THE VOICE OF MODESTO

CLAIM AGAINST THE CITY OF MODESTO
(Government Code Section 910 et.seq.)

Mindy Livingston hereby makes claim against the City of Modesto and submits the following statements in support of the claim:

1. Claimant’s address is 421 McHenry Avenue, Modesto, California 95354.

2. Notices concerning the claim should be sent directly to claimant.

3. All injuries incurred as a result of this claim occurred  prior to, during, and subsequent to the Alcohol Decoy Operation conducted by the City of Modesto Police Department, against the claimant’s business, on or about, December 13, 2008.  The subject criminal charges against the claimant were ultimately dismissed, on, or about, June 11, 2009.

4. Damages incurred by the claimant occurred in the City of Modesto, County of Stanislaus.

5. The circumstances giving rise to this claim are as follows:  Officials and employees of the City of Modesto, acting with ulterior motives, intentionally encouraged, solicited, and or, conspired to commence a sting operation at the claimant’s business for the purpose of slandering and libeling the claimant.  These individuals attempted to interfere with the business interests of the claimant. Additionally, said individuals violated claimant’s civil rights and the right of commerce she maintains as a citizen of the United States. The aforementioned actions of these individuals led to the criminal citation of the claimant and disciplinary proceedings by the Department of Alcohol and Beverage Control. All criminal citations and disciplinary proceedings were subsequently dismissed.

6. Claimant’s injuries include, but are not limited to, business losses, damage to personal and business reputation, violation of civil rights and right of commerce.  In addition, claimant has suffered pain and suffering.

7. The names of City officials and employees include, but are not limited to the following:
MPD Officer Stewart, and MPD Officer Rakaitis:

8. My claim as of this date is in an amount that would place it within the jurisdiction of the Superior Court.  The claim is based on injury, damages and loss in amount to be proved later.

Dated: September 11, 2009
 ___________________________
 Mindy Livingston
 MedMar LLC 
 Claimant