Cotchett Pitre & McCarthy LLP
A Litigation Law Firm - San Francisco,
Los Angeles, New York, Seattle
840 Malcolm Road, Suite 200
Burlingame, CA 94010
Tel: (650) 697-6000
Fax: (650) 697-0577

Ryder Law Firm
Jesse P. Ryder, Esq.
6739 Myers Road
E. Syracuse, NY 13057
Tel: (315) 382-3617
Fax: (315) 295-2502

May 25, 2022

Via U.S. Mail and E-mail

Hon. Mayor Byron W. Brown
201 City Hall
Buffalo, NY 14202

Dear Mayor Brown,

This letter is to follow up on our discussion at the funeral services of our clients, the family of Ms. Celestine Chaney, regarding the 27-billion-dollar Class action lawsuit we are contemplating against all responsible parties for the massacre of the outstanding innocent citizens of your city of Buffalo. These parties include but are not limited to, gun manufacturers, gun sellers, social media, the school, the parents with whom he lived and stored his guns, and others.

As Mr. Jesse Ryder and I mentioned, we represent several victims of this tragedy. These include employees of Tops Grocery Store, shoppers who were inside the store, some of whom were saved from the gunman by hiding in the storage cooler, and individuals in the parking lot who narrowly escaped the gunman's wrath. The class will consist of these individuals, direct victims, shoppers, employees, and customers in the parking lot where two people were murdered.

During the course of our discussion, you inquired whether we would be interested in representing your City of Buffalo for the losses the City has incurred, including the cost of police and fire personnel and other City losses, harms, and damages. As we indicated, we would be honored to represent your City of Buffalo on a Contingency Fee basis for 25% of any recovery and will advance all Court Costs and fees to be reimbursed at the conclusion of the litigation. I have conferred with Mr. Joseph Cotchett of the firm COTCHETT PITRE & McCARTHY LLP who has extensive experience in representing Cities and Public Entities in cases involving mass torts.

Lastly, I also indicated that we intend to set aside an amount from any recovery to create a local Student Non-violent Coordinating Committee (Buffalo SNCC), as well as a local SNCC in every major city in America, with the aim and objective of teaching and counseling in local schools from Elementary to High Schools the importance of racial tolerance, non-violence, and the scientific fact of the unifying humanity of all human beings. This was the approach in my hometown of Selma, Alabama in creating the successful Selma SNCC.

We will also push for legislation to create a "Red Flag Registry", patterned after the sex offense registry, to require mandatory action against any individual who expressly or impliedly indicates an intent to harm others on social media, in publication, or in any manner whatsoever, including listing the names and tracking the whereabouts of such individuals. Of course, appropriate due process will be afforded, such as the person being evaluated by three independent mental health professionals and a judicial hearing confirming the truth and veracity of such threats.

Mr. Cotchett, Mr. Ryder, and I eagerly await your response affirming the proposed representation. After your confirmation, we will forward you a formal retainer agreement confirming the contingency fee of 25% of recovery and our advancement of the cost of Litigation.

Please feel free to contact me at any time on my cell phone: 415-601-0268.