police
officers, supervisors, managers and other employees' from the United States Secret
Service
Uniformed Division and United States Capitol Police without establishing firearm
s control
and legal justification discharged their service weapons.

43.
Decedent Miriam I. Carey sustained numerous injuries about her body, further
shock, substantial pain and damage to her vehicle.

44.
Decedent Miriam Iris Carey was removed from the vehicle alive.
45.
Decedent Miriam Iris Carey's minor child EF was not physically injured.
46.
Decedent Miriam Iris Carey was transported to Medstar Washington Hospital
Center where she was pronounced dead by Dr. Christine Trankiem.

47.
Decedent Miriam Iris Carey was later transported to the Office of the Chief
Medical Examiner for an autopsy.

48.
Claimant Idella Carey, decedent Miriam Iris Carey's mother, as well as Sisters
Franchette R. Carey, Valarie Carey, Amy M. Carey-Jones, Andrea D. Carey and

Denise Jones-Hayden; Brother Kenneth Leon Jones and a host of other family
Cordelia
members and
friends viewed some or all parts of this very public shooting that was broadcasted
live over the
television airwaves.
49.
Since the death of decedent Miriam Iris Carey, not one federal government has
contacted claimants' to express condolences for their loss.

50.
Other than questioning Claimant Idella Carey, decedent Miriam Iris Carey's
mother, as well as Sisters Franchette R. Carey, Valarie Carey, Amy M. Carey-
Jones, Andrea
D. Carey and Cordelia Denise Jones-Hayden; Brother Kenneth Leon Jones and
family members by the Federal Bureau of Investigation and the United States
a host of other
Secret Service
about decedent Miriam Iris Carey's personal activities, not one member of the
United States
Secret Service Uniform Division or the United States Capitol Police officially
notified them of
decedent's death consistent with department policies.

51.
Because of the intentional, negligent and reckless actions of police officers,
supervisors, managers and other related employees' assigned to the United States
Secret
Service Uniform Division and United States Capitol Police, they collectively caused
the
avoidable death of decedent Miriam Iris Carey.

52.
Because of the intentional, negligent and reckless actions of police officers,
supervisors, managers and other related employees' assigned to the United States
Service Uniform Division and United States Capitol Police claimants sustained
Secret
substantial
damages.
PRAYER FOR RELIEF
Claimants pray that the United States of America; United States Secret Service
Uniform Division and United States Capitol Police will:
53.
Conduct a full and comprehensive investigation into the claims;
54.
Determine there is substantial competent evidence to support claims presented

herein;
55.
Determine the intentional, negligent and reckless actions of police officers,

supervisors, managers and other related employees' assigned to the United
States Secret Service Uniform Division and United States Capitol Police were
acting within the scope of their employment;
56.
Determine as a result of the intentional, negligent and reckless actions of police

officers, supervisors, managers and other related employees' assigned to the
10
United States Secret Service Uniform Division and United States

Police, they collectively caused the avoidable death of decedent
Capitol
Miriam Iris
Carey, therefore, such wrongful actions are imputed to the Unite
d States of
America; and
57.
Determine the United States of America is liable for the avoid
able death of
decedent Miriam his Carey and immediately pay all compensato
ry damages to
the claimants.
Dated: January 24, 2014
New York, NY
Respectful submitted,
By:
Eric Sanders
Eric Sanders, Esq.
THE SANDERS FIRM, P.C.
1140 Avenue of the Americas, 9th Floor
New York, NY 10036
Website: http://www.thesandersfirmpc.corn
11
EXHIBIT A
FI
STADERS FIRM,
PC
1140 Avenue of the Americas,

9th Floor, New York, NY 10036
Phone:
Fax:
Email:
Facebook: thesandersfirmec
October 3, 2013
Ms. Idella Carey

o/b/o The Estate of Miriam I. Carey
1167 Stanley Avenue, Apt 2E
Brooklyn, NY 11208
MASTER RETAINER AGREEMENT
I.
LEGAL SERVICES FEE
This Master Retainer Agreement will confirm the agreement between "You," the "Client"
and THE SANDERS FIRM, P.C., the "Firm." "You," the "Client," have agreed
to retain the
"Firm" in connection with investigating claims related to Medical Malpractice,
Civil Rights
violations or other violations of law o/b/o Decedent Miriam I. Carey in the State of
Connecticut,
New York, the District of Columbia or any other jurisdiction. The "Firm" will
handle and
represent "You," the "Client" throughout the entire process of investigating any
claims o/b/o
Decedent Miriam I. Carey.
"You," the "Client" will remit to the "Firm," a Legal Services Fee of 0.00, for
its'
acceptance of "You," as a "Client," for the purposes of investigating claims related
to Medical
Malpractice, Civil Rights violations or other violations of law o/b/o Decedent Miriam
I. Carey,
in the State of Connecticut, New York, the District of Columbia or any other jurisdic
tion. This
Master Retainer Agreement does not cover Costs and Disbursements associa
ted with
investigating claims related to Medical Malpractice, Civil Rights violations or other
violations of
law o/b/o Decedent Miriam I. Carey in the State of Connecticut, New York, the
District of
Columbia or any other jurisdiction as defined in Paragraph II and III.
"You," the "Client," agree that any Legal Services Fees due and owed to the "Firm"
not paid within fifteen (15) days of receipt of the invoice will incur a monthly charge
of one
and one-half percent (1.5%) compound interest until PAID IN FULL.
"You," the "Client," agree, that if you present a financial instrument to the "Firm"
such as a check, money order and/or credit card, for the payment of legal
services as
defined in Paragraph I, that is dishonored then "You," the "Client," agree to reimbu
rse the
"Firm" for any service fees.
II.
COURT AWARDS
As compensation for costs and services rendered in the future, the exact amount of
which
is not ascertainable, in the event that the appropriate federal court award
costs and fees in this
matter, the calculations will be based upon the following rates:
1.
2.
3.
4.
5.
6.
III.
Hourly rate of Senior Attorneys/Partners

$ 675.00;
Hourly rate of Senior Associates
$ 525.00;
Hourly rate of Associates:
$ 475.00;
Hourly rate of Paralegals/Support Staff:
$ 175.00;
All other costs and fees billed against this matter will reflect the actual
costs and fees incurred by the "Firm," with the exception of intern
al
printing, photocopying, and scanning costs that will be billed at .12
cents
per page; and
The compensation for costs and services as outlined in this paragr
aph
applies regardless of any other monies owed and/or received pursua
nt to
the Contingency Fee as defined in Paragraph IV hereafter.
COSTS AND DISBURSEMENTS
"You," the "Client," agree to pay the "Firm" at each stage of this matter
, all Costs and
Disbursements associated with investigating claims related to Medical
Malpractice, Civil Rights
violations or other violations of law o/b/o Decedent Miriam I. Carey
in the State of Connecticut,
New York, the District of Columbia or any other jurisdiction as incurre
d by the "Firm." This
may include, but is not limited to, filing fees, service fees, sworn deposi
tions fees, expert fees,
printing, photocopying, scanning, emailing, etc.
"You," the "Client," agree that any Costs and Disbursements due
and owed to the
"Firm" not paid within fifteen (15) days of receipt of the invoic
e will incur a monthly
charge of one and one-half percent (1.5%) compound interest until
PAID IN FULL.
"You," the "Client," agree, that if you present a financial instrument
to the "Firm"
such as a check, money order and/or credit card, for the
payment of Costs and
Disbursements as defined in Paragraph III, that is dishonored, then
"You," the "Client,"
agree to reimburse the "Firm" for any service fees.
IV.
CONTINGENCY FEE
"You," the "Client" has further agreed that if investigating claims

related to Medical
Malpractice, Civil Rights violations or other violations of law o/b/o Deced
ent Miriam I. Carey in
the State of Connecticut, New York, the District of Columbia or any
other jurisdiction rights
results in a settlement agreement, with or without the filing of
a lawsuit and/or judicial
intervention, then "You," the "Client" agrees to pay the "Firm,"
thirty-three and one third
percent (33 1/3%) of any monies so received, as a Contingency Fee.
V.
RIGHTS AND RESPONSIBILITIES

"You," the "Client" agrees that other members of the "Firm" and/or other
Printing, photocopying and scanning costs are billed at a rate of .12 cents
2
per page.
members hired
by the "Firm," may perform substantial work on this matter and/or appear
on your behalf. This
may occur due to legal qualifications, time conflicts, illness, attention
to other matters or in
accordance with State Bar requirements, etc.
"You," the "Client" agrees that you have an affirmative obligation to keep
the "Firm"
informed as to any changes that may influence the outcome of these matters
.
"You," the "Client" agrees that the "Firm" shall keep you informed as to
the progress of
these matters. These matters and the progress are open to "You," the "Client
," for your physical
inspection with advance notice to the "Firm."
"You," the "Client" agrees that you are aware of the unique hazards of
handling legal
matters, and that despite the best efforts of the "Finn," the "Firm" CANN
OT guarantee a result.
However, the "Firm" will handle these matters expeditiously and efficien
tly in accordance with
its goal to provide the highest legal and ethical standards.
"You," the "Client" agrees that when these matters are ready for hearing
and/or trial, any
monies due and owed to the "Firm" must be PAID IN FULL otherwise,
the "Firm" reserves the
right to move to terminate the Attorney-Client relationship2 consistent with DR
2-110.
2
DR 2-110 [1200.151 Withdrawal from Employment
A. In general
1. If permission for withdrawal from employment is required by the rules
of a tribunal, a lawyer shall not withdraw
from employment in a proceeding before that tribunal without its permissi
on.
2. Even when withdrawal is otherwise permitted or required under section
DR 2-110 [1200.15] (A)(1), (B), or (C), a
lawyer shall not withdraw from employment until the lawyer has taken
steps to the extent reasonably practicable to
avoid foreseeable prejudice to the rights of the client, including giving
due notice to the client, allowing time for
employment of other counsel, delivering to the client all papers and property
to which the client is entitled and
complying with applicable laws and rules.
3. A lawyer who withdraws from employment shall refund promptly any part
of a fee paid in advance that has not
been earned.
B. Mandatory withdrawal
A lawyer representing a client before a tribunal, with its permission if
required by its rules, shall withdraw from
employment, and a lawyer representing a client in other matters shall withdraw
from employment, if:
1.The lawyer knows or it is obvious that the client is bringing the legal action,
conducting the defense, or asserting a
position in the litigation, or is otherwise having steps taken, merely for
the purpose of harassing or maliciously
injuring any person.
2. The lawyer knows or it is obvious that continued employment will result
in violation of a Disciplinary Rule.
3. The lawyer's mental or physical condition renders it unreasonably

difficult to carry out the employment
effectively.
4. The lawyer is discharged by his or her client.
C. Permissive withdrawal.
3
In any event, the "Firm," will enforce its right under N.Y. Jud. Law 475, and petition
the Court, to enforce an attorney lien upon the matter for recovery of its legal fees, costs and
disbursements.
VI.
TERMINATION OF THIS MASTER RETAINER AGREEMENT
"You," the "Client" agrees that if you elect to terminate this Master Retainer Agreement
prior to the completion of all of the legal services contemplated by the "Firm," then "You," the
"Client" will be promptly billed in accordance with the rates specified in Paragraph II herein.
In any event, the "Firm," will enforce its rights under N.Y. Jud. Law 475, and petition
the Court, to enforce an attorney lien upon the matter for recovery of its legal fees, costs and
disbursements.
"You," the "Client," agree that any outstanding Termination Fees and/or Costs and
Disbursements due and owed to the "Firm" not paid within fifteen (15) days of receipt of
Except as stated in DR 2-110 [1200.151(A), a lawyer may withdraw from representing a client if withdrawal can be
accomplished without material adverse effect on the interests of the client, or if:
1. The client
a. Insists upon presenting a claim or defense that is not warranted under existing law and cannot be supported by
good faith argument for an extension, modification, or reversal of existing law.
b. Persists in a course of action involving the lawyer's services that the lawyer reasonably believes is criminal or
fraudulent.
c. Insists that the lawyer pursue a course of conduct which is illegal or prohibited under the Disciplinary Rules.
d. By other conduct renders it unreasonably difficult for the lawyer to carry out employment effectively.
e. Insists, in a matter not pending before a tribunal, that the lawyer engage in conduct which is contrary to the
judgment and advice of the lawyer but not prohibited under the Disciplinary Rules.
f. Deliberately disregards an agreement or obligation to the lawyer as to expenses or fees.
g. Has used the lawyer's services to perpetrate a crime or fraud.
2. The lawyer's continued employment is likely to result in a violation of a Disciplinary Rule.
3. The lawyer's inability to work with co-counsel indicates that the best interests of the client likely will be served by
withdrawal.
4. The lawyer's mental or physical condition renders it difficult for the lawyer to carry out the employment
effectively.
5. The lawyer's client knowingly and freely assents to termination of the employment.
6. The lawyer believes in good faith, in a proceeding pending before a tribunal, that the tribunal will find the
existence of other good cause for withdrawal.
4
the invoice will incur a monthly charge of one and one-half percent (1.5%) compound
interest until PAID IN FULL.
"You," the "Client," agree, that if you present a financial instrument to the "Firm"
such as a check, money order or credit card, for the payment of the Termination Fee
and/or Costs and Disbursements as defined in Paragraphs II, III and VI, that is dishonored
then "You," the "Client," agree to reimburse the "Firm" for any service fees.
VII.
APPEALS
This Master Retainer Agreement does not cover any appeals to the State of Connecticut,
New York, the District of Columbia or any other jurisdictions appeals courts, the Second Circuit
Court of Appeals, District of Columbia Court of Appeals or the Supreme Court of the United
States.
VIII. ARBITRATION
"You," the "Client" agrees that if a Fee Dispute arises, you may have the right to
arbitration of such dispute pursuant to Part 137 of the Rules of the Chief Administrator of the
Courts, a copy of which is available upon request.
Sincerely,
Eric Sanders
SIGNED AND ACCEPTED ON THE ABOVE TERMS
Idella Carey
DURABLE GENERAL POWER OF ATTORNEY

NEW YORK STATUTORY SHORT FORM
THE POWERS YOU GRANT BELOW CONTINUE TO BE E141+ECTIVE
SHOULD YOU BECOME DISABLED OR INCOMPETENT
Caution: This is an important document. It gives the person whom you designate
(your "Agent") broad powers to handle your property during your lifetime, which may
Include powers to mortgage, sell, or otherwise dispose of any real or personal property
without advance notice to you or approval by you. Then powers will continue to exist even
after you become disabled or incompetent These powers are explained more fully In New
York General Obligations Law, Article 5, Title 15, Sections 5-1502A through 5-1503, which
expressly permit the use of any other or different form of power of attorney.
This document does not authorize anyone to make medical or other health care
decisions. You may execute a health care proxy to do this.
If there is anything about this form that you do not understand, you should ask a
lawyer to explain it to you.
THIS is intended to constitute a DURABLE GENERAL POWER OF ATTORNEY
pursuant to Article 5, Title 15 of the New York General Obligations Law:
64ei
4kis9ie.
hereby appoint:
(irEsertyour name and address)
(If one person is to be appointed agent, insert the name and address of your agent above)
(If two or more persons are to be appointed agents by you, insert their name and addresses above)
my attorney(s)-in-fact TO ACT
(If more than one agent is designated CHOOSE ONE of the following two choices by putting your initials in ONE
of the blank spaces to the left of your choice:)
E.:1e,
Each agent may SEPARATELY act.

All agents must act TOGETHER.
(If neither blank space is initialed the agents will be required to act TOGETHER)
IN MY NAME, PLACE AND STEAD, in any way which I myself could do, if I were personally
present, with respect to the following matters as each of them is defined in Title 15 of Article 5
of the New York General Obligations Law to the extent that I am permitted by law to act through
an agent:
DIRECTIONS: Initial in the blank space to the left of your choice any one or more
of the following lettered subdivisions as to which you WANT to give your agent authority.
If the blank space to the left of any particular lettered subdivision is NOT initialed, NO
2
AUTHORITY WILL BE GRANTED for matters that are included in that subdivision.
Alternatively, the letter corresponding to each power you wish to grant may be written or
typed on the blank line in subdivision "(Q)", and you may then put your initials in the blank
space to the left of subdivision "(Q)" in order to grant each of the powers so indicated.)
] (A) real estate transactions;
] (K) records, reports and statements;
] (B) chattel and goods transactions;
] (L) retirement benefit transactions;
(C) bond, share and commodity

transactions;
] (D) banking transactions;
] (M) making gifts to my spouse,

children and more remote descendants, and
parents, not to exceed in the aggregate
$10,000 to each of such persons in any year;
j (E) business operating transactions;
] (N) tax matters;
] (F) insurance transactions;
] (0) all other matters;
] (G) estate transactions;
] (P) full and unqualified authority to

my
attorney(s)-in-fact to delegate any or all of
the foregoing powers to any person or
persons whom my attomey(s)-in-fact shall
select;
] (H) claims and litigation;

] (I) personal relationships and
affairs;
] (J) benefits from military service;
[V... (Q) each of the above matters

iikritifipal by the following lette
4\-(1110
(Special provisions and limitations may be included in the statutory short form durable power of attorney only if they conform to the
requirements of 5-1503 of the New York General Obligations Law.)
This Durable Power of Attorney shall not be affected by my subsequent disability or incompetence.
If every agent named above is unable, or unwilling to serve, I appoint (insert name and address of successor)
to be my agent for all purposes hereunder
To induce any third party to act hereunder, I hereby agree that any third party receiving a duly
this instrument may act hereunder, and that revocation or termination
hereof shall be ineffective as to such third party unless and until actual notice or knowledge of such
revocation or termination shall have been received by such third party, and I for myself and for my heirs,
executors, legal representatives and assigns, hereby agree to indemnify and hold harmless any such third
party from and against any and all claims that may arise against such third party by reason of such third
executed copy or facsimile of
party having relied on the provisions of this instrument.

This Durable General Power of Attorney may be revoked by me at any time.
In Witness Whereof, I have hereunto signed my name this
day of I)1302019...943
(YOU SIGN HERE:) -4

(Signature of Principal)
ACKNOWLEDGMENT
(for use within the State of New York)
STATE OF NEW YORK, COUNTY OF ar....
On the (t1I day of `/ft O% in the year
for said State, personally appeared ...11E1..AA\
ss.:
, before me, the undersigned, a Notary Public in and
personally known to me or proved to me on the basis of satisfactory evidence to be the individual(s) whose
name(s) is (are) subscribed to the within instrument and acknowledged to me that he/she/they executed the
same in his/her/their capacity(ies), and that by his/her/their signature(s) on the instrument, the individual(s), or
the person upon behalf of which the individual(s) acted, executed the instrument.
Notary Public: State of New York

CVS
Nt). Dabis(;.1
ACKNOWLEDGMENT
(for use outside the State of New York)
STATE OF
, COUNTY OF
On the
day of
for said State, personally appeared
in the year
7)6"aa eti41 )Ao,aovii
ss.:
, before me, the undersigned, a Notary Public in and
personally known to me or proved to me on the basis of satisfactory evidence to be the individual(s) whose
name(s) is (are) subscribed to the within instrument and acknowledged to me that he/she/they executed the
same in his/her/their capacity(ies), and that by his/her/their signature(s) on the instrument, the individual(s), or
the person upon behalf of which the individual(s) acted, executed the instrument, and that such individual made
such appearance before the undersigned in
(Insert city or political subdivision and state or county or other place acknowledgment taken).
(Signature and office of individual taking acknowledgment)

1/1/2000
EXHIBIT B
t
AO 93 (Rev. 12109) Search and Sei7ACC Warrant
UNI FED STATES DISTRICT COURT

for the
District Of Columbia
In the Matter of the Search of
2010 Nissan Infiniti
Bearing CT License Plate No. 323-YNS and
)
Vehicle Identification No: JNICV6EL413M261683 )
Case 1: 13-inj-744
Assigned to: Magistrate Judge Deborah A. Robinson
Assigned Date: 10/4/2013
Description: Search and Seizure Warrant
SEARCH AND SEIZURE WARRANT

To:
Any authorized law enforcement officer
An application by a federal law enforcement officer or an attorney for the government requests the search
of the following person or property located in the
Columbia
District of
N/A
A 2010 Nissan Infiniti, black in color, Conneticut License No. 323-YNS and Vehicle Identification Number
JN I CV6EL413M261683.
The person or property to be searched, described above, is believed to conceal
expended bullets or bullet fragmenM vehicle ownership paperwork; maps, documents, and/or photographs of, or
pertaining to, the White House; alcohol or drugs (legal or illegal); and/or evidence of a mechanical malfunction or tack
thereof may be inside the sus t vehicle
I find that the affidavit(s), or any recorded testimony, establish probable cause to search and seize the person or
ProPettY.
YOU ARE COMMANDED to execute this warrant on or before
(not to exceed 14 days)
]in the daytime 6:00 am. to 10 p.m.
El at any time in the day or night as I find reasonable cause has been
establ ished.
Unless delayed notice is authorized below, you must give a copy of the warrant and a receipt for the property
taken to the person from whom, or from whose premises, the property was taken, or leave the copy and receipt at the
place where the property was taken.
The officer executing this warrant, or an officer present during the execution of the warrant, must prepare an
inventory as required by law and promptly return this warrant and inventory to United States Magistrate Judge
(name)
Ell find that immediate notification may have an adverse result listed in 18 U.S.C. 2705 (except for delay
of trial), and authorize the officer executing this warrant to delay notice to the person who, or whose property, will be
searched or seized (check the appropriate box) for
days (not to exceed MO until, the facts justifying, the later specif date of
Date and time issued:
-OCT -4 2013
City and state: Washington, D.C.
e signs
Deborah A. Robinson, U.S. Magistrate Judge

Printed name and title
. 12/09 Search and Sei=urr Warrant (Page 2)
93
Return
Date and lime warrant executed:
Case No..-
fv-S
Copy of warrant and inventory left with:
10/1/13 LoN ; loi 11 6 :0:43 OW-i cer C7 L cccov._%,,\-1Lt . r tuce...5,11.55t Po.u.k. tu ass;yes_ z-c)C1S-D ite3 \AC.-,,rf`.. )1A(SS
-11, k.illori,s'API:. evr-yev* CC Er
rnoiael okfirciNiusSS a.,65,
i -Invent
-. r71- 4
made in the presence of :
Inventory of the property taken and name of any person(s) seized:
(LI
(AWA-0T-C-ret1-5
1-ifi:)" c
rt--)je.r-AL' le5
(-1) 'C' rctr-p-QuNt
""vr-l.kiv
",t-CAICA-C
FILED
OCT- 8 2013
Clerk U.S. District &
Courts for the District Ban

of Columbia
Certification
I declare under penalty of perjury that this inventory is correct and was returned along with the original
warrant to the designated judge.
Date: 107- 1.
6*alExecuting
lic;
Fe.
r 's signar
ire
ke
6thcf...cs / hit eui-t()G,-t i MR

Printed name and fide
AO 106 (Rev. 06/09) Applicatioe fora Starch Warrant
UNITED STATES DISTRICT COURT

for the
District of Columbia
(Briefly describe the properly to be searched
or like:* the person by name and address)
Case 1: 13-mj-744

Bearing CT License Plate No: 323-YNS and
Vehicle Identification No: JN1CV6EL413M261683
APPLICATION FOR A SEARCH WARRANT

I, a federal law enforcement officer or an attorney for the government, request a search warrant and state under
penalty of perjury that I have reason to believe that on the following person or property (ides,* the person or describe the
property to be searched and give its /ocation):A 2010 Nissan Infiniti, black in color, Conneticut License No. 323-YNS and
Vehicle Identification Number JN1CV6EL413M261683.
District of
located in the
, there is now concealed (ideiri6 the
Columbia
person or describe the property to be seized):
expended bullets or bullet fragments; vehicle ownership paperwork; maps, documents, and/or photographs of, or
pertaining to the White House; alcohol or drugs (legal or illegal); and/or evidence of a mechanical malfunction or lack
thereof may be Inside the suspect vehicle
The basis for the search under Fed. R. Crim. P. 4I(c) is (check one or more):
fif evidence of a crime;
isf contraband, fruits of crime, or other items illegally possessed;
property designed for use, intended for use, or used in committing a crime;
0 a person to be arrested or a person who is unlawfully restrained.
The search is related to a violation on.
Code Section
18 U.S.C. 242
Deprivation of Rights Under
_Offense Description
or of Law
The application is based on these facts:

See Attached Affidavit in Support of Search Warrant
!if Continued on the attached sheet.
days (give exact ending date if more than 30 days:
0 Delayed notice of
under 18 US.C. 3103a, the basis of which is set forth on the attached sheet.
) is requested
Applicant's si ture
Felicia Lucas, LT, MPD

Sworn to before me and signed in my presence.

Date:
OC T 4 2013
City and state: Washington, D.C.
Deborah A. Robinson, United States Magistrate Judge

United States District Court

For the
Case 1: 13-mj-744
AFFIDAVIT IN SUPPORT OF A SEARCH WA Assigned to: Magistrate Judge Deborah A. Robinson
FOR THE ENTIRE VEHICLE, INFINITY, G37XS, VEHICLE IDENTIFICATION NUMBER

(VIN#) JN1CV6EL413M261683, CONNECTICUT LICENSE # 323-YNS. THE VEHICLE IS
DESCRIBED AS A TWO (2) DOOR, BLACK COLORED, 2010 NISSAN INFINITI LT.
RESUME: Your affiant is a sworn member of the Metropolitan Police Department, assigned
to the Internal Affairs Bureau (IAB), Internal Affairs Division (IAD), and has been so
employed for more than (19) nineteen years.
Your affiant is currently assigned to the Internal Affairs Division (IAD). Your affiant has
investigated a variety of criminal offenses. She has arrested and assisted in arresting
numerous subjects for various offenses, and assisted with the preparation and execution of
numerous search warrants.
POLICE REPORT: On Thursday, October 3, 2013, Detectives of the Metropolitan Police
Department's Internal Affairs Division, became involved in the investigation of a police
involved shooting.
This incident began on Thursday, October 3, 2013, at approximately 2:18 p.m. at a vehicle
checkpoint to the White House, located at 15th and E Street, Northwest, Washington, D.C.
Members of the United States Secret Service, Uniformed Division, (hereinafter, "USSSUD), encountered the aforementioned vehicle at 15th and E Streets Northwest, Washington
D.C.. The suspect vehicle was being operated by a black female (hereinafter, "Decedent").
Decedent refused to stop at the vehicle checkpoint and made a U-turn and began to flee in
the vehicle. A USSS-UD officer attempted to block the vehicle with a bicycle rack,
however, the vehicle pushed over the bicycle rack, knocking the officer to the ground.
Officers from the USSS-UD initiated a pursuit of the suspect vehicle. Decedent was
observed operating the vehicle erratically, violating several District of Columbia traffic
regulations. Decedent entered a traffic circle against the flow of traffic and drove onto a
curb in front of #10 Maryland Avenue, Southwest, Washington DC. The suspect
vehicle was immediately surrounded by officers from the USSS-UD, and United States
Capitol Police (hereinafter, "USCP"). Decedent then drove the suspect vehicle in
reverse, striking a USSS-UD police vehicle. Members from both. USSS-UD and USCP
then discharged their service weapons at the vehicle. Decedent then drove the suspect
vehicle off the curb, traveling northbound on First Street, Northeast and then eastbound
in the 100 block of Constitution Avenue, Northeast, Washington, D.C. Officers from
USSS-UD and USCP pursued the suspect vehicle to et Street and Constitution
Avenue, Northeast where Decedent stopped the suspect vehicle abruptly, and then
1
turned left and drove over a median strip. Decedent then drove in reverse in the 200
block of Maryland Avenue, Northeast, where Decedent again refused to stop.
At this point, officers from both USSS-UD and USCP fired several rounds into the
suspect vehicle, striking Decedent. The vehicle came to rest on the median area
directly behind the guard's booth on the United States Capitol grounds.
Decedent, along with an uninjured child, were removed from the vehicle. Decedent was
transported to the Washington Hospital Center where she was pronounced dead by Dr.
Christine Trankiem of the medical staff. Decedent's remains were transported to the
Office of the Chief Medical Examiner for the District of Columbia pending an autopsy.
The suspect vehicle was recovered as evidence and has remained in police custody.
Based on the above facts and circumstances, your affiant believes that the vehicle
described above is of evidentiary value and may contain physical evidence such as
expended bullets or bullet fragments fired by the officers; vehicle ownership paperwork;
maps, documents, and/or photographs of, or pertaining to, the White House; alcohol or
drugs (legal or illegal); and/or evidence of a mechanical malfunction or lack thereof may
be inside the suspect vehicle.
Your affiant respectfully requests that a District Court Search Warrant be issued for the
entire vehicle known as a 2010 Nissan Infiniti G37XS, VIN#JN1CV6EL413M261683,
Connecticut License # 323-YNS.
ece.i M
Affiant
United ates Attorney
OCT -4 2013
Subscribed
orn to before me this
day of
Mag s rate
DEBORAH 4. ROBINS4.1.;
MAG1STP.ATE JUDGE
2013
EXHIBIT C
GOVERNMENT OF THE DISTRICT OF COLUMBIA

DEPARTMENT OF HEALTH
CERTIFICATE OF DEATH: FILE DATE: OCTOBER 15, 2013
FILE NUMBER: 108-201 3-00409 I
FULL NAME OP DECEASED: MIRIAM IRIS CAREY

SEX: FEMALE.
DATE OF DEATH: OCTOBER 03, 2013
TIME OF DEATH: 3:08 PM
PLACE OF DEATH: WASHINGTON HOSP1TAt. CENTER,
...SSI`:
DATE OF BIRTH: AUGUST 12, 1979 -
BIRTHPLACE: BROOKLYN, NEW YORK
MOTHER'S MAIDEN NAME: IDELLA CAREY

FATHERS NAME: LEON FAULES .
EDUCATION: BACHELOR'S DEGREE (E.G.BA,BS)
MARITAL. STATUS:NEVER:MARRIED
SURVIVING SPOUSE:
RESIDENCE: STAMFORD, CONNECT1Cyk/,`,e
FUNERAL HOME: ALEXANDER S "0:000;
RACE:: BLACK OR AFRICAN AMERICAN
E - DC
HiSi,ANic ORIGIN: NOT

i" '
SPANISH/FIISPANIC/LATTNO
DATE OF DISPOSITION: OCTOBE
F DISPOSITION::
MANNER OF DEATH: HOMICIDE
CAUSE OF DEATH
A. MULTIPLE GUNSHOT WOUNDS
()TILER SIGNIFICANT CONDITIONS: NONE
CD239562
This document certifies that this is a true and, correct reproduction or abstract of
Records Division of the District of ColUmbia Department of Health.
tne official record filed in the Vital
DATE ISSUED
WARNING: IT IS UNLAWFUL TO MAKE COPIES OF THIS DOCUMENT AND PRESENT THEM AS OFFICIAL COPIES
EXHIBIT D
Grace Funeral Chapels
Printed 101912013
607 North Conduit Blvd

Brooklyn, NY 11208
Statement of Funeral Expenses
Tel: 718-2354088 800-378-7857 Fax: 718-235-6008

www.gracefunerals.com
GRACE
Case Number:
Name of Deceased:
Date of Death:
2013-326
Miriam Carey
1010312013
Arrangement; 1010812013
Invoice To:
Vaiarie Carey
Age: 34
Funeral Home Charges

1
Transfer of Remains
Embalming of Autopsied Remains
$595.00
Other Preparation - Dressing/Casketing
$100.00
Other Preparation - Cosmetology
Basic Arrangements
Supervision for Visitation
$450.00
Supervision for Funeral Service (with Procession to Cemetery)
$300.00
1 @ $1,100.00
$1,100.00
$60.00
$495.00
Use of Facilities for Visitation (Large)
$500.00
Use of Facilities for Funeral Service (Large)
$500.00
10
Hearse - Outside New York City
$400.00
11
Passenger Limo (Long Local within 25 miles)
$800.00
12
Memorial Cards Color or B&W Photo (per 100)
$400.00
$175.00
13
Register Book
14
Hairdressing
$75.00
15
Additional prayer cards that come with American rose
$20.00
16
Disk from live broadcast
$30.00
17
18
$69.95
Casket or Alternative Container
Supplier: Aurora Casket Company, Model: Orchid Blend Gray 18 Gauge Steel
$1,695.00
Subtotal of Funeral Home Charges:
$7,764.95
Cash Advances
1
Mailing Fee
Cemetery or Crematory
Pinelawn Memorial Park
Death Certificate Transcripts
4 @ $18.00
$72.00
Livery
1 @ $30.00
$30.00
Gratuities
Alexander Pope Funeral Home
$350.00
Organist
$150.00
Subtotal of Cash Advances:
GFC-NY
2013-326 Miriam Carey
1 @ $15.00
$15.00
$4,762.00
$20.00
$5,399.00
Page 1 of 2
G R AC .E
Case Number:
Name of Deceased:
Date of Death:
2013-326
Miriam Carey
10/03/2013
Summary of Charges
Funeral Home Charges:
Cash Advances:
Adjustment:
Total Funeral Charges:
Payment:
Balance Due:
GFC-NY
Printed 10/9/2013

607 North Conduit Blvd
Brooklyn, NY 11208
Tel: 718-235-8088 800-378-7857 Fax: 718-235-6008
www.gracefunerals.com
2013-326 Miriam Carey
Arrangement:; 10/08/2013
Statement of Funeral Expenses
Invoice To:
Valarie Carey
Age: 34
$7,764.95
$5,399.00
$0.00
$13,163.95
$8,163.95
$5,000.00
Page 2 of 2
RECEIPT
1.4
Van
BALANCE DUE
1
::
THIS PAYMENT ''
(i./ .-)
AMOUNT OF ACCOUNT I I
CASE #
RECEIVED FROM
co-
BY
CREDIT CARD AUTHORIZATION #
CREDIT CARD
M.O.
M.O. #
CHECK #
CHECK
1-7 CASH
(718) 235-8088
gracefunerals,com
607 North Conduit Blvd.

Brooklyn, NY 11208
ThankcYou
STYLE 1805
CAME
DATE
ADDRESS
SOLD BY
QUAN
1
2
3
4
5
6
7
8
10
11
12
13
14
aty
15
16
I
18
-.......
Coolatidifi
21
22
CUSTOMER'S ORDER NO.
owf
RECEIV
t;)
6-0
EXHIBIT E
PETITION/ADMINISTRATION
OR PROBATE OF WILL
PC-200 REV. 7/13 Page 1
RECORDED:
STATE OF CONNECTICUT
COURT OF PROBATE
[Type or print in ink file in duplicate.]
[Complete Confidential Information Sheetfor PC-200 on last page. Use Second Sheet, PC-180, for additional data.]
TO: COURT OF PROBATE, Stamford
DISTRICT NO. 53
ESTATE OF [Include all names and initials under which any asset was held.]
Miriam I. Carey
DECEDENT'S RESIDENCE AT TIME OF DEATH [Include full address.]

114- I C Woodside Green
Stamford, CT
PETITIONER [Name and address]
Valarie Carey
DA I E OF PETITION
11-5-2013
DATE OF DEATH
10-03-2013
151 WRONGFUL DEATII CLAIM

SED ON:
JURISDICTIO
u Other [P/ease explain other
I Domicile in District Li
jurisdictional basis]
domicile is different than
residence, please explain]
Use Second Sheet, PC-180, for explanation
SURVIVING SPOUSE [Name and address. If there is

no surviving spouse, so state]
There is no surviving spouse
HEIRS, BENEFICIARIES, THE DECEDENT'S CONSERVATOR(S) AND TRUSTEES, if any. Indicate any person who is a minor,
in the military service or under conservatorship or legal disability. C.G.S. 45a-436, 45a-438, 45a-439. Include the name, address
and position of trust of the legal representative of any party who has been adjudicated incapable.
I.
HEIRS [Give names and addresses. In addition, provide date of birth of any child under age 18.]
Spouse
There is no surviving spouse
Children
(Minor child under 18
Address unknown
Children of a deceased child

There are no children of a deceased child
IF NO children or grandchildren, give name(s) and address(es) of decedent's surviving parents:
Continued
PETITION/ADMINISTRATION OR PROBATE OF WILL
PC-200
OR PROBATE OF WILL
PC-200 REV. 7/13 Page 2
RECORDED:
COURT OF PROBATE
[Type or print in ink. File in duplicate]
IF NO spouse, children, grandchildren or parents, give name(s) and address(es) of decedent's brother(s) and sister(s) or
children of any deceased brother or sister. [Identify relationship to decedent.]
IF NONE of the above apply, please refer to C.G.S. 45a-439(a)(3) and provide a family tree.
2. BENEFICIARIES UNDER THE WILL, including trustees [Give name(s) and address(es) and paragraph in Will where interest
in the estate arises and dm& of birth ofany child under age 18. It is not necessary to list the address i it is already listed above.]
There is no known will
3. BENEFICIARIES OF t ESTAMENTARY TRUST(S) ESTABLISHED UNDER THE WILL [Give name(s) and address(es) of
each current beneficiary and presumptive remainder beneficiary and paragraph in Will where the interest in the trust arises
and date ofbirth of any child under age 18. It is not necessary to list the address if it is already listed above. Probate Court
Rules of Procedure sections 1.1(9) and 1.1 (27)]
There is no known Testamentary Trust
4. DECEDENTS CONSERVATOR(S) [Give name(s) and address(es).]

There are no conservators
The petitioner states that the following efforts have been made to identify or locate any person whose name and/or address is unknown:
The petitioner has tried to locate the decedent's child her niece Erica Francis but, the alleged father Eric Francis has been very
elusive and refuses to give the location where Erica resides. There is a custody petition pending in Family Court
THE PETITIONER REPRESENTS that:
.*
Decedent left a will
and codicil(s) herewith presented for probate, dated
Decedent, after making said will and codicil(s)
had a child born, or
adopted a minor child, or
married or
had his or
her marriage dissolved by divorce or annulment. C.G.S. 45a-257a - 257c. [Explain any checked boxes on Second Sheet,
PC-I80.]
The proposed fiduciary named below is not the primary executor named in said will or codicil. [Explain on Second Sheet,
PC-180.]
Decedent left no will.
0
E One or more of the children listed are not also the children of the surviving spouse.
E Decedent owned an interest in real estate other than in survivorship in Connecticut at the time of death.
Decedent, or spouse or children of the decedent

did [Did not ever receive aid or care from the State of Connecticut.
[Ilaffirmative, check appropriate boxtes).]
State of Connecticut 11 Department of Veterans' Affairs. C.G.S. 45a-355.
(Rocky Hill facility)
The estimated value of solely-owned assets, excluding real estate is S
All the foregoing data is true and complete to the best of his or her knowledge and belief and he or she has used all proper
diligence to ascertain the names and addresses of all heirs and beneficiaries. Any additional data given on Second Sheet, PC-180,
is made a part hereof.
Continued
PC-200
OR PROBATE OF WILL
PC-200 REV. 7/13 Page 3
RECORDED:
COURT OF PROBATE
[Type or print in ink. Pile in duplicate.]
WHEREFORE, THE PETITIONER REQUESTS that said will and codicils, if any, be approved and admitted to probate and that
either letters testamentary be issued or letters of administration be granted to the below-named proposed fiduciary.
The representations contained herein are made under the penalties of false statement.
Date:
Petitioner
[Type or print name here.]
CERTIFICATION
certify that a copy of said will and codicil(s), if any, and this petition were sent to the following persons:
Name and Address
Signature of petitioner or attorney

[Type or print name]
PROPOSED FIDUCIARY
IF APPOINTED, I WILL ACCEPT SAID POSITION OF TRUST.
Signature
[Type or print na under signature.]
Address and zip code
arie Carey
Fiduciary 0 is Q is not a resident of the State of Connecticut
Fiduciary 0 is I:is not a resident of the State of Connecticut
Telephone No.:
Telephone No.:
ATTORNEY FOR PROPOSED FIDUCIARY [Name, address, telephone number, Conn. Bar Juris No.]
Signature of attorney for proposed fiduciary:

Each of the undersigned represents that he or she has examined the petition and related documents and HEREBY WAIVES NOTICE OF H ARING
upon the petition and has NO OBJECTION to the granting and approval thereof. II/six/re is insufficient, use General Waiver. PC-181. Please also
print or type name.)
e)-Yte--5
Name: Amy M. Carey-Jones
Name: Franchette R. Carey
rt-71-12,6
C.PV-te
Name: Andrea D. Carey
ame: Idella Carey
PETITION/ADMINISTRATION OR P OBATE OF WILL
Name:
Name:
Continued
PC-200
OR PROBATE OF WILL
PC-200 REV. 7/13 Page 4
RECORDED:
COURT OF PROBATE
[Type or print in ink. File in duplicate.]
CERTIFICATE EXISTENCE OF INTER VIVOS TRUST
[Complete this section for trusts that are beneficiaries under the will.]
This is to certify that the trust document for the [Name of trust]
between [Name(s)]
as
dated
grantor(s)
, as trustee(s)
and [Name(s)]
is in my/our possession, has been duly executed. and the trust is in full force and effect.
Names and addresses of all current trustees:
The representations contained herein are made under the penalties of false statement.
Date:
Trustees Sipature
[Type or print name here.]
Continued
PC-200
CONFIDENTIAL
INFORMATION SHEET
FOR PC-200,
Petition/Administration
or Probate of Will
REV. 7/13
DO NOT RECORD
COURT OF PROBATE
[Type or print in ink]
Court of Probate, Stamford
District
The social security number ofthe decedent is required in connection with this proceeding.
In the Matter of, Miriam 1- Carey
,deceased
Social Security Number:
PC-200
APPOINTMENT OF GUARDIAN AD
LITEM FOR INTERESTED PARTY
PC-182B REV. 7/13
RECORDED:
COURT OF PROBATE
[Type or print in black ink]
COURT OF PROBATE, DISTRICT OF Stamford Probate Distr DISTRICT NO. PD53
IN THE MATTER OF Miriam 1. Carey, deceased (13-0586D)
DATE OF COURT APPOINTMENT

November 19, 2013
PRESIDING JUDGE: Hon. Gerald M. Fox, Jr., Judge

THE COURT HEREBY APPOINTS: James M. Rubino, Esq., 1100 Summer Street, Stamford, CT 06905, (203)327-4212
FOR WHOM, IN THE CAPACITY OF, AND FOR THE REASON INDICATED BELOW:
GUARDIAN AD LITEM FOR
PERSON(S) TO BE REPRESENTED [If a minor, include date of birth.]
A minor who may be interested in said matter or estate.
t
Gerald M. Fox, Jr., Judge
The undersigned hereby certifies that a copy of this appointment was sent on \
1` j
to each party and attorney of
record, as follows:
Name and Address
Valarie Carey,
c/o Eric Francis, address unknown
Eric Francis, address unknown
James M. Rubino, Esq., 1100 Summer Streets Stamford, CT 06905
Idaliz Gomez, Assistant Clerk
APPOINTMENT OF GUARDIAN AD LITEM FOR INTERESTED PARTY
PC-182B
t_..........7
BALANCE DUE
THIS PAYMENT
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AMOUNT OF ACCOUNT
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888 WASHINGTON BOULEVARD

P.O. BOX 10152
STAMFORD, CONNECTICUT 0 904-2152
STAMFORD PROBATE COURT
BY
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DATE k \ 4:414.
4762
U. S. Department of Justice
Civil Rights Division
Office of the Assistant Attorney General
Washington, D.C. 20530
MAR 1 1 2014
Mr. Eric Sanders, Esquire
The Sanders Finn, PC
1140 Avenue of the Americas
9th Floor
New York, NY 10036-5803
Dear Mr. Sanders:
This responds to your letter, dated November 25, 2013, to Attorney General Eric H.
Holder regarding the shooting death of Miriam I. Carey in Washington, District of Columbia.
We apologize for our delay in responding to your letter. In your letter, you request the
Department of Justice to commence an investigation into the circumstances surrounding the
incident.
The Criminal Section of the Civil Rights Division and the United States Attorneys'
Offices are responsible for investigating and prosecuting criminal conduct involving willful
deprivations of rights. In general, these matters include violent bias-motivated crimes, excessive
physical force by local and federal law enforcement officials, violations of involuntary servitude
statutes, and violence against reproductive health care facilities.
As you are aware from speaking with a representative of the United States Attorney's
Office for the District of Columbia, the Department of Justice is reviewing the facts and
circumstances of the shooting death of Miriam I. Carey. Upon conclusion of this thorough and
independent review, the Department will take whatever action is deemed appropriate.
We hope this information is helpful. Please do not hesitate to contact the Department if
we may be of assistance with this or any other matter.
Sincerely,
Joce.t:14
Jocelyn Samuels
Acting Assistant Attorney General
EXHIBIT 3

Ronald C. Machen Jr.
United States Attorney for the
Judiciary Center
555 Fourth St. N. W.
PRESS RELEASE
FOR IMMEDIATE RELEASE
Thursday, July 10, 2014
For Information Contact:

Public Affairs
(202) 252-6933
http://vvww.justice.gov/usao/dc/index.html
U.S. Attorney's Office Concludes Investigation

Into the Death of Miriam Carey
No Charges to Be Filed in Shooting Near U.S. Capitol
WASHINGTON The U.S. Attorney's Office for the District of Columbia announced
today that there is insufficient evidence to pursue federal criminal civil rights or local charges
against officers from the U.S. Secret Service and U.S. Capitol Police who were involved in the
fatal shooting of Miriam Carey on Oct. 3, 2013, just blocks from the U.S. Capitol.
Officials from the U.S. Attorney's Office for the District of Columbia notified Ms.
Carey's family and their representatives of this decision today.
The U.S. Attorney's Office for the District of Columbia and the Metropolitan Police
Department conducted a comprehensive review of the incident, which included interviews of
more than 60 witnesses and careful review of all crime scene evidence, ballistics reports, scene
and traffic video footage, photographs, the autopsy report, and other evidence. After a thorough
review of all the evidence, the U.S. Attorney's Office concluded that the evidence was
insufficient to prove beyond a reasonable doubt that the officers who were involved in the
shooting used excessive force or possessed the requisite criminal intent at the time of the events.
The investigation covered a chain of events that took place on Thursday, Oct. 3, 2013,
between 2:13 p.m. and 2:20 p.m., a time span of just seven minutes. During that period, Ms.
Carey confronted officers at three locations one at the White House and two near the Capitol.
At 2:13 p.m., Ms. Carey, 34, of Stamford, Conn., drove into a well-marked, restricted
White House checkpoint at 15th and E Streets NW, without authorization and without stopping.
After seeing Ms. Carey refuse to stop at the direction of two uniformed Secret Service officers,
an off-duty U.S. Secret Service officer placed a metal bike rack in her path to block Ms. Carey's
exit. Ms. Carey then struck the bike rack, and the off-duty Secret Service officer who was
standing behind it, knocking both the bike rack and the officer onto the ground. The incident at
the White House checkpoint lasted about 30 seconds.
Ms. Carey then drove down Pennsylvania Avenue at speeds estimated at 40-80 mph,
while weaving through traffic, and ignoring red lights.
Four minutes after leaving the White House checkpoint, Ms. Carey arrived at Garfield
Circle, one of two traffic circles in front of the U.S. Capitol. She drove into the circle going
against the flow of traffic, almost hitting another vehicle head-on. Ms. Carey then turned her
vehicle towards the permanently-affixed black barriers that block vehicular traffic on the
pedestrian walkway that leads to the steps of the U.S. Capitol. The pursuing law enforcement
officers blocked Ms. Carey's exit from the left, right and rear of her vehicle, attempted to open
her locked doors, and issued multiple commands for her to exit the vehicle. Ms. Carey then put
her vehicle in reverse and rammed the marked cruiser that was positioned behind her vehicle.
After ramming the cruiser, Ms. Carey drove forward onto the sidewalk, forcing officers
to run out of Ms. Carey's path to avoid being struck by her vehicle. It was at this point, as Ms.
Carey drove on the sidewalk between the wall that borders the U.S. Capitol lawn and the tree
boxes on the sidewalk, that two U.S. Secret Service police officers and a U.S. Capitol Police
officer fired eight rounds at Ms. Carey. Investigators do not believe that Ms. Carey was hit by
any of these rounds. Ms. Carey then drove back around Garfield Circle, against the flow of
traffic, and headed towards Constitution Avenue. The incident at Garfield Circle lasted
approximately 35 seconds.
The U.S. Capitol, the U.S. Supreme Court, and other buildings within the Capitol square
were put on lockdown in response to the "shots fired" report. With continued reckless and
evasive driving, Ms. Carey traveled along the north side of the Capitol and headed towards the
Senate and House office buildings. A U.S. Capitol Police officer who was responding to the
scene in his cruiser slammed into one of the barriers that had just been raised in response to the
lockdown order, causing what sounded like an explosion that was later reported by witnesses.
The cruiser was totaled and the officer had to be airlifted to the hospital for treatment of his
injuries.
Approximately one minute after the shooting at Garfield Circle, Ms. Carey arrived at the
manned U.S. Capitol Police Truck Interdiction Point at 2nd Street and Maryland Avenue NE.
With raised barriers blocking her path, Ms. Carey made a sharp left, drove up a curb, over the
center median, and struck an unmarked Supreme Court police officer's vehicle that had stopped
in front of the Hart office building. After ignoring multiple commands given by officers who
were running towards her vehicle with guns drawn, Ms. Carey revved her engine and then
reversed her vehicle and drove directly at a U.S. Capitol Police officer who was approaching Ms.
Carey's vehicle from behind. As the U.S. Capitol Police officer ran towards the median to avoid
being struck by Ms. Carey's vehicle, he and another officer from the U.S. Secret Service (who
also had fired shots at the Garfield Circle location) started firing. The two officers fired nine
rounds each. Twenty seconds after Ms. Carey had arrived at the 2nd and Maryland location, her
vehicle crashed into the kiosk and came to rest. Ms. Carey was unconscious at this time, and did
not get out of the vehicle. No additional rounds were fired by officers after the crash.
After the shooting and after Ms. Carey's vehicle crashed into the kiosk and came to rest,
the officers on the scene discovered that there was a young child in the vehicle. They carried the
child from the car. The child, who was not seriously injured, was taken to a hospital.
Medical personnel arrived on the scene and attempted to revive Ms. Carey. She was
transported to a hospital, where she was pronounced dead. Ms. Carey sustained five gunshot
wounds to her neck and torso area, one of which was fatal. She was not under the influence of
illegal drugs or alcohol, and no weapon was recovered from inside her vehicle.
Under the applicable federal criminal civil rights laws, prosecutors must establish beyond
a reasonable doubt not only that an officer's use of force was excessive, but also that the officer
willfully deprived an individual of a constitutional right. Proving "willfulness" is a heavy
burden, and means that it must be proven that the officer acted with the deliberate and specific
intent to do something the law forbids. Accident, mistake, fear, negligence and bad judgment do
not establish such a criminal violation. After a careful, thorough and independent review of the
evidence, federal prosecutors have found insufficient evidence to prove beyond a reasonable
doubt that these officers used excessive force under the circumstances known to them at the time
or that they acted with the requisite criminal intent. Accordingly, the investigation into this
incident has been closed without prosecution.
The Justice Department remains committed to investigating allegations of excessive force
by law enforcement officers and will continue to devote the resources necessary to ensure that all
allegations of serious civil rights violations are fully and completely investigated.
14-161
##
EXHIBIT 4
Amended FTCA Administrative Claims

X
IN RE: MIRIAM IRIS CAREY
Claimant,
-againstUNITED STATES OF AMERICA; UNITED STATES SECRET
SERVICE and UNITED STATES CAPITOL POLICE
Respondents
X
To: Respondents' UNITED STATES OF AMERICA; UNITED STATES SECRET SERVICE
and UNITED STATES CAPITOL POLICE
United States of America
do United States Department of Justice
900 Pennsylvania Avenue NW
United States Department of Homeland Security
do United States Secret Service
Office of the General Counsel
Communications Center-LEG
245 Murray Lane, SW, Building T-5
Office of the Chief Counsel
499 South Capitol Street, SW
CLAIMANTS'
1.
The Estate of Miriam Iris Carey by and through her personal representative
Valarie Carey on behalf of decedent's mother Idella Carey.

2.
[della Carey, the decedent's mother and grandmother of minor grandchild EF, the
decedent's daughter.
3.
EF, the minor child of decedent Miriam Iris Carey
AMOUNTS OF CLAIMS
Each claimant seeks $50,000,000.00 (Fifty million dollars).
The aggregate sum certain sought by all claimants is $150,000,000.00 (One hundred-fifty
million dollars)
BASIS OF CLAIMS
1.
These claims for the wrongful death of decedent Miriam Iris Carey arise under
the Federal Tort Claims Act (28 U.S.C. 1346(b), 2401(b), 2674, 2675(a), 2679, and
2680(h)); the Wrongful Death Act of the District of Columbia (D.C. Code 16 2701 et seq.);
the Fourth Amendment (Unlawful Search of the Person, Unlawful Search of Property,
Unlawful Seizure of Person, Excessive Force, Unlawful Seizure of Property); Fifth
Amendment (Due Process and Equal Liberty) and other related local and common law claims.
2.
The claims arise from the numerous intentional, grossly negligent and reckless
actions of the unidentified aggressive Caucasian Male, police officers, supervisors and
managers assigned to the United States Secret Service Uniform Division and United States
Capitol Police, their collective actions caused the 'avoidable' wrongful death of decedent
Miriam Iris Carey.
3.
The decedent Miriam Iris Carey was born from the loving union of Leon Faules
(deceased 1987) and Idella Carey on August 12, 1979 in Brooklyn, N.Y., the fourth of their
five daughters.
4.
Mother, Daughter, Sister and Friend, decedent Miriam Iris Carey held an
important place in the lives of many.

5.
Decedent Miriam Iris Carey grew up in East New York, Brooklyn, where she
learned to face life's challenges with a spirit of self-determination.
6.
Decedent Miriam Iris Carey was an achiever who consistently sought to reach
her life goals.

7.
Decedent Miriam Iris Carey had a passion for cooking and loved life.
8.
Decedent Miriam Iris Carey's greatest joy was spending time with her minor
child EF, as well as family and friends.

9.
Decedent Miriam Iris Carey, RDH, was a licensed dental hygienist.
10.
Decedent Miriam Iris Carey graduated from Brooklyn College with a
Bachelor's of Science Degree in Health and Nutrition Services.

11.
Decedent Miriam Iris Carey aspired to teach others in the field of dentistry.
12.
At the time of decedent Miriam Iris Carey's death, 34, her minor child EF;
Mother ldella Carey and Sisters Franchette R. Carey, Valarie Carey, Amy M. Carey-Jones,
Andrea D. Carey and Cordelia Denise Jones-Hayden; Brother Kenneth Leon Jones and a host
of other family members and friends survived her.
AMENDED ALLEGED FACTS OF THE CLAIMS'
13.
Decedent Miriam Iris Carey was traveling in her 2010 Infiniti G37XS Coupe,
vicinity of 15th Street NW and E Street NW, located next to President's Park, one of the White
House Complex gate entrances.
14.
Decedent Miriam Iris Carey was legally operating the vehicle, her minor child
EF was seated in a child safety seat in the rear of the vehicle.

15.
According to the Application for A Search Warrant, filed in the United States
' This administrative claim details information available at the time of filing. Claimants' reserve the right to
amend this administrative claim for consideration during the presentment and investigation phase to the United
States of America; United States Secret Service Uniform Division and United States Capitol Police based upon
newly discovered facts.
District Court for the District of Columbia dated October 4, 2013, decedent Miriam Iris Carey
entered the aforementioned area approximately 2:18 P.M. According to the Press Release
issued by the United States Attorney's Office for the District of Columbia dated July 10, 2014,
Decedent Miriam Iris Carey entered the aforementioned area approximately 2:13 P.M.
16.
The actual timeline and other facts throughout this matter are open questions.
The actual timeline and other facts will be crystalized if the claims are not adjusted, once a
federal complaint is filed and discovery commences.
17.
Claimants' allege decedent Miriam Iris Carey being unfamiliar with the area,
mistakenly drove past the first guard post at the White House Complex gate entrance because
the entrance was negligently maintained, covered and supervised by police officers,
supervisors and managers assigned to the United States Secret Service Uniform Division.
18.
Claimants' allege decedent Miriam Iris Carey committed no crime, as
mistakenly entering the White House Complex is not violative of any federal or District of
Columbia statute.
19.
Claimants' allege if decedent Miriam Iris Carey lived, the United States Secret
Service Uniform Division would have presumably asserted with the unfettered support of the
United States Attorney's Office for the District of Columbia, specious baseless legal claims
she violated 22-3302(b) Unlawful entry on property.
20.
Claimants' allege the problem is decedent Miriam Iris Carey did not have the
requisite mens rea to violate this section of the law, as an objective analysis of her actions
indicated she never intentionally entered the White House Complex then "refuse to quit the
same on the demand of the lawful occupant or his agent" within the meaning of the statute.
21.
Claimants' allege there is nothing in the Application for A Search Warrant,
filed in the United States District Court for the District of Columbia dated October 4, 2013, or
the Press Release issued by the United States Attorney's Office for the District of Columbia
dated July 10, 2014, that indicates decedent Miriam Iris Carey entered the White House
Complex then "refuse to quit the same on the demand of the lawful occupant or his agent;"
therefore, there was NO PROBABLE CAUSE decedent Miriam Iris Carey violated 223302(b), much less convict her BEYOND A REASONABLE DOUBT.
22.
Claimants' allege it is important to note, after the original federal tort claims
were filed, on May 7, 2014, Mathew E. Goldstein, a Caucasian Male, was accused of violating
22-3302(b), when he drove directly behind a presidential motorcade through the White
House Complex gate at the intersection of 17th Street NW and Pennsylvania Avenue NW.
23.
Claimants' allege despite Mathew E. Goldstein's alleged transgression, he was
not aggressively pursued and fired upon by police officers, supervisors and managers of the
United States Secret Service Uniform Division.
24.
Claimants' allege the aforementioned further supports their theory the gates
surrounding the White House Complex are negligently maintained, covered and supervised by
police officers, supervisors and managers assigned to the United States Secret Service
Uniform Division.
25.
Claimants' allege mistaken entries occurred in the past and will continue to
occur because the White House Complex gates are negligently maintained, covered and
supervised by police officers, supervisors and managers assigned to the United States Secret
Service Uniform Division.
26.
Claimants' allege after realizing her innocent mistake, decedent Miriam Iris
Carey made a U-turn to leave the area heading a short distance eastbound on E Street NW
back towards 15th Street NW.

27.
Claimants' allege for some inexplicable reason, instead of simply allowing
decedent Miriam Iris Carey to leave the area, an unidentified aggressive Caucasian Male in
dark clothed civilian attire, without provocation or legal justification, intentionally, negligently
and recklessly grabbed a metal police barrier and threw himself in front of her vehicle.
28.
Claimants' allege this unidentified aggressive Caucasian Male has a cooler in
his left hand.

29.
Claimants' allege according to the Press Release, this unidentified aggressive
Caucasian Male is an off-duty United States Secret Service officer.

30.
Claimants' allege decedent Miriam Iris Carey simply panicked, then tried to
avoid this unidentified aggressive Caucasian Male by using evasive action going around him,
but since the area is confined, he made contact with her vehicle.
31.
Claimants' allege decedent Miriam Iris Carey had committed no crime, thus the
police had no legal basis to stop her or use any amount of physical force against her.
32.
Claimants' allege this unidentified aggressive Caucasian Male's actions slightly
damaged her vehicle, more importantly, completely startled her, which endangered her safety
as well as Claimant No.: 3, her minor child EF and public.
33.
Claimants' allege after this unidentified aggressive Caucasian Male made
contact with her vehicle, she continued driving through the White House Complex gate to
protect herself and Claimant No.: 3, her minor child EF headed eastbound on Pennsylvania
Avenue NW.
34.
Claimants' allege now completely agitated, the unidentified aggressive
Caucasian Male wanted to 'make that bitch pay' so he along with on-duty police officers,
supervisors and managers in government motor vehicles began to pursue decedent Miriam Iris
Carey and Claimant No.: 3, her minor child EF at high speeds endangering their lives and the
public.
35.
Claimants' allege this unidentified aggressive Caucasian Male with the intent to
`make that bitch pay' he, other police officers, supervisors and managers inconsistent with
their police training, failed to terminate pursuing decedent Miriam Iris Carey and Claimant
No.: 3, her minor child EF.
36.
Claimants' allege the risk to them, the public, the police officers, supervisors
and managers outweighed the benefit of investigating a harmless mistaken entrance through
the White House Complex gate.
37.
Claimants' allege the United States Secret Service Uniform Division Executive
Police Management along with radio dispatchers, inconsistent with their police training, failed
to order this unidentified aggressive Caucasian Male, police officers, supervisors and
managers immediately to terminate pursuing decedent Miriam Iris Carey and Claimant No.: 3,
her minor child EF.
38.
Claimants' allege the risk to them, the public, the police officers, supervisors
and managers outweighed the benefit of investigating a harmless mistaken entrance through
the White House Complex gate.
39.
Claimants' allege in complete fear for she and Claimant No.: 3, her minor child
EF'S safety, decedent Miriam Iris Carey continued traveling eastbound on Pennsylvania
Avenue NW, then at the corner of 3rd Street SW, made a right heading southbound on 3rd
Street SW, still pursued by the unidentified aggressive Caucasian Male, police officers,
supervisors and managers in government motor vehicles.
40.
Claimants' allege both the United States Secret Service Uniformed Division
and the United States Capitol Police engaged pursuing decedent Miriam Iris Carey's vehicle.
41.
Claimants' allege at the corner of Maryland Avenue SW, decedent Miriam Iris
Carey made a left turn heading eastbound on Maryland Avenue SW and struck a curb near 10
Maryland Avenue SW near the James A. Garfield Memorial after being forced over by the
unidentified aggressive Caucasian Male, police officers, supervisors and managers in
government motor vehicles.
42.
Claimants' allege the unidentified aggressive Caucasian Male along with police
officers, supervisors and managers assigned to the United States Secret Service Uniform
Division and the United States Capitol Police surrounded decedent Miriam Iris Carey's
vehicle.
43.
Claimants' allege the immediate area moderately populated with vehicular and
pedestrian traffic.
44.
Claimants' allege the unidentified aggressive Caucasian Male along with other
police officers, supervisors and managers on foot approached decedent Miriam Iris Carey's
vehicle with their service weapons drawn, pointed in the ready position to be fired.
45.
Claimants' allege the unidentified aggressive Caucasian Male first placed
himself at a tactical disadvantage by standing directly in front of decedent Miriam Iris Carey's
vehicle.
46.
Claimants' allege the unidentified aggressive Caucasian Male then circled
around approaching decedent Miriam Iris Carey's driver side, where he had a clear,
unobstructed view of the interior.
47.
Claimants' allege the senior police officers, supervisors and managers never
established firearms control consistent with their police training.

48.
Claimants' allege decedent Miriam Iris Carey noticed these police officers,
supervisors and managers approaching with their service weapons drawn, pointed in the ready
position to be fired, in an attempt to protect herself and Claimant No.: 3, her minor child EF,
panicked placing her vehicle in reverse accidentally striking a marked police vehicle.
49.
Claimants' allege the aggressive Caucasian Male along with other police
officers, supervisors and managers from the United States Secret Service Uniformed Division
and United States Capitol Police without establishing firearms control or legal justification,
inconsistent with their police training discharged their service weapons at decedent Miriam
Iris Carey's moving vehicle.
50.
officers, supervisors and managers several discharged rounds entered decedent Miriam Iris
Carey's vehicle striking her head to the left side, back of the head, back and left arm.
51.
officers, supervisors and managers mortally wounding her.

52.
Claimants' allege as supported by the Autopsy Report dated October 4, 2013,
prepared by the Government of the District of Columbia, Office of the Chief Medical
Examiner, a number of discharged rounds entered decedent Miriam Iris Carey's body from
back to front indicating she was moving away and not a danger to anyone.
53.
Claimants' allege the unidentified aggressive Caucasian Male along with the
other police officers, supervisors and managers will claim they discharged their service
weapons to protect other officers; however, such a specious argument would be in direct
conflict with their police training and applicable law, as you cannot create your own
10
justification using poor tactics.

54.
Claimants' allege decedent Miriam Iris Carey experienced severe shock and
substantial pain throughout her body.

55.
Claimants' allege Claimant No.: 3, sustained severe emotional distress.
56.
Claimants' allege at the time of the firearm discharges, the unidentified
aggressive Caucasian Male along with other police officers, supervisors and managers from
the United States Secret Service Uniformed Division and United States Capitol Police already
knew decedent Miriam Iris Carey was UNARMED.
57.
police officers, supervisors and managers from the United States Secret Service Uniformed
Division and United States Capitol Police already knew decedent Miriam Iris Carey's vehicle
was not considered a DEADLY WEAPON consistent with their police training nor was it used
as a deadly instrument.
58.
Division and United States Capitol Police already knew decedent Miriam Iris Carey did not
use any firearm or other form of deadly physical force against them or others before they
discharged their service weapons towards her.
59.
knew decedent Miriam Iris Carey had committed no crime or violation of any other law.
60.
11
knew Claimant No.: 3, decedent Miriam Iris Carey's minor child EF was in the rear passenger
area of the vehicle but fired anyway.
61.
Claimants' allege despite having actual and/or constructive knowledge as
indicated in Allegation Nos.: 1 through 60, the aggressive Caucasian Male along with other
Division and United States Capitol Police discharged their firearms anyway endangering
decedent Miriam Iris Carey, Claimant No.: 3, her minor child EF and the public.
62.
Claimants' allege the firearms discharge occurred as decedent Miriam Iris
Carey headed eastbound on Maryland Avenue SW towards the James A. Garfield Memorial,
then northbound on
63.
Street NW past the Peace Circle.
Division and the United States Capitol Police continued to pursue now mortally wounded
decedent Miriam Iris Carey in government motor vehicles.
64.
Claimants' allege despite sustaining a mortal wound, decedent Miriam Iris
Carey continued traveling northbound on 1St Street NW, then at the corner of Constitution
Avenue NW, made a right heading eastbound on Constitution Avenue NW, still pursued by
the unidentified aggressive Caucasian Male along with other police officers, supervisors and
managers from the United States Secret Service Uniformed Division and the United States
Capitol Police in government motor vehicles.
65.
Claimants' allege decedent Miriam Iris Carey stopped her vehicle near the
12
corner of 2nd Street NE and Constitution Avenue NE.

66.
Claimants' allege decedent Miriam Iris Carey panicked abruptly turning left
over a median, quickly reversing her vehicle where the unidentified aggressive Caucasian
Male along with other police officers, supervisors and managers from the United States Secret
Service Uniformed Division and the United States Capitol Police without establishing firearms
control and legal justification discharged their service weapons towards her vehicle.
67.
Claimants' allege decedent Miriam I. Carey sustained numerous injuries about
her body, further shock, substantial pain and damage to her vehicle
68.
Claimants' allege decedent Miriam Iris Carey was removed from vehicle alive.
69.
Claimants' allege Claimant No.: 3, decedent Miriam Iris Carey's minor child
EF was not physically injured but, sustained severe emotional distress.

70.
Claimants' allege decedent Miriam Iris Carey was transported to Medstar
Washington Hospital Center where she was pronounced dead by Dr. Christine Trankiem.
71.
Claimants' allege decedent Miriam Iris Carey was later transported to the
Office of the Chief Medical Examiner for an autopsy.

72.
Claimants' allege decedent Miriam Iris Carey clothes were not secured and
vouchered in accordance with United States Secret Service Uniform Division and United
States Capitol Police policies with the intent to cover-up the criminal conduct and civil rights
violations of the unidentified aggressive Caucasian Male along with other police officers,
supervisors and managers from the United States Secret Service Uniformed Division and the
United States Capitol Police against her.
73.
Claimant Idella Carey, decedent Miriam Iris Carey's mother, as well as Sisters
Franchette R. Carey, Valarie Carey, Amy M. Carey-Jones, Andrea D. Carey and Cordelia
13
Denise Jones-Hayden; Brother Kenneth Leon Jones and a host of other family members and
friends viewed some or all parts of this very public shooting that was broadcasted live over the
television airwaves.
74.
Division and the United States Capitol Police intentionally leaked false and misleading
information about decedent Miriam Iris Carey.
75.
Division and the United States Capitol Police intentionally misled the public falsely claiming
through 'anonymous leaks sources' decedent Miriam Iris Carey was mentally disturbed, using
medications.
76.
Claimants' allege they already knew based upon the Toxicology Report that
was untrue.
77.
Division and the United States Capitol Police engaged in the aforementioned with the intent to
cover-up their criminal conduct and violations of her civil rights.
78.
Other than questioning Claimant Idella Carey, decedent Miriam Iris Carey's
mother, as well as Sisters Franchette R. Carey, Valarie Carey, Amy M. Carey-Jones, Andrea
D. Carey and Cordelia Denise Jones-Hayden; Brother Kenneth Leon Jones and a host of other
family members by the Federal Bureau of Investigation and the United States Secret Service
about decedent Miriam Iris Carey's personal activities, not one member of the United States
14
Secret Service Uniform Division or the United States Capitol Police notified them of her death
consistent with department policies.
79.
Claimants' allege because of the intentional, negligent and reckless actions of
Capitol Police, they collectively caused the 'avoidable' death of decedent Miriam Iris Carey.
80.
Claimants' allege because of the intentional, negligent and reckless actions of
Capitol Police they sustained substantial damages.
PRAYER FOR RELIEF
Claimants' pray the United States of America; United States Secret Service Uniform
Division and United States Capitol Police will:
81.
Conduct a full and comprehensive investigation into the claims;
82.
Determine there is substantial competent evidence to support claims presented

herein;
83.
Determine the intentional, negligent and reckless actions of the unidentified

aggressive Caucasian Male along with other police officers, supervisors and
managers assigned to the United States Secret Service Uniform Division and
United States Capitol Police were acting within the scope of their employment;
84.
Determine as a result of the intentional, negligent and reckless actions of the

unidentified aggressive Caucasian Male along with other police officers,
supervisors and managers assigned to the United States Secret Service Uniform
15
Division and United States Capitol Police, they collectively caused the
`avoidable' death of decedent Miriam Iris Carey, therefore, such wrongful
actions are imputed to the United States of America; and
85.
Determine the United States of America is liable for the 'avoidable' death of
decedent Miriam Iris Carey and immediately pay all compensatory damages to
the claimants.
Dated: August 19, 2014

New York, NY
Respectful sub fitted,

By:
Eric Sanders
Eric Sanders, Esq.
THE SANDERS FIRM, P.C.
New York, NY 10036
(844) 839-8077 (Business Telephone)
Website: http://www.thesandersfirmpc.com
16
EXHIBIT 1
8/19/2014
DC Code - 22-3302. Unlawful entry on property.
Code of the District of Columbia (Unofficial)

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Code of the District of Columbia
Title 22. Criminal Offenses and Penalties
' Chapter :13. Trespass; Injuries to Property
22-3302. Unlawful entry on property.
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Current as of...
December 13, 2 013 and through D.C. Act 20-210 (except D.C. Acts 20-130, 20-157, and 20-204)
22-3302. Unlawful entry on property.

(a) (1) Any person who, without lawful authority, shall enter, or attempt to enter, any private dwelling, building, or
other property, or part of such dwelling, building, or other property, against the will of the lawful occupant or of the
person lawfully in charge thereof, or being therein or thereon, without lawful authority to remain therein or thereon
shall refuse to quit the same on the demand of the lawful occupant, or of the person lawfully in charge thereof, shall be
deemed guilty of a misdemeanor, and on conviction thereof shall be punished by a fine of not more than the amount set
forth in 22 -'1571.01, imprisonment for not more than 180 days, or both. The presence of a person in any private
dwelling, building, or other property that is otherwise vacant and boarded-up or otherwise secured in a manner that
conveys that it is vacant and not to be entered, or displays a notrespassing sign, shall be prima facie evidence that any
person found in such property has entered against the will of the person in legal possession of the property.
(2) For the purposes of this subsection, the term "private dwelling" includes a privately owned house, apartment,
condominium, or any building used as living quarters, or cooperative or public housing, as defined in section 3(1)
of the United States Housing Act of 1937, approved August 22, 1974 (88 Stat. 654; 42 U.S.C. 1437a(b)), the
development or administration of which is assisted by the Department of Housing and Urban Development, or
housing that is owned, operated, or financially assisted by the District of Columbia Housing Authority.
(b) Any person who, without lawful authority, shall enter, or attempt to enter, any public building, or other property,
or part of such building, or other property, against the will of the lawful occupant or of the person lawfully in charge
thereof or his or her agent, or being therein or thereon, without lawful authority to remain therein or thereon shall
refuse to quit the same on the demand of the lawful occupant, or of the person lawfully in charge thereof or his or her
agent, shall be deemed guilty of a misdemeanor, and on conviction thereof shall be punished by a fine of not more than
the amount set forth in 22 -1571.01, imprisonment for not more than 6 months, or both.
httplidocode.org isi
etsections/22-3302.html
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8/19/2014
DC Code- 22-3302. Unlawful entry on property.
History
(Mar. 3,1901, 31 Stat.1324, ch. 854, 824; Mar. 4,1935,49 Stat.37, ch. 23; July 17,1952, 66 Stat. 766, ch.
941, 1; Apr. 24, 2007, D.C. Law 16-306, 219, 53 DCR861o; Dec. 10, 2009, D.C. Law 18-88, 215, 56 DCR
7413; June 11, 2013, D.C. Law 19-:117, 201(h), 60 DCR2o64.)
Cross References
Burglary, see 22-801.
Public lands, trespass, damage to, and removal of property, federal crimes and offenses, see 18 U.S.C. 1851 et seq.
Sect ion References
This section is referenced in 23-581.
Prior Codifications
1981 Ed., 22-3102.
1973 Ed., 22-3102.
Effect of Am en dm ents
D.C. Law 16-306 inserted: 'The presence of a person in any private dwelling, building, or other property that is
otherwise vacant and boarded-up or otherwise secured in a manner that conveys that it is v acant and not to be
entered, or displays a no trespassing sign, shall be prima facie evidence that any person found in such property has
entered against the will of the person in legal possession of the property."
D.C. Law 18-88 rewrote the section, which had read as follows: "Any person who, without lawful authority, shall
enter, or attempt to enter, any public or private dwelling, building, or other property, or part of such dwelling,
building, or other property, against the will of the lawful occupant or of the person lawfully in charge thereof, or
being therein or thereon, without lawful authority to remain therein or thereon shall refuse to quit the same on
the demand of the lawful occupant, or of the person lawfully in charge thereof, shall be deemed guilty of a
misdemeanor, and on conviction thereof shall be punished by a fine not exceeding $100 or imprisonment in the
Jail for not more than 6 months, or both, in the discretion of the court. The presence of a person in any private
dwelling, building, or other property that is otherwise vacant and boarded-up or otherwise secured in a manner
that conveys that it is vacant and not to be entered, or displays a no trespassing sign, shall be prima facie evidence
that any person found in such property has entered against the will of the person in legal possession of the
property."
The 2013 amendment by D.C. Law 14-317 substituted "not more than the amount set forth in 22-1c71.01" for
"not more than $1,000" in (a)(1) and (b).
Emergency Legislation
For temporary (90 day) amendment of section, see 7(a) of the Sentencing Reform Congressional Review
Emergency Amendment Act of 2001 (D.C. Act 13-462, October 25, 2000, 47 DCR9443)
For temporary (90 day) amendment of section, see 219 of Omnibus Public Safety Emergency Amendment Act
of
2006 (D.C. Act 16-445, July 19, 2006, 53 DCR6443)

For temporary (90 day) amendment of section, see 219 of Omnibus Public Safety Congressional Review
http://dccode.org/simple/sections/22-3302.htini
2/3
8/19/2014
DC Code- 22-1./.02 Unlawful entryon property.
Emergency Amendment Act of 2006 (D.C. Act 16-490, October 18, 2006, 53 DCR 8686).
For temporary (90 day) amendment of section, see 219 of Omnibus Public Safety Congressio
nal Review
Emergency Amendment Act of 2007 (D.C. Act 17-10, January 16, 2007, 54 DCR 1
479)
For temporary (90 day) amendment of section, see 219 of Omnibus Public Safety Second Congressio
nal Review
Emergency Amendment Act of 2007 (D.C. Act 17-25, April 19, 2007, 54 DCR4036).
For temporary (90 day) amendment of section, see 215 of Omnibus Public Safety and Justice
Emergency
Amendment Act of 2009 (D.C. Act 18-181, August 6, 2009, 56 DCR69o3).

For temporary (90 day) amendment of section, see 215 of Omnibus Public
Safety and Justice Congressional
Review Emergency Amendment Act of 2009 (D.C. Act 18-227, October 21, 2009, 56
DCR 8668).
For temporary (90 days) amendment of this section, see 201(h) of the Criminal Fine Proportion
ality Emergency
Act of 2013 (D.C. Act 20-45, April 1, 2013, 6o DCRS400, 20 DCSTAT 1300).
Legislative History of Law 16-306
Law 16-306, the "Omnibus Public Safety Amendment Act of 2006", was introduced in Council
No. 16-247, which was referred to Committee on the Judiciary. The Bill was adopted on
and assigned Bill
first and second readings
on June 6, 2006, and October 3, 2006, respectively. Signed by the Mayor on October 17,
2006, it was assigned

Act No. 16-482 and transmitted to both Houses of Congress for its review. D.C. Law 16-106 became
effective on
April 24, 2007.

For Law 18-88, see notes following 22-402.
See note to 22-R'101.
Editor's Notes
Applicability of D.C. Law 19-n17: Section 401 of D.C. Law 19-117 provided that the act shall apply
only to offenses
committed on or after June 11, 2013.

This is a fast, unofficial interface to the Unofficial DC Code by openlawdc.
See a problem? Report an issue. Search provided by Swiftvpe.
http://dccode.org/simple/sections/22-3302.htrri
3/3
EXHIBIT 2
AO 106 (Rev. 06109) Apistiottico for aSearch Warrant
UNITED STATES DISTRICT COURT

for the
(Briefly describe the property to be searched
or irlentfb, tire person by name and address)
Bearing CT License Plate No: 323-YNS and
vehicle Identification No: JN1CV6EL413M261683
Case 1:13-mi-744
Assigned Date: 10M72013
APPLICATION FOR A SEARCH WARRANT

1, a federal law enforcement officer or an attorney for the government, request a search warrant and state under
penalty of perjury that I have reason to believe that on the following person or property (identify the person or describe
the
properly robe searched and give its location): A 2010 Nissan Infiniti,, black in color, Conneticut License
No. 323-YNS and
Vehicle identification Number JN1CV6EL413/v1261683.
located in the
District of
person or describe the property to be seizeo):
, there is now concealed (ides the
Columbia
expended bulets or bullet fragments; vehicle ownership paperwork: maps, documents, and/or photographs of, or
pertaining to the White House: alcohol or drugs (legal or ilegal); and/or evidence of a mechanical malfunction or lack
thereof may be Inside the suspect vehicle

The basis for the search under Fed. R. Crim. P. 41(c) is (check one or more):
11( evidence of a crime;

I/contraband, fruits of crime, or other items illegally possessed;
si property designed for use, intended for use, or used in committing a crime;
0 a person to be arrested or a person who is unlawfully restrained.
The search is related to a violation of
Code Section
18 U.S.C. 242
_Offense Description
Deprivation of Rights Under or of Law
The application is based on these facts:

See Attached Affidavit in Support of Search Warrant
Continued on the attached sheet.
0 Delayed notice of
days (give exact ending date if more than 30 days:
under 18 US.C. 3103a, the basis of which is set forth on the attached sheet.
44-4 't
Appticane sI
) is requested
./1-}
Felicia Lucas, LT, MPD

Printed name and time
Sworn to before me and signed In my presence.

Date:
City and state:
- 4 2013
Washington. D.c.
Deborah A. Robinson, United States Magistrate Judge


For the
case 1: 13-mj-744
AFFIDAVIT IN SUPPORT OF A SEARCH WA Assigned to: Magistrate Judge Deborah A. Robinson
Assigned Date: 10i4/2013
Descriphorr: Search and Seizure Warrant
FOR THE ENTIRE VEHICLE, INFINITY, G37XS, VEHICLE IDENTIFICATION NUMBER

(VIN#) JN1CV6EL413M261683, CONNECTICUT LICENSE # 323-YNS. THE VEHICLE IS
DESCRIBED AS A TWO (2) DOOR, BLACK COLORED, 2010 NISSAN INFINITI LT.
RESUME: Your affiant is a sworn member of the Metropolitan Police Department, assigned
to the Internal Affairs Bureau (LAB), Internal Affairs Division (IAD), and has been so
employed for more than (19) nineteen years.
Your affiant is currently assigned to the Internal Affairs Division (IAD). Your affiant has
investigated a variety of criminal offenses. She has arrested and assisted in arresting
numerous subjects for various offenses, and assisted with the preparation and execution of
numerous search warrants.
POUCE REPORT: On Thursday, October 3, 2013, Detectives of the Metropolitan Police
Department's Internal Affairs Division, became involved in the investigation of a police
involved shooting.
This incident began on Thursday, October 3, 2013, at approximately Zi 8 p.m. at a vehicle
checkpoint to the White House, located at 15th and E Street, Northwest, Washington, D.C.
Members of the United States Secret Service, Uniformed Division, (hereinafter, "USSSUD), encountered the aforementioned vehicle at 15th and E Streets Northwest, Washington
D.C.. The suspect vehicle was being operated by a black female (hereinafter, 'Decedent").
Decedent refused to stop at the vehicle checkpoint and made a U-turn and began toflee in
the vehicle. A USSS-UD officer attempted to block the vehicle with a bicycle rack,
however, the vehicle pushed over the bicycle rack, knocking the officer to the ground.
Officers from the USSS-UD initiated a pursuit of the suspect vehicle. Decedent was
observed operating the vehicle erratically, violating several District of Columbia traffic
regulations. Decedent entered a traffic circle against the flow of traffic and drove onto a
curb in front of #10 Maryland Avenue, Southwest, Washington DC. The suspect
vehicle was immediately surrounded by officers from the USSS-UD, and United States
Capitol Police (hereinafter, NUSCP'). Decedent then drove the suspect vehicle in
reverse, striking a USSS-UD police vehicle. Members from both USSS-UD and USCP
then discharged their service weapons at the vehicle. Decedent then drove the suspect
vehicle off the curb, traveling northbound on First Street, Northeast and then eastbound
in the 100 block of Constitution Avenue, Northeast, Washington, D.C. Officers from
USSS-UD and USCP pursued the suspect vehicle to 2nd Street and Constitution
Avenue, Northeast where Decedent stopped the suspect vehicle abruptly, and then
turned left and drove over a median strip. Decedent then drove in reverse in the 200
block of Maryland Avenue, Northeast, where Decedent again refused to stop.
At this point, officers from both USSS-UD and USCP fired several rounds into the
suspect vehicle, striking Decedent. The vehicle came to rest on the median area
directly behind the guard's booth on the United States Capitol grounds.
Decedent, along with an uninjured child, were removed from the vehicle. Decedent was
transported to the Washington Hospital Center where she was pronounced dead by Dr.
Christine Trankiem of the medical staff. Decedent's remains were transported to the
Office of the Chief Medical Examiner for the District of Columbia pending an autopsy.
The suspect vehicle was recovered as evidence and has remained in police custody.
Based on the above facts and circumstances, your affiant believes that the vehicle
described above is of evidentiary value and may contain physical evidence such as
expended bullets or bullet fragments fired by the officers; vehicle ownership paperwork;
maps, documents, and/or photographs of, or pertaining to, the White House; alcohol or
drugs (legal or illegal); and/or evidence of a mechanical malfunction or lack thereof may
be inside the suspect vehicle.
Your affiant respectfully requests that a District Court Search Warrant be issued for the
entire vehicle known as a 2010 Nissan Infiniti G37XS, VIN#JN1CV6EL413M261683,
Connecticut License # 323-YNS.
tuw 1,51.1
!Digit:
(A./
Afflant
United
tes Attorney
OCT -4 2013
orn to before me this
Mag ate
DEBORAH A. POSINSO
13,S. MRSISTPATE JUDGE
day of
2013
EXHIBIT 3
Government of the District of Columbia

Office of the Chief Medical Examiner
AUTOPSY REPORT
CASE NUMBER: 13-02470

NAME OF DECEDENT: MIRIAM IRIS CAREY
AGE: 34 YEARS
RACE!ETH: OTHER
DATE OF DEATH: OCTOBER 3, 2013
GENDER: FEMALE
AUTOPSY DATE: OCTOBER 4, 2013
PERFORMED BY: NIKKI MOURTZINOS, D.O.

FINAL DIAGNOSES
I. Multiple Gunshot Wounds
II. Scattered abrasions, neck, torso, and upper extremities
III. Scattered contusions, neck, torso, left hand, and lower extremities
IV. Lacerations, right arm and left hand
V. Negative post-mortem toxicological examination: See OCME Toxicology Report.
CAUSE OF DEATH:
MULTIPLE GUNSHOT WOUNDS
MANNER OF DEATH:
HOMICIDE
13-02470
MIRIAM IRIS CAREY
Page 2 of 8
PRESENT AT AUTOPSY
Officer Tina Ramadan and Agent James King of the Metropolitan Police Department
were present at the autopsy. Also present at autopsy was Inspector Alfonso M. Dyson
of the United States Secret Service and Sergeant Mark Shutters, an Investigator for the
Office of Professional Responsibility of the United States Capitol Police.
EVIDENCE RELEASED
Projectiles:
Pulled Hair:
Fingernail clippings:
Sex Kit:
Combed hair:
Blood Patch:
Ligature:
Clothing:
Bags from Hands:
Other:
LABORATORY PROCEDURES
Toxicology:
X-ray:
Bacteriology:
Photo:
Dental:
Microscopy:
DNA Cards:
Fingerprints:
X
X
Virology:
EXTERNAL EXAMINATION
The body is that of a well-developed, well-nourished, adult female, measuring 651/4
inches tall and weighing 138 lbs. She appears compatible with the stated age of
34 years. Injuries to the body are noted and will be described below. Debris, including
glass fragments and grass, are present on the body. Dried blood is present on the face,
torso and the upper extremities.
Rigor mortis is fully developed in the extremities, jaw, and neck. Livor mortis is found
on the posterior surfaces of the body except in areas exposed to pressure. The
deceased has long, black and wavy scalp hair averaging 17" in length. The irides are
brown. The comeae are clear. The conjunctivae are pale and show no petechial
hemorrhages. The sclerae are white. Dried blood is present within the nares and the
external auditory canals. The mouth contains natural teeth that are in good condition.
The neck and chest are symmetrical. The abdomen is flat. The external genitalia are
those of a normal adult female. A sanitary napkin overlies the external genitalia. There
13-02470
MIRIAM IRIS CAREY
Page 3 of 8
is asymmetry of the left arm due to injuries that will be described below. The remaining
extremities are symmetrical and without obvious deformities.
An identification band issued by the District of Columbia Office of the Chief Medical
Examiner (DC OCME) bearing the name "(UNIDENTIFIED),(FEMALE)" and the Case
#13-02470 is around the decedent's left ankle and left great toe. Hospital identification
bands encircle the right ankle and left great toe.
CLOTHING
The body is received unclad. No clothing accompanies the body.
SCARS/TATTOOS/MARKINGS
Tattoos are not visualized. A 5/8" scar is on the posterior aspect of the right ankle. A
11/4" x 3/8" hyperpigmented patch of skin is on the posterior aspect of the left thigh.
MEDICAL THERAPY
An endotracheal tube emerges from the mouth. An intraosseous catheter is inserted
into the left shin. Intravascular access catheters are in the right subclavian region, the
left inguinal region, and the right antecubitat fossa. Electrocardiograph pads are on the
chest, the left side of the abdomen, the arms, and the legs. A sitastic sheet dressing is
on the right chest. A 9W thoracotomy incision is on the left side of the chest, displaying
sutures and staples, and located at the level of the left 5th intercostal space. A chest
tube with associated thoracotomy incision is inserted into the right chest at the level of
the 7th intercostal space.
Internal examination also reveals a previously incised pericardial sac due to medical
intervention.
DESCRIPTION OF INJURY
The gunshot wounds are numbered for the purpose-of description only and do not imply
a wound sequence. Projectiles recovered are left in the custody of the Metropolitan
Police Department.
GUNSHOT WOUND OF THE HEAD (GSW # 1)
There is an entrance gunshot wound of the left side of the head, located 4Y2" below the
top of the head and 4" left of the posterior midline (along the convexity of the head).
The entrance gunshot wound measures 3/8" x 1/4" and displays an eccentric ring of
13-02470
MIRIAM IRIS CAREY
Page 4 of 8
abrasion measuring up to 1/8" at the 6 o'clock position. There is no soot or gunpowder

stippling on the surrounding skin. The hemorrhagic wound path injures the left
temporal scalp, the left temporal bone of the skull (internal beveling), the dura, the left
temporal lobe of the brain, the left cerebellar hemisphere, the pontomedullary junction of
the brainstem, the right cerebellar hemisphere, the right temporal lobe of the brain, the
dura, and the right temporal bone at the base of the skull from where a deformed bullet
and bullet fragments are recovered. Bullet fragments are also recovered along the
wound path (cerebellum). Associated injuries include a 5" x 3" hemorrhage of the
parietal scalp, a 31/2" x 11/4" hemorrhage of the left temporal scalp, a 1%" x 1/2"
hemorrhage of the right temporal scalp, a 21/2" x 1" hemorrhage of the posterior
parietaVoccipital scalp, subgaleal hemorrhage of the occipital and bilateral temporoparietal regions, mild subarachnoid hemorrhage of the right cerebral convexity,
hemorrhage of the right temporalis muscle, extensive comminuted fractures of the
calvarium and base of the skull, including bilateral orbital plates, and marked
fragmentation of the cerebellum and medulla oblongata. There is a 3/4" x 1/4" contusion
of the outer canthus of the left eye and a'/" x'/2" contusion of the inner canthus of the
left eye. There is a 2" x 1" contusion of the right upper eyelid.
The gunshot wound is directed from left to right and back to front with minimal
upward/downward deviation.
GUNSHOT WOUND OF THE BACK (GSW # 2)
There is an entrance gunshot wound of the left upper back located 8W below the top of
the head and 2W left of the posterior midline (along the contours of the body). The
entrance gunshot wound measures 5/8" x'1/2" and displays an eccentric ring of abrasion
measuring up to 1/8" at the 7 o'clock position. A 5/8" curvilinear abrasion extends
outward from the entrance gunshot wound at the 11 o'clock position. There is no soot
or gunpowder stippling on the surrounding skin. The hemorrhagic wound path
sequentially injures the skin, soft tissue, and musculature of the left upper back, the soft
tissue and musculature of the posterior neck, the right transverse process of C5 (with
fracture), and the musculature, soft tissue, and skin from the right lower cheek where a
3/4" x 3/8" lacerated exit gunshot wound is located 7" below the top of the head and
3 5/8" right of the anterior midline (along the convexity of the head). A 23/4" x 1" faint
contusion encircles the exit gunshot wound. No bullets or bullet fragments are
recovered along the wound path. Associated injuries include a 1" x 3/4" contusion of the
upper back that overlies the wound path of the bullet. There is no underlying injury to
the spinal cord or the major vessels of the neck.
The gunshot wound is directed from back to front, left to right, and upward.
13-02470
MIRIAM IRIS CAREY
Page 5 of 8

There is an entrance gunshot wound of the right upper back, located 9 3/16" below the
top of the head and 4%" right of the posterior midline (along the contours of the body).
The entrance gunshot wound measures 5/8" x 3/8" and displays an eccentric ring of
abrasion measuring up to 1/8" at the 8 o'clock position. Several abrasions, ranging in
measurement from less than 1/16" to 3/16", surround the entrance gunshot wound
(pseudostippling). There is no soot or gunpowder stippling on the surrounding skin.
The hemorrhagic wound path sequentially injures the skin, soft tissue and musculature
of the right upper back, the right scapula (with fracture), the right proximal humerus
bone (with fracture), and the musculature, soft tissue, and skin of the right shoulder
where a lacerated exit gunshot wound is located 1/4" below the top of the right shoulder.
The exit gunshot wound measures 3/4" x'/4". There is a 2W x 13/4" contusion encircling
the exit gunshot wound. Numerous bullet fragments are recovered along the wound
path (right scapula). Associated injuries include comminuted fractures of the right
scapula and right humerus bone.
The gunshot wound is directed from back to front, left to right with minimal
upward/downward deviation.
There is an entrance gunshot wound of the right upper back (just above the right axilla),
located 11" below the top of the head and 9" right of the posterior midline (along the
contours of the body). The entrance gunshot wound measures 1/2" x 1/4" and displays an
eccentric ring of abrasion measuring up to 1/16" at the 1 o'clock position. A 1" x 5/8"
contusion encircles the entrance gunshot wound. There is no soot or gunpowder
stippling on the surrounding skin. The hemorrhagic wound path sequentially injures the
skin, soft tissue, and musculature of the right upper back, and the musculature, soft
tissue, and skin of the right upper chest from where an exit gunshot wound is located
113/4" below the top of the head and 3 3/8" right of the anterior midline (along the
contours of the body). The exit gunshot wound measures'/2" x'/". A 3" x 2" contusion
encircles the exit gunshot wound. No bullets or bullet fragments are recovered along
the wound path.
The gunshot wound is directed from back to front, right to left, and slightly downward.
GUNSHOT WOUND OF THE LEFT ARM (GSW #5)
There is an entrance gunshot wound of the upper outer left arm, located 5" below the
top of the left shoulder. The gaping entrance gunshot wound measures 1%" x
13-02470
MIRIAM IRIS CAREY
Page 6 of 8
The left arm and forearm display an extensive 8%" x 41/2" area of contusion with
numerous abrasions ranging in measurement from less than 1/16" to 1%"
(pseudostippling). There is no soot or gunpowder stippling on the surrounding skin.
The hemorrhagic wound path sequentially injures the skin, soft tissue, and musculature
of the upper outer left arm, the left humerus bone (with fracture), and the musculature
and soft tissue of the upper inner left arm from where a deformed bullet is located.
Bullet fragments are also recovered along the wound path. Associated injuries include
two contusions of the upper inner left arm (3" x 23/4" and 1W' x 11/2").
The gunshot wound is directed from left to right with slight upward deviation.
ADDITIONAL INJURIES
A Y2" x 3/16" abrasion is on the back of the neck. A 5/8= x 3/8" contusion is on the back
of the neck. Two abrasions (3/16" x 1/8" each) are on the left upper chest. A 2" x11/4"
contusion encircles a 1/4" x 1/16" abrasion of the left upper chest. A 5/16" x 3/8"
abrasion is on the middle of the chest. A 3/4" x Y2" abrasion is on the anterior chest,
between the breasts. A 3/8" x 1/16" abrasion is on the left breast. A'/4" x 3/16"
laceration is on the upper right arm. A 11/2" x 31/2" area of punctate abrasions is on the
right forearm. A 21/4" x 2" abraded area is on the dorsal aspect of the left hand,
displaying several lacerations measuring up to'/". A 1" x 1W contusion is on the
dorsal aspect of the left hand.
A 1/4" x 1/8" contusion is on the right thigh. A 1/2" x 1/4" contusion is on the left thigh. A'/2"
x 1/4" contusion is on the right shin.
INTERNAL EXAMINATION
Injuries described above will not be repeated.
BODY: The body is opened with a Y-shaped incision. The organs occupy their usual
positions and relationships. There is no increased fluid in the pericardial, peritoneal, or
pleural cavities. The abdominal fat has a thickness of 1W.
CARDIOVASCULAR SYSTEM: The heart weighs 240 grams. The epicardial and
endocardial surfaces are smooth and glistening. The great vessels and coronary
arteries arise normally and follow normal courses. The myocardium where sectioned, is
uniformly firm and has a homogeneous, tan-red appearance. The left ventricle has a
thickness of 1.1 cm, the interventricular septum 1.3 cm, and the right ventricle 0.2 cm.
The left ventricular cavity measures 3.1 x 2.2 cm and the right ventricular cavity
measures 2.5 x 1.6 cm. The cardiac valves are thin and delicate. The coronary arteries
13-02470
MIRIAM IRIS CAREY
Page 7 of 8
on cross-section are widely patent and free of significant atherosclerotic plaque

formation. The aorta displays scattered atherosclerotic plaques.
RESPIRATORY SYSTEM: The trachea, mainstem bronchi and primary bronchial
branches are unobstructed. The right lung weighs 240 grams and the left lung weighs
180 grams. The pleural surfaces are smooth and glistening and have a pink-red
appearance. On cross-section, the parenchyma is unremarkable. There are no
pulmonary emboli.
HEPATOBILIARY SYSTEM: The liver weighs 1180 grams. The capsule is smooth and
glistening. On cross-section, the parenchyma is unremarkable. The gallbladder is
unremarkable and contains approximately 15 mL of bile.
GASTROINTESTINAL SYSTEM: The esophagus, stomach, small and large bowel, and
appendix are unremarkable. The stomach contains approximately 15 mL of dark-brown
material; no tablets or capsules are identified. After washing, the esophageal, gastric,
and duodenal mucosa present neither ulcers nor tumors.
PANCREAS: The pancreas is grossly unremarkable with the usual lobular, firm
parenchyma.
HEMOLYMPHATIC SYSTEM: The spleen weighs 80 grams. An accessory spleen is
noted. The capsule is intact. The parenchyma has a normal follicular pattern on
sections. No enlarged or abnormal lymph nodes are found.
GENITOURINARY SYSTEM: The right and left kidney each weigh 100 grams. The
capsules strip with ease revealing smooth cortical surfaces. On cross-section, the
cortices are unremarkable. The collecting systems, ureters, and bladder are
unremarkable. The bladder contains 150 mL of dear yellow urine. The uterus, tubes,
and ovaries are unremarkable. An intrauterine device is appropriately placed.
ENDOCRINE SYSTEM: The pituitary, thyroid and adrenal glands are unremarkable.
MUSCULOSKELETAL SYSTEM: (See Description of injuries.) The uninjured skeleton
is intact and without fractures or deformity. The uninjured red-brown musculature is
unremarkable.
NECK: Sections through the tongue reveal no contusions or hemorrhages. The neck is
dissected in a layer-by-layer fashion. There are no focal hemorrhages of the strap
muscles of the neck or of the intrinsic muscles of the larynx. The hyoid bone, the
thyroid, the cricoid cartilages, and the cervical spine are intact. The larynx is opened
13-02470
MIRIAM IRIS CAREY
Page 8 of 8
posteriorly. The vocal cords are thin and pliable. There is no evidence of infection,
neoplasm, or trauma. The airway is patent.
HEAD AND CENTRAL NERVOUS SYSTEM: (See Description of Injuries). The scalp
is incised and retracted. The cranial vault is opened. The scalp and skull display the
injuries described above. The epidural space is free of hemorrhage. The uninjured
dura is thin, tough, and pliable. The uninjured leptomeninges are glistening and
translucent. The brain weighs 1160 grams and the cerebral hemispheres, midbrain,
and pons display the injuries described above. The uninjured structures at the base of
the brain, including cranial nerves and blood vessels, appear intact. On cross-section of
the brain parenchyma, there is no evidence of natural disease.
SPECIMENS
Submitted for toxicological analyses are samples of blood, bile, urine, vitreous humor,
gastric contents, liver, and brain. Representative sections are retained in formalin.
TOXICOLOGIC EXAMINATION
See toxicology report.
1
NIKKI MOURTZINOS, D.O.

Depuill Medical Examiner
Reviewed by:
1
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NM/ksh/Imt
Date Signed
it
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* * *
GOVERNMENT OF THE DISTRICT OF COLUMBIA

OFFICE OF THE CHIEF MEDICAL EXAMINER
401 E Street SW
Telephone: 202-698-9059 Fax: 202-698-9104
TOXICOLOGY REPORT
CASE IDENTIFICATION
Toxicology Number
TX13-1130
Name:
UNIDENTIFIED, Female
Report Date:
1 1/18/2013
Agency Name:
OCME
Agency Number:
Medical Examiner:
SPECBIEN(S) RECEIVED
Item Sample
Date Received
1 Femoral - Blood
13-02470
Nikki Mourtzinos, D.O.
10/10/2013
Heart - Blood
10/10/2013
Heart-Blood
10/10/2013
10/10/2013
Urine
Bile
10/10/2013
Vitreous Humor
10/10/2013
Liver
10/10/2013
Brain
10/10/2013
Gastric Contents
10/10/2013
10 IVC - Blood
10/10/2013
RESULTS
Item Sample
Compound
Method 1
Method 2
Value
Units
Comment
None were detected
ANALYSIS
DESCRIPTION
Volatiles - HS/GC
Specimen(s) were analyzed by headspace gas chromatography (HS/GC) for ethanol, acetone,
methanol, and isopropanol.
EIA - ELISA
Specimen(s) were screened by enzyme-linked immunosorbent assay (ELISA) for amphetamines,

barbiturates, benzodiazepines, can nabinoids, cocaine metabolites, methadone, methamphetamines,
opiates, phencyclidine, oxycodone, buprenorphine and zolpidem.
Basic Screen - GC/MS/NPD Specimen(s) were screened by gas chromatography-mass spectrometrynitrogen phosphorus
(GC/MS/NPD) for the presence of general basic compounds. The detection of any compound is
concentration dependent.
Screen - LC/MS/MS
Specimen(s) were screened by liquid chromatography-mass spectrometry-mass spectrometry

(LC/MS/MS) for the presence of general compounds. The detection of any compound is concentration
dependent.
LTnCAS W. ZAR LL, MFS, FTS-ABFT

ief Toxicologist, OCME
I certify that lam the Chief Toxicologist at the Office of the Chief Medical Examiner (OCME) for the District of Columbia
or their designee.
The laboratory results summarized above were correctly determined by proper laboratory procedure, are
accurately set forth in this official
report, and are certified by me to be accurate. In addition, I certify that the above analyses were conducted while safeguarding
the chain of
custody of the specimens being analyzed.
TX13-1130 Pagel of 1
EXHIBIT 4
U. S. Department of Justice
Civil Rights Division
Office of the Assistant Attorney General
MAR 1 1 2014
Mr. Eric Sanders, Esquire
The Sanders Firm, PC
9th Floor
New York, NY 10036-5803
Dear Mr. Sanders:
This responds to your letter, dated November 25, 2013, to Attorney General Eric H.
Holder regarding the shooting death of Miriam I. Carey in Washington, District of Columbia.
We apologize for our delay in responding to your letter. In your letter, you request the
Department of Justice to commence an investigation into the circumstances surrounding the
incident.
The Criminal Section of the Civil Rights Division and the United States Attorneys'
Offices are responsible for investigating and prosecuting criminal conduct involving willful
deprivations of rights. In general, these matters include violent bias-motivated crimes, excessive
physical force by local and federal law enforcement officials, violations of involuntary servitude
statutes, and violence against reproductive health care facilities.
As you are aware from speaking with a representative of the United States Attorney's
Office for the District of Columbia, the Department of Justice is reviewing the facts and
circumstances of the shooting death of Miriam I. Carey. Upon conclusion of this thorough and
independent reView, the Department will take whatever action is deemd appropriate.
We hope this information is helpful. Please do not hesitate to contact the Department if
we may be of assistance with this or any other matter.
Sincerely,
Jocelyn Samuels
Acting Assistant Attorney General
EXHIBIT 5

GRETCHEN E. DEIVIAR
OFFICE OF THE GENERAL COUNSEL
General Counsel
THOMAS A. DIBIASE
Deputy General Counsel
JAMES W. JOYCE
Senior Counsel
SCHARON L. BALL
Senior Counsel
April 15, 2014

OGC 2014-028
VIA FEDERAL EXPRESS
Eric Sanders, Esquire
The Sanders Firm, P.C.
New York, NY 10036
Re: Federal Tort Claims Act Administrative Claim
Dear Mr. Sanders:
The United States Capitol. Police (USCP) is in receipt of a document dated January 24,
2014, submitted by your law firm with regard to Miriam Iris Carey. The document was received
on February 4, 2014, and is being processed under the Federal Tort Claims Act procedures.
The USCP Office of the General Counsel will contact you if further information is
needed.
Sincerely,
(s
James W. J ceP
Senior C nsel
499 South Capitol Street, SW, Suite 820, Washington, DC 20003 Voice 202.593.3619 Fax 202.593.4477
Mailing Address; 119 D Street, NE, Washington, DC 20510
EXHIBIT 6
U.S. DeparLment of Homeland Security
UNITED STAVES SECRET SERVICE

APR 15 2014
REGISTERED MAIL
Eric Sanders, Esq.
Ninth Floor
New York, New York 10036
RE:
Administrative Tort Claim of the Estate of Miriam Iris Carey, et al.
Dear Mr. Sanders:

This letter is in response to your clients' administrative tort claim dated
January 24, 2014, which you submitted to the United States Secret Service (Secret
Service). The claim was received by the Secret Service's Office of the Chief Counsel on
February 24, 2014. The Secret Service will contact you if further information is needed.
To ensure that the Secret Service receives your correspondence in a timely
manner, please direct any future mailings to the following address: Communications
Center-LEG, Attn: Office of the Chief Counsel, 245 Murray Lane, SW, Building T-5,
Washington, DC 20223.
Sincerely,
'le
Donna L. Cahill
Chief Counsel
'
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COMMUNICATIONS CENTER (LEG)

245 Murray Lane, S.W., Bldg. T-5
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UNITED oral, S P05701SERVIDE;)
REGISTERED MAIL"'
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P611 7690.01000.9311
RE 001 639 090 US

Label 200, August 2005
Eric Sanders, Esq.

1140 Avenue of the Americ
Ninth Floor
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EXHIBIT 7
SUPERIOR COURT OF THE DISTRICT OF COLUMBIA

CRIMINAL DIVISION
DCTN: 014013691
Lockup No: 28
Case No:
Citation Date:
INFORMATION
The United States Attorney for the District of Columbia informs the Court that within the District of Columbia:
Defendant's Name: Mathew EGoldstein
(First)
(MI)
681895
(Last)
14063549
(PM)
(CCNO)
(DOB)
Also Known As: Mathew Evan Goldstein

(First)
(Middle)
(Last)
Address:
I On or about May 6, 2014, within the District of Columbia, Mathew E Goldstein, without lawful authority, did remain,
attempt to enter or enter certain property, that is, White House Complex, against the will of the United States
government, the lawful occupant thereof and the person lawfully in charge thereof. (Unlawful Entry, in violation of
22 D.C. Code, Section 3302 (2001 ed.))
Co-Defendants:
Rule 105:
Judge:
United States Attorney for the District of Columbia

By: Assistant United States Attorney
By Officer:
N
ist,_
Date: May 7, 2014

Badge No.:
PSA: 206 Domestic El
SUPERIOR COURT FOR THE DISTRICT OF COLUMBIA

CRIMINAL DIVISION
UNITED STATES
VS
GOLDSTEIN, MATHEW EVAN

The event occured on 05/06/2014 at approximately 1632 at 1600 PENNSYLVANIA AVE NW in Washington DC,
ON TUESDAY, MAY 6, 2014, AT APPROXIMATELY 1632 HOURS, AO (J. HOHMAN #0567 SS/UDW)
WHILE IN FULL UNIFORM AT THE INTERSECTION OF 17TH STREET NW AND PENNSYLVANIA
AVENUE NW, WAS CONTROLLING TRAFFIC FOR THE ARRIVAL OF AN AUTHORIZED US SECRET
SERVICE MOTORCADE THROUGH THE WHITE HOUSE COMPLEX ENTRANCE GATE LOCATED ON
PENNSYLVANIA AVENUE AT 17TH STREET NW. AS THE MOTORCADE APPROACHED THE GATE
SOUTHBOUND ON 17TH STREET AND MADE A LEFT TURN INTO THE GATE, AO OBSERVED A
GRAY HONDA CIVIC BEARING MARYLAND LICENSE PLATE 5AH5380 FOLLOWING THE FINAL CAR
IN THE MOTORCADE AT A DISTANCE OF LESS THAN FIVE FEET (NOI #7016343176), THE HONDA
CIVIC CONTINUED TO FOLLOW THE MOTORCADE THROUGH THE GATE AT SUCH A CLOSE
DISTANCE THAT THE GATE BOLLARDS WERE UNABLE TO BE RAISED TO PREVENT ACCESS TO
THE VEHICLE, AND THE UNAUTHORIZED VEHICLE PROCEEDED THROUGH THE GATE, PAST A
LARGE 'DO NOT ENTER' SIGN AND TWO ROWS OF LARGE METAL BOLLARDS DESIGNED TO
PREVENT UNAUTHORIZED VEHICLE ACCESS (NOT #7016343165), INTO THE RESTRICTED 1600
BLOCK OF PENNSYLVANIA AVENUE NW.
ONCE THE VEHICLE WAS IDENTIFIED AS BEING UNAUTHORIZED, AAO (T. OSBORNE #1334
SS/UDW), WHO WAS ON FOOT PATROL IN THE 1600 BLOCK OF PENNSYLVANIA AVENUE NW,
HALTED THE VEHICLE BY STEPPING IN FRONT OF IT NEAR THE INTERSECTION OF JACKSON
PLACE NW AND PENNSYLVANIA AVENUE NW. AAO REMOVED THE DRIVER; OF1, LATER
IDENTIFIED BY HIS MARYLAND DRIVER'S LICENSE AS GOLDSTEIN, MATHEW EVAN (W/M, DOB:
FROM THE VEHICLE AND PLACED HIM IN CUSTODY. THE VEHICLE
WAS THEN DECLARED SUSPICIOUS.
MPDC EOD WAS CONTACTED AND RESPONDED TO THE SCENE AND DECLARED THE VEHICLE
SAFE.
OF1 WAS PLACED UNDER ARREST FOR *UNLAWFUL ENTRY' AT 1744 HOURS AND TRANSPORTED
TO MPDC 2ND DISTRICT FOR PROtESSING.
0E1 WAS MIRANDIZED ON SCENE AT 1708 HOURS
OFI'S VEHICLE WAS TOWED FOR SAFEKEEPING BY ANA TOWING TO 1620 2ND STREET SW.
The event and acts described above occurred primarily in the District of Columbia and were committed as described by
defendant(s) listed in the case caption.
Subscribed at)
41
fore me this. May 6, 2014
ilia I i
CA)
le(
'Sedge
OTT
Witnesif
Clerk
i
HOHMAN, JOHN 1001373
Printed Name of Member / CAD#
Printed Name of Witness / Deputy Clerk
The foregoing statement was made undo: penalty of criminal prosecution and punishment for false statements pursuant to D.C. Code 22.2514
Dee. 1,0. Di_ osn.3i2o 3
Page: 1 0t 1
EXHIBIT 8

Ronald C. Machen Jr.
United States Attorney for the
Judiciary Center
555 Fourth St. N. W.
PRESS RELEASE
FOR IMMEDIATE RELEASE
Thursday, July 10, 2014
For Information Contact:

Public Affairs
(202) 252-6933
http://www.justice.gov/usaoldc/index.html
U.S. Attorney's Office Concludes Investigation

Into the Death of Miriam Carey
No Charges to Be Filed in Shooting Near U.S. Capitol
WASHINGTON The U.S. Attorney's Office for the District of Columbia announced
today that there is insufficient evidence to pursue federal criminal civil rights or local charges
against officers from the U.S. Secret Service and U.S. Capitol Police who were involved in the
fatal shooting of Miriam Carey on Oct. 3, 2013, just blocks from the U.S. Capitol.
Officials from the U.S. Attorney's Office for the District of Columbia notified Ms.
Carey's family and their representatives of this decision today.
The U.S. Attorney's Office for the District of Columbia and the Metropolitan Police
Department conducted a comprehensive review of the incident, which included interviews of
more than 60 witnesses and careful review of all crime scene evidence, ballistics reports, scene
and traffic video footage, photographs, the autopsy report, and other evidence. After a thorough
review of all the evidence, the U.S. Attorney's Office concluded that the evidence was
insufficient to prove beyond a reasonable doubt that the officers who were involved in the
shooting used excessive force or possessed the requisite criminal intent at the time of the events.
The investigation covered a chain of events that took place on Thursday, Oct. 3, 2013,
between 2:13 p.m. and 2:20 p.m., a time span of just seven minutes. During that period, Ms.
Carey confronted officers at three locations one at the White House and two near the Capitol.
At 2:13 p.m., Ms. Carey, 34, of Stamford, Conn., drove into a well-marked, restricted
White House checkpoint at 15th and E Streets NW, without authorization and without stopping.
After seeing Ms. Carey refuse to stop at the direction of two uniformed Secret Service officers,
an off-duty U.S. Secret Service officer placed a metal bike rack in her path to block Ms. Carey's
exit. Ms. Carey then struck the bike rack, and the off-duty Secret Service officer who was
standing behind it, knocking both the bike rack and the officer onto the ground. The incident at
the White House checkpoint lasted about 30 seconds.
Ms. Carey then drove down Pennsylvania Avenue at speeds estimated at 40-80 mph,
while weaving through traffic, and ignoring red lights.
Four minutes after leaving the White House checkpoint, Ms. Carey arrived at Garfield
Circle, one of two traffic circles in front of the U.S. Capitol. She drove into the circle going
against the flow of traffic, almost hitting another vehicle head-on. Ms. Carey then turned her
vehicle towards the permanently-affixed black barriers that block vehicular traffic on the
pedestrian walkway that leads to the steps of the U.S. Capitol. The pursuing law enforcement
officers blocked Ms. Carey's exit from the left, right and rear of her vehicle, attempted to open
her locked doors, and issued multiple commands for her to exit the vehicle. Ms. Carey then put
her vehicle in reverse and rammed the marked cruiser that was positioned behind her vehicle.
After ramming the cruiser, Ms. Carey drove forward onto the sidewalk, forcing officers
to run out of Ms. Carey's path to avoid being struck by her vehicle. It was at this point, as Ms.
Carey drove on the sidewalk between the wall that borders the U.S. Capitol lawn and the tree
boxes on the sidewalk, that two U.S. Secret Service police officers and a U.S. Capitol Police
officer fired eight rounds at Ms. Carey. Investigators do not believe that Ms. Carey was hit by
any of these rounds. Ms. Carey then drove back around Garfield Circle, against the flow of
traffic, and headed towards Constitution Avenue. The incident at Garfield Circle lasted
approximately 35 seconds.
The U.S. Capitol, the U.S. Supreme Court, and other buildings within the Capitol square
were put on lockdown in response to the "shots fired" report. With continued reckless and
evasive driving, Ms. Carey traveled along the north side of the Capitol and headed towards the
Senate and House office buildings. A U.S. Capitol Police officer who was responding to the
scene in his cruiser slammed into one of the barriers that had just been raised in response to the
lockdown order, causing what sounded like an explosion that was later reported by witnesses.
The cruiser was totaled and the officer had to be airlifted to the hospital for treatment of his
injuries.
Approximately one minute after the shooting at Garfield Circle, Ms. Carey arrived at the
manned U.S. Capitol Police Truck Interdiction Point at 2nd Street and Maryland Avenue NE.
With raised barriers blocking her path, Ms. Carey made a sharp left, drove up a curb, over the
center median, and struck an unmarked Supreme Court police officer's vehicle that had stopped
in front of the Hart office building. After ignoring multiple commands given by officers who
were running towards her vehicle with guns drawn, Ms. Carey revved her engine and then
reversed her vehicle and drove directly at a U.S. Capitol Police officer who was approaching Ms.
Carey's vehicle from behind. As the U.S. Capitol Police officer ran towards the median to avoid
being struck by Ms. Carey's vehicle, he and another officer from the U.S. Secret Service (who
also had fired shots at the Garfield Circle location) started firing. The two officers fired nine
rounds each. Twenty seconds after Ms. Carey had arrived at the 2nd and Maryland location, her
vehicle crashed into the kiosk and came to rest. Ms. Carey was unconscious at this time, and did
not get out of the vehicle. No additional rounds were fired by officers after the crash.
After the shooting and after Ms. Carey's vehicle crashed into the kiosk and came to rest,
the officers on the scene discovered that there was a young child in the vehicle. They carried the
child from the car. The child, who was not seriously injured, was taken to a hospital.
Medical personnel arrived on the scene and attempted to revive Ms. Carey. She was
transported to a hospital, where she was pronounced dead. Ms. Carey sustained five gunshot
wounds to her neck and torso area, one of which was fatal. She was not under the influence of
illegal drugs or alcohol, and no weapon was recovered from inside her vehicle.
Under the applicable federal criminal civil rights laws, prosecutors must establish beyond
a reasonable doubt not only that an officer's use of force was excessive, but also that the officer
willfully deprived an individual of a constitutional right. Proving "willfulness" is a heavy
burden, and means that it must be proven that the officer acted with the deliberate and specific
intent to do something the law forbids. Accident, mistake, fear, negligence and bad judgment do
not establish such a criminal violation. After a careful, thorough and independent review of the
evidence, federal prosecutors have found insufficient evidence to prove beyond a reasonable
doubt that these officers used excessive force under the circumstances known to them at the time
or that they acted with the requisite criminal intent. Accordingly, the investigation into this
incident has been dosed without prosecution.
The Justice Department remains committed to investigating allegations of excessive force
by law enforcement officers and will continue to devote the resources necessary to ensure that all
allegations of serious civil rights violations are fully and completely investigated.
14-161
44#
EXHIBIT 5
U.S. Department of Homeland Security
UNITED STATES SECRET SERVICE

2014
REGISTERED MAIL

Ninth Floor
RE: Administrative Tort Claim of the Estate of Miriam. Iris Carey, et al.
Dear Mr. Sanders:
This letter pertains to your clients' Federal Tort Claims Act (FTCA) admin
istrative claim
dated January 24, 2014, as well as their amended claim dated August 19,
2014. These
documents were received by the United States Secret Service Office of the
Chief Counsel on
February 24, 2014 and September 2, 2014, respectively.
Your clients' claim is denied. This denial constitutes a final disposition
of both the
original and amended claim for purposes of 28 U.S.C. 2675.
If your clients are dissatisfied with this decision, they have the right to file
suit under the
FTCA in the appropriate federal district court no later than six (6) month
s from the date of this
letter.
S cerely/
i\elt
A.T.
Deputy Director
RE 001 639 174 US
COMMUNICATIONS CENTER (LEG)

ATTN: TOM HUSE
245 MURRAY LANE SW BLDG T-5
WASHINGTON, DC 20223
UNITED STATES POSTAL SERVICE C~

Ninth Floor
psN 7690.01.0i00.9111
111111111111111111111111111
R E 001 639 174 U S
REGISTERED MAILTM
Label 200, August 2005
itz-*EV
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US POSTAGE
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EXHIBIT 6
PHONE: 202-224-9806

OFFICE OFTHE CHIEF
119 D STREET, NE
WASHINGTON, DC 20510-7218
COP 20140197
VIA CERTIFIED MAIL
New York, NY 10036
RE: Amended Federal Tort Claims Act Administrative Claim
Dear Mr. Sanders:
This letter is in response to your client's amended claim for damages dated August 19,
2014, and received by the United States Capitol Police (USCP) on August 25, 2014, under the
provisions of the Federal Tort Claims Act.
After thoroughly investigating, evaluating, and reconsidering all of the available
information and the circumstances surrounding this amended claim, the USCP Office of the
General Counsel (OGC) has recommended that this claim be denied. After further review and
reconsideration of its merits, I must concur with the recommendation of the USCP OGC in this
matter.
This decision is final and constitutes final agency action pursuant to section 2675 of Title
28, United States Code.
If you elect to file suit, you must file in an appropriate United States district court no later
than six (6) months after the date of the mailing of this letter.
Sincere
dAdC
Kim C. Dine
Chief of Police
Nationally Accredited by the Commission on Accreditation for Law Enforcement Agencies, Inc.
WASHINGTON, DC 20510-7218
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SERGEANT AT ARMS, U.S. HOUSE OF REPRESENTATIVES
EXHIBIT 7
United States Secret Service Protective Mission Panel

(USSSPMP)
Joseph Hagin, Thomas Perrelli, Danielle Gray, Mark Filip
The Honorable Jeh Johnson.
Secretary, Department of Homeland Security
Dear Secretary Johnson:
We write in response to your memorandum dated October 10, 2014 requesting our
independent assessment and recommendations for the security of the White House compound,
recommendation of candidates to be the next Director of the Secret Service and subjects for
further review.
The Panel immediately began reviewing documents, receiving briefings, and identifying
a list of persons to be interviewed. The Panel received fill' cooperation from the Secret Service,
DHS, and the White House, as well as numerous other state and federal agencies and individuals
who offered their time and insight into a multitude of issues. We met with approximately 50
employees of the Secret Service itselfofficers and agents currently in service, junior and midlevel managers and Assistant Directors, officials from headquarters and field offices, agency
leadership, and a number of the agency's past directors and other former agents. The Panel felt it
was critical to receive extensive information from experts outside the Service who were engaged
in missions similar to the Service, had expertise in management of law enforcement or security
agencies, or were involved in the development or deployment of protective technology.
Ultimately, the Panel met with over 120 representatives and leaders from a broad array of federal
agencies and research facilities, as well as with representatives of major metropolitan police and
security forces.
The enclosed report seeks to provide a roadmap for reform that a new director and newly
invigorated Secret Service will need to implement. We believe that the Secret Service must
commit itself to the kind of utmsfonnative, continuing change discussed in this Report.
I 2. IC 1 if
Date
-*-Joseph W. Hagin
545/Y
Date
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Date
United States Secret Service Protective Mission Panel

(USSSPMP)
Joseph Hagin, Thomas Perrelli, Danielle Gray, Mark Filip
Executive Summary
to
Report from the
United States Secret Service
Protective Mission Panel
to the
Secretary of Homeland Security
DECEMBER 15, 2014
This page intentionally left blank.
EXECUTIVE SUMMARY'
The paramount mission of the United States Secret Serviceprotecting the President and
other high-ranking national officialsallows no tolerance for error. A single miscue, or even a
split-second delay, could have disastrous consequences for the Nation and the world. The men
and women of the Secret Service fulfill one of the most important obligations in this country, and
they do so often with no personal recognition, no desire for fame, and modest compensation. We
know special agents of the United States Secret Service as the silent figures around the President,
but we tend to notice them only in the extraordinarily rare moments when they fail. Most
Americans know little of the work of the Secret Service's Uniformed Division and do not realize
that it is the Uniformed Division that plays a primary role in the protection of the White House.
Throughout its work, the Protective Missions Panel ("the Panel") developed an even
greater appreciation than each of us had previously for the work of the Secret Service. From our
meetings at the highest levels of the Secret Service, to meetings with line agents and officers, we
saw individuals who were unwavering in their passion and dedication to duty. In discussions
with others inside and outside of the U.S. government, including other law enforcement agencies
and the U.S. military, there was agreement that, when it comes to providing personal protection
to a chief executive and others, the Secret Service is without peer. Facing constant threats and
charged with guarding the world's most powerful and visible head of state and the most
accessible executive mansion of any large nation, the Secret Service has an extraordinary track
record of success. This is not to say that the Secret Service does not make mistakes. But we owe
the agents, officers, and line personnel of the Secret Service a debt of gratitude.
For an organization that has a zero-failure mission, however, a commitment to constant
improvement and a refusal to compromise are essential. The Secret Service must be prepared to
face every evolving threat in a rapidly changing environment and to stay constantly ahead of
those who could threaten the White House, the President, and other protecteesincluding the
First Family, the Vice-President, and foreign heads of state. That central mission requires a
dynamic organization that constantly evaluates its performance and seeks to improve, with
leaders able to take the agency to that higher level of performance. It requires personnel who are
not only committed to the mission and of great character and ability, but who are also highly
trained and innovative. And it requires deployment of the best available technology to augment
the talents and training of the men and women of the Secret Service.
The Panel was established following the events of September 19, 2014, when a lone
individual leapt over the White House fence, onto the North Lawn, and ultimately into the White
House itself. This Panel's mandate was not to redo the report prepared by Department of
Homeland Security ("DHS") Deputy Secretary Alejandro Mayorkas ("Mayorkas Report"), which
makes specific fmdings related to the September 19 fence jumping incident, but to accept its
findings and undertake a broader review of the Secret Service's protection of the White House
compound.
On December 15, the United States Secret Service Protective Mission Panel submitted its full Report to the
Secretary of Homeland Security for review. This Executive Summary provides a high-level overview of our
independent assessments and recommendations to the Secretary.
The Panel enjoyed full cooperation from the Secret Service, DHS, and the White House,
as well as numerous other state and federal agencies and individuals who offered their time and
insight into a multitude of issues. We met with approximately 50 employees of the Secret
Service itselfofficers and agents currently in service, junior and mid-level managers and
Assistant Directors, officials from headquarters and field offices, agency leadership, and a
number of the agency's past directors and other former agents. The Panel thanks Acting Director
Joe Clancy for this cooperation and for all that he has already done to put the Secret Service back
on the right course.
The Panel also felt it was critical to receive extensive information from experts outside
the Service who were engaged in missions similar to the Service, had expertise in management
of law enforcement or security agencies, or were involved in the development or deployment of
protective technology. Ultimately, the Panel met with over 120 representatives and leaders from
a broad array of federal agencies and research facilities, as well as with representatives of major
metropolitan police and security forces. Among government agencies alone, in addition to
Secret Service and White House personnel, the Panel met with representatives of the Central
Intelligence Agency; the Defense Advanced Research Projects Agency; the Department of
Defense's Joint Non-Lethal Weapons Directorate; the Defense Threat Reduction Agency; the
Federal Bureau of Investigation Security Division and Washington Field Office; the Department
of Homeland Security's Office of Cybersecurity and Communications, Federal Protective
Service, Office of the Chief Financial Officer, Office of the General Counsel, Office of
Infrastructure Protection, Office of the Inspector General, Office of Operations, Coordination,
and Planning, the Science and Technology Directorate's Homeland Security Advanced Research
Projects Agency, and the Transportation Security Administration; the U.S. Marine Corps; the
U.S. Marshal Service; the U.S. Navy; the U.S. Park Police; the Pentagon Force Protection
Agency; Sandia National Laboratories; and the Department of State's Bureau of Diplomatic
Security. The Panel also met with, among others, local law enforcement agencies that often
partner with the Secret Service.
Our review and recommendations fall within three general areas: training and personnel;
perimeter security, technology, and operations; and leadership. A number of the
recommendations go directly to issues highlighted by the events of September 19. Among other
things, the Panel believes strongly that the fence around the White House needs to be changed as
soon as possible to provide better protection. We recognize all of the competing considerations
that may go into questions regarding the fence, but believe that protection of the President and
the White House must be the higher priority. As the Executive Branch, Congress, and the
Service itself have all recognized, the fence must be addressed immediately.
A better fence can provide time, and time is crucial to the protective mission. Every
additional second of response time provided by a fence that is more difficult to climb makes a
material difference in ensuring the President's safety and protecting the symbol that is the White
House. Additionally, the ease with which "pranksters" and the mentally ill can climb the current
fence puts Secret Service personnel in a precarious position: When someone jumps the fence,
they must decide, in a split-second, whether to use lethal force on a person who may not actually
pose a viable threat to the President or the White House. By deterring these more frivolous
threats, a more effective fence can minimize the instances when such difficult decision making is
required.
We decline to say precisely what the optimal new fence should look like. Importantly,
designers of the new fence must balance security concerns with the long and storied tradition of
the White House being the "People's House." These historical, symbolic, and aesthetic factors
deserve consideration, but ultimately they should not be permitted to delay or prevent a fence
that could save lives. A number of common-sense improvements should be explored. For sure,
the fence must be taller; even an increase of four or five feet would be materially helpful.
Horizontal bars, where climbers can easily place feet or hands, should be eliminated or placed
where they provide little assistance. The top of the fence can also be manipulated in certain
wayssuch as including curvature outward at the top of the fenceto make scaling it much
more difficult for most. Any of these adjustments, the Panel is certain, can be made without
diminishing the aesthetic beauty or historic character of the White House grounds.
But the problems exposed by recent events go deeper than a new fence can fix. The
Panel thus looked more broadly at the Service, recognizing that issues affecting the Service's
protective operations more generally have their greatest impact on protection of the White House
and President. Of the many concerns the Panel encountered, the question of leadership is, in our
view, the most important. The Panel found an organization starved for leadership that rewards
innovation and excellence and demands accountability. From agents to officers to supervisors,
we heard a common desire: More resources would help, but what we really need is leadership.
Consistent with Secretary Johnson's directive, the Panel considered the qualities needed
in a new director for the Service, as well as the next management team. The Panel has concluded
that the Service needs strong, new leadership that can drive change within the organization.
While we believe the right person could come from many different backgrounds and believe that
leadership qualities are more important than any particular background, we think the right person
should come from outside the Service. We know that many in the Service today would argue
that its unique protective mission can only be understood and managed by someone who has
served within its ranks. The Panel appreciates the virtue of experience in the Service, but we
believe that at this time in the agency's history, the need for Service experience is outweighed by
what the Service needs today: dynamic leadership that can move the Service forward into a new
era and drive change in the organization. The next director will have to make difficult choices,
identifying clear priorities for the organization and holding management accountable for any
failure to achieve those priorities. Only a director from outside the Service, removed from
organizational traditions and personal relationships, will be able to do the honest top-to-bottom
reassessment this will require. Finally, this will also require support from a management team
that combines diverse strengthsincluding those in the Service as well as those from outside,
those with special agent or law enforcement training, and those with other professional
backgrounds.
The new leader will need to help the Secret Service learn to improve itself by listening to
the outside. The Panel heard one common critique from those inside and outside the Service:
The Service is too insular. The Secret Service is justifiably proud of its preeminence and its
history. But the Secret Service could benefit greatly from reaching outside itself to other entities,
3
here and abroad, that share a similar mission or have knowledge and skills that would be
valuable to the Secret Service. The Panel spent significant time interviewing leaders inside and
outside the federal government who are experts in technology and protection of physical
locations, and the Service could benefit greatly from long-term consistent engagement with these
types of complementary experts. Such engagement should include regular and hard-edged
evaluations of the Service itself, as well as its methods; this kind of constant evaluation and
improvement needs to become part of the Secret Service's culture.
The next director also needs to help the Secret Service be clear about its priorities, and
there should be no doubt about what comes first. The agency exists to protect the President and
its other very high-level protectees. Yet the Secret Service has sometimes acted in ways that
send mixed signals on a number of fronts. While promoting other capacities might help bring
resources into the agency, the new leadership needs to think carefully about how the agency's
core priorities are implemented up and down the organisation, and focus on improving them.
The new leader will also need to reform the Secret Service's administrative capabilities.
If the Secret Service is to remain the best in the world and defeat its adversaries every time, it has
to be the best in every facet of the game. An agency that needs the best agents and officers on
the front lines needs a hiring process run by human resources experts valued for their specialized
knowledge about how to recruit and retain talent, in a timely and efficient manner. An agency
that needs to be three steps ahead of those who would do its protectees harm needs more of the
best and most innovative scientists and engineers dreaming up ways to defeat the next threat.
And an agency that needs to spend every penny wisely needs an administrative department that
can demonstrate with rigorous precision why additional resources are necessary and knows how
to budget for it.
Finally, the next director will need to help strengthen a culture of accountability. The
organization asks its protective agents to stand in front of a bullet to protect the President. It
expects its Uniform Division officers to maintain high alertness at every moment of a long shift.
It requires its advance teams to scour massive new venues for the smallest weakness. The
agency's zero-failure mission requires that its high standards be met. In order for the Service's
agents and officers to meet its high standards, they must see that the organization itself believes
in its standards and enforces them in a consistent, evenhanded manner. In other words, agency
leadership, managers, and front line supervisors must believe and show that they are accountable
for their mission. These are not just morale issues, or issues of fairness or trust. Accountability
creates the culture of performance that the Secret Service needs to meet its zero-failure mission.
The necessary changes will thus require strong leadership, but they will also require
resources. The Secret Service is stretched to and, in many cases, beyond its limits. Perhaps the
Service's greatest strengththe commitment of its personnel to sacrifice and do the job "no
matter what"has had unintended consequences. Special agents and Uniformed Division
personnel protecting the White House work an unsustainable number of hours. Rather than
invest in systems to manage the organization more effectively and accurately predict its needs,
the Service simply adds more overtime for existing personnel. Rather than sending its agents
and officers to training, it keeps them at their posts.
The Panel found that, due in large part to limitations on personnel, the Service's training
regimen has diminished far below acceptable levels. The Presidential Protective Division's
("PPD") so-called "Fourth Shift" had once ensured that for two weeks out of every eight, the
President's detail was maintaining its strength, practicing, and getting better. But Secret Service
reports show that in FY 2013, apart from firearms re-qualifications and basic career development
technical requirements, the average special agent received only forty-two hours of training. The
Uniformed Division has never trained at the level of PPD, but today training for the Uniformed
Division has also fallen below acceptable levels. In FY 2013, Service data shows that the
Uniformed Division as a whole received 576 hours of training, or about 25 minutes for each of
over 1300 Uniformed Division officers. We believe that the Secret Service should be staffed at a
level that enables it to provide a true Fourth Shift for training to its Presidential Protective
Division and Vice-Presidential Protective Division special agents, and to ensure that Uniformed
Division officers are in training for no less than 10% of their time.
Providing more time for training requires increased staffing, but the Secret Service needs
more agents and officers even beyond the levels required to allow for in-service training. The
President and other protectees cannot receive the best possible protection when agents and
officers are deployed for longer and longer hours with fewer and fewer days off. For years, the
Service has taken on additional missionsin both its protective and investigative rolesbut has
not matched its request for additional resources to those expanded missions. The Service has to
increase the number of agents and, to an even greater extent, increase the size of the Uniformed
Division to ensure protection of the White House. We think that a new director should give
serious consideration to whether there are collateral or non-essential missions that can be shed,
though we believe the Service's investigative mission provides benefits to its protective mission.
We also recognize that the new director must carefully manage the Service's other missions to
ensure adequate resources are available to protection. But under any scenario, the Service has to
increase significantly in size.
This Report attempts to quantify the additional personnel needed, but the Panel has been
hamstrung to some extent by the lack of complete data. Put simply, the Service does not have
systems in place to make the most prudent budgeting choices. Like so many agencies, the
Service has, for years, looked at its base budget and tried to ballpark how much more it might be
able to get through the OMB and congressional processes. The result, however, is that no one
has really looked at how much the mission, done right, actually costs. That is why one of our
most important recommendations is that a new director start with a zero-based budget. Forget
about what the Service has asked for in the past: Define the mission, and make the argument to
policy makers in the Executive Branch and Congress that this sumwhich we believe to be
more than current appropriationsis needed. As an interim step, the Panel recommends that
Congress and the Executive Branch work together to ensure appropriations sufficient for an
additional 85 special agents and 200 Uniformed Division officers; the Panel believes this is a
first step, but likely not the last step, to ensure adequate training and personnel for the White
House.
The Panel also reviewed a variety of physical security and operational issues at the White
House, and makes a number of recommendations about the ongoing security of the compound.
Aspects of this discussion are classified, and the Panel believes strongly that operational issues
5
related to the protection of the White House should not be the subject of detailed public debate in
this Report or any other fora. The events of September 19 highlighted a number of potential
vulnerabilities that need to be addressed quickly. Fortunately, those events have served as a call
to action for the Service.
Many of the recommendations set forth below are not new. Indeed, some of them
precisely echo recommendations that the White House Security Review made in 1995 ("1995
Security Review") but that remain concerns today. Others even harken back to
recommendations made in the Warren Commission Report following the assassination of
President Kennedy. And still others track internal recommendations made by the Service. As
the Secret Service itself has recognized, the Service has often made recommendations and
proposed solutions as it identified problems, but has frequently failed to implement its own
recommendations.
Some of the changes address isolated problems, with well-defined options to solve them,
while others will require far more study by, we hope, a dynamic, new management team that will
lead the Service into the future. Following September 19, the Service began implementing a
number of reforms, and those efforts have continued alongside the Panel's work.
Finally, the Panel recognizes that many of these recommendations will be difficult.
Many will cost money, which is always a challenge in Washington D.C. We are mindful of the
current budget climate and the value of taxpayer dollars, and we would not recommend spending
a penny unwisely.
Many others will require strong leadership and a will to change, which can be difficult for
an organization with such a storied history. Some in the Secret Service will resist and may need
to move on. But the Secret Service cannot lose focus on its core and essential mission: the
protection of the current, past, and future Presidents of the United States. As a nation, we should
not fail to make prudent investments in personnel, technology, and leadership when the stakes
are so high.
Summary of Recommendations
Training and Personnel
Provide a true "Fourth Shift" for training the Presidential and Vice-Presidential Protective
Divisions, so that they spend two weeks out of every eight in training, and ensure that
Uniformed Division ("UD") officers are in training for no less than 10% off their time: Only
with constant training can all of the teams at the White House perform the coordinated actions needed
to effectively respond.
Implement integrated training focused on ensuring that all teams at the White House know
their roles in responding to specific threats: Teams need to train with the full complement of
forces with which they will operate in real life, and the training needs to be provided force-wide, not
just to those on duty on the day that training is scheduled.
Train in conditions that replicate the physical environment in which they will operate: A
security team should also be trained so that it is intimately familiar with the space in which it is
operating.
Increase the Uniformed Division, as quickly as can be appropriately managed, by an initial 200
positions, and the Presidential Protective Division ("PPD") by 85 positions. Perform additional
analyses and, likely, further increases as necessary: Both UD and PPD are currently stretched
beyond their limits.
Reform and professionalize recruiting, hiring, promotion and rotation process that puts the
most talented, capable individuals in place as efficiently as possible: The Service must continue
efforts to develop a professionalized recruiting and hiring process that finds talented individuals,
evaluates candidates rigorously for the PPD, and hires them quickly.
Technology, Perimeter Security, and Operations!

Ensure that the Office of Technical Development and Mission Support proactively reviews and
refreshes the Service's technological footprint. The Service should receive dedicated funds for
technology, both within its own budget and within DHS Science & Technology's budget, to
accomplish these tasks: Technology systems used on the complex must always remain on the
cutting edge, and the Service must invest in technology, including becoming a driver of research and
development that may assist in its mission.
Replace the outer fence that surrounds the 18 Acres to give Secret Service personnel more time
to react to intrusions: The current seven-and-a-half-foot fence, not just along Pennsylvania Avenue
but around the compound's entire perimeter, must be replaced as quickly as possible.
Leadership
Clearly communicate agency priorities, give effect to those priorities through its actions, and
align its operations with its priorities: The Panel believes the Secret Service's leadership must
make those choices in a manner to ensure that its core protective mission remains first priority.
Promote specialized expertise in its budget, workforce, and technology functions. Filling
important administrative functions with agents rather than professional administrators may
not be optimal.
2
A number of our recommendations pertaining to technology, perimeter security, and operations contained
classified material and are thus not reproduced here.
7
Present a zero-based or mission-based budget that will provide sufficient resources to

accomplish its mission, beginning immediately by working within DEIS to adopt a workforce
staffing model: The Service must build a new budget from the ground up by defming its mission,
determining what it will take to achieve it, and asking for that. The mission is important enough to
justify that approach.
Create more opportunities for officers and agents to provide input on their mission and train its
mid- and lower-level managers to encourage, value and respond to such feedback: Leadership
and, even more critically, mid- and lower-level managers, need to make clear that their mission
requires that they get things rightand thus that the agency values information out of sync with the
status quo or the leadership's views.
Lead the federal protective force community: Collaboration with protective forces like the Federal
Protective Service, the Pentagon Force Protection Agency, the FBI Police, and the State Department's
Bureau of Diplomatic Security and other agencies, especially on technology, could significantly
increase opportunities for innovation.
Receive periodic, outside assessments of the threats to and strategies for protecting the White
House compound: The Secret Service should engage other federal agencies to evaluate the threats
that the agency faces and its ways of doing business.
Resume participation in international fora with comparable protective services of friendly
nations: While most national protective forces do not compare to the Secret Service, those of certain
nations are much more similar than they are different.
Give leadership's priorities and reforms the organization's sustained attention and hold the
agency accountable through to their completion: Following through on reforms and
recommendations has been an issue for the Service in the past.
Implement a disciplinary system in a consistent manner that demonstrates zero tolerance for
failures that are incompatible with its zero-failure mission: It is clear that the rank-and-file--and
even very senior current and former members of the Secret Servicedo not have confidence that
discipline is imposed in a fair and consistent manner.
Hold forces accountable for performance by using front-line supervisors to constantly test
readiness: To be ready for a job where quick reactions and reflexes are critical, supervisors need to
drive home to their officers and agents that the front line is constantly being tested.
The next director of the Secret Service should be a strong leader from outside the agency who
has a protective, law enforcement, or military background and who can drive cultural change
in the organization and move the Secret Service forward into a new era: The need to change,
reinvigorate, and question long-held assumptionsfrom within the agency itselfis too critical right
now for the next director to be an insider.
Establish a leadership development system that identifies and trains the agency's future
managers and leaders: To promote from within and move the agency forward, however, the Secret
Service needs to do a better job of identifying future leaders and preparing them for the role.
EXHIBIT 8
Mr. Eric Sanders

Sir, l am writing this in confidence since my job with the United States Capitol Police would be in
jeopardy for publicly coming forward.
I recently read online "Did She Have To Be Killed" by David Montgomery of the Washington Post, and I
felt compelled to contact you.
First, please give my condolences to the family of Ms. Miriam Carey for their loss.
While the US District attorney has failed to prosecute the officers involved in the actual shooting, I
would like you to focus on another aspect of this tragedy, one that was vaguely mentioned in the article,
the neglect of the Capitol Police.
It is well known throughout the Department that the Capitol Police were operating the "pop-up"
barriers on the Avenues without procedures in place. This is especially relevant since when Ms. Carey
was driving towards Capitol Hill, the officers operating the safety barriers would have/should have
raised these barriers, and this alone would have prevented Ms. Carey from driving up Constitution
Avenue where she was ultimately shot. While people may speculate as to the outcome, there was a
high probability Ms. Carey's vehicle would have been diverted with the proper use of the barricades
making the outcome of this much different. The fact that the Capitol Police almost killed one of their
own shows the uncertainty in which many of these officers routinely operate. There has even been talk
that the officers working these avenues did not have up-to-date training to operate these barriers,
which shows negligence on the Capitol Police. I would think your office could make the proper inquires
to get this information or by asking around the Department.
The most recent event involving the Capitol Police during the president's State of the Union address has
also brought Ms. Carey's issue to light. The fact that members of congress want to know how an armed
robbery suspect was let go by the Capitol Police while Ms. Carey ended up dead should also help in your
cause. Here they used the barriers to prevent the vehicle from entering the Capitol area, which should
have happened in Ms. Carey's incident. There have been rumors the Department is terrified of the two
cases being brought up simultaneously because it will revive interest and talk about Ms. Carey.
Whether you have to force Congress, go through the media, or demonstrate on Capitol Hill, I do hope
you continue to fight on behalf of the Carey family, especially for the child she left behind.
I am not sure if any of this will help you or benefit the family of Ms. Cary's for the loss they have
suffered.
I hope you understand my reluctance for not attaching by name.
Concerned employees
`/,'',/,
CGO
Mr. Eric Sanders+

The Sanders Firm
9th Floor
New York, NY 10036
)09 FEB 2015 ni t.
ateCTIMORE:44D '"<tn12

In The Matter of Miriam Carey v. United States of America, Et Al.

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CLAIM FOR DAMAGE,

RUCTIONS: Please read carefully the instru

1. Submit to Appropriate Federal Agency:

2. Name, address of claimant, and claima

United States of America; United States Secr

Eric Sanders, Esq., of THE SANDERS FIRM

6. DATE AND DAY OF ACCIDENT

7. TIME (A.M. OR P.M.)

place of occurrence and

Claimants filed and presented previous fede

City, State, and Zip Code).

CLAIMANT, STATE THE NAME

The Estate of Miriam Iris Carey - Emotiona

ADDRESS (Number, Street, City, State,

12. (See instructions on reverse).

AMOUNT OF CLAIM (in dollars)

and Zip Code)

12c. WRONGFUL DEATH

12d. TOTAL (Failure to specify may cause

instructions on rever e side).

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G FORM 14. DATE OF SIGNATURE

CIVIL PENALTY FOR PRESENTING

Authorized for Local Reproduction

CRIMINAL PENALTY FOR PRESENTING

STANDARD FORM 95 (REV. 2/2007)

PRESCRIBED BY DEPT. OF JUSTICE

ted, it is essential that the claimant provide the followin

13. Have you filed a claim with your

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14. If deductible, state amount

with your carrier, what action has your insurer taken

17. Do you carry public liability and property

or proposed to take with reference to your claim?

(It is necessary that you ascertain these facts).

Yes If yes, give name and address of insuran

Claims presented under the Federal Tort Claim

A CLAIM SHALL BE DEEMED TO HAVE BEEN

STANDARD FORM 95 REV. (2/2007) BACK

1140 Avenue of the Americas,

November 25, 2013

The Honorable Eric Holder

An innocent unarmed United States Citizen with a toddler was killed

2013-11-14 Justice is right in Gods eye sight.

people will be murdered.

2013-11-14 This is important to me because as a Veteran and an American, I

have a repeat of this!

They need explanations just like anyone else would.

2013-11-14 that could have been my sister

2013-11-14 Because that could have been my sister.

for officers to take other measures.

and concern for the Human Life

2013-11-14 It could have been my family member or friend. Clarity is needed.

2013-11-14 I wouldn't want something like that to happen to one of my family

I don't like the way justice is being abandoned in America.

2013-11-14 I FEEL THIS COULD HAVE BEEN HANDLE DIFFERENTLY

2013-11-14 An abuse of authority resulting in the killing of an unarmed women

2013-11-14 supporting a old friend

2013-11-14 I believe that justice needs to be served.

2013-11-14 I felt that incident was reenacted. In the beginning I

2013-11-14 Miriam is my was and still my best friend and I would

2013-11-14 Justice for this unjustified murder of Miriam Carey

2013-11-15 They didn't have to kill her!