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GERAGOS & GERAGOS

A PROFESSIONAL CORPORATION
LAWYERS
HISTORIC ENGINE CO. NO. 28
644 South Figueroa Street
Los Angeles, California 90017-3411
Telephone (213) 625-3900
Facsimile (213) 232-3255
Geragos@Geragos.com

MARK J. GERAGOS
SBN 108325
BEN J. MEISELAS
SBN 277412
Attorneys for Sexual Assault Victim Kim A. Adams

GERAGOS&GERAGOS, APC

HISTORIC ENGINE CO. NO. 28

644 South Figueroa Street
Los Angeles, California 90017-3411

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CALIFORNIA GOVERNMENT TORT CLAIM SECTION 910

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KERN COUNTY

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KIM ADAMS

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Claim No.: UNASSIGNED

Victim,

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adv.
KERN COUNTY; KERN COUNTY
PROBATION DEPARTMENT; DAVID
M. KUGE; REYES SOBERON JR.

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Defendants.

CALIFORNIA GOVERNMENT TORT

CLAIM, NOTICE OF FILING AND LATE
FILING PURSUANT TO GOVERNMENT
CODE SECTIONS 911.4-912.2

Clerk of Board of Supervisors

1115 Truxtun Avenue, 5th Floor
Bakersfield, California 93301

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-1CALIFORNIA GOVERNMENT TORT CLAIM SECTION 911.4-912.2

GERAGOS&GERAGOS, APC

HISTORIC ENGINE CO. NO. 28

644 South Figueroa Street
Los Angeles, California 90017-3411

I.

STATEMENT OF CLAIM
A. INTRODUCTION

Sexual assault victim Kim Adams brings this claim against the man who sexually

assaulted her, Kern County Probation Officer Reyes Soberon Jr., as well as against Kern

County and the Kern County Probation Department which enabled Mr. Soberons conduct

and attempted to cover it up.

There is currently a criminal case pending against Probation Officer Soberon in Kern

County Superior Court (People v. Soberon, Case No. BF162579A) for sexually assaulting

Kim Adams, and at least two other DOE victims, yet the Kern County Probation Department

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and Kern County District Attorneys Office have held no press conferences and have issued

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no public statements regarding this serial molester within their ranks.

At every turn, Kim Adams has been told by Kern County Officials not to go to the
FBI, not to go to the media, and not to hire a lawyer.
It is unknown how many other victims of Mr. Soberon have been silenced. However,
there are believed to be countless other victims.
Mr. Soberon continues to walk the streets, as felony counts against him for sexual
assault against the two other DOE victims have been inexplicably reduced to misdemeanors
to apparently enable the County and Mr. Soberon to avoid a public preliminary hearing.

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On July 25, 2016, the criminal Court has scheduled a reset trial date for Mr.

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Soberon, and it remains unknown if Mr. Soberon has been offered a sweetheart plea deal at

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the same time Ms. Adams has been compelled by Kern officials to suffer in silence.

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Ms. Adams will be silenced no more, and brings this claim to ensure Mr. Soberon and

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Kern County are brought to justice on behalf of herself, and potentially countless other

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women who have been sexually tortured by Soberon and silenced by Kern County.

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B. REYES SOBERON, JR.

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From around April 2012 through June 2015, Kern County Probation Officer Reyes

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Soberon repeatedly, brutally, methodically, and serially molested and sexually assaulted Kim
Adams who was on probation and purportedly assigned to his supervision.

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-2CALIFORNIA GOVERNMENT TORT CLAIM SECTION 911.4-912.2

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Soberon would mislead Ms. Adams into coming to the probation office and take Ms.
Adams to a corner where he would digitally penetrate her vagina and anus, while sticking his
tongue down her throat, moaning: I want you to make me cum in my pants.
This routine was repeated over and over again.

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GERAGOS&GERAGOS, APC

HISTORIC ENGINE CO. NO. 28

644 South Figueroa Street
Los Angeles, California 90017-3411

In one horrific instance, Soberon sexually assaulted Ms. Adams at her home in front
of her disabled son suffering from cerebral palsy as he lay helpless, crawling on the ground.
Soberon threatened Ms. Adams that he would put her in jail for the rest of her life if

she refused his disgusting sexual desires. Ms. Adams, a 44-year old mother of three boys,

was terrified for her life and for her safety.

In 2015, Ms. Adams was approached at her home by a female probation officer who

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informed Ms. Adams that she was in violation of her community service obligations and

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would be placed under arrest. Ms. Adams was shocked because Soberon had told her that he

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was extending her community service and that she did not need to complete it. The female

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probation officer confiscated her phone and confirmed that Soberon had indeed told her that

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her community service was being extended. Additionally, the female probation officer saw

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messages with Soberon calling her sexy mamacita and baby doll, and asking what Ms.
Adams would do for him. The female probation officer immediately left Ms. Adams home
without anything else said.
Following this incident, Ms. Adams began receiving threatening calls from Soberon

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that he was going to kill her. At this point, Ms. Adams found the courage and went to the
Probation Department to report Soberon. A number of probation officers attempted to
dissuade Ms. Adams from making the report. As it turned out, after Ms. Adams made the

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report, Soberon was not even the assigned probation officer to Ms. Adams, yet the Kern

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County Probation Department was allowing him to continue supervising her. Further, it

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became clear that Soberon was making up fake commitments and requirements for Ms.

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Adams (which were not part of her probation) so she had to personally meet him at the

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probation office where he would sexually assault her. Internal Affairs investigated the

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matter, and also told Ms. Adams that she could not speak with anyone, especially the FBI,

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and could not retain an attorney.

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Although Soberon was arrested on December 23, 2015, Ms. Adams first learned that
Soberon was arrested several months later when she received a subpoena to appear at a
hearing in his criminal case.
Ms. Adams submitted a Government Tort Claim, in pro per, pursuant to Government

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GERAGOS&GERAGOS, APC

HISTORIC ENGINE CO. NO. 28

644 South Figueroa Street
Los Angeles, California 90017-3411

Code Section 910 on April 5, 2016. The Kern County Board of Supervisors rejected the
claim on the grounds that the claim was filed more than 6 months after the last act of
molestation which took place on or around June 2015. Ms. Adams now brings this Request

to Late File, having retained counsel Geragos & Geragos, pursuant to Government Code

Sections 911.4, et seq.

Specifically, throughout 2015 Ms. Adams was repeatedly told by Kern County

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Probation Officials and her Internal Affairs interviewers that she should not retain an

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attorney, not speak to the media, and not talk with FBI. Additionally, Ms. Adams was not

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made aware of Mr. Soberons arrest until on or around March 2016, when she was

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subpoenaed.

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Ms. Adams feared that no criminal action was taken against Soberon and that he
would carry out on his threat to kill her had he remained on the force of Kern County
Probation. Finally, Ms. Adams is the victim of a sexual assault that is currently being
criminally prosecuted.

Ms. Adams psychological torment and health based on her

victimization merits the Board of Supervisors accepting Ms. Adams Government Code
Section 910 filing.
Pursuant to Government Code Section 911.4, Ms. Adams filed her claim within 1 year

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of the accrual of the cause of action. Attached as Exhibit A is the filing of Ms. Adams

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pro per Government Tort Claim.

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C. KERN COUNTY PROBATION DEPARTMENT

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The Kern County Probation Department enabled and attempted to cover up the

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conduct of Soberon. When Ms. Adams first arrived to sign paperwork at the Probation

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Office she was approached by Soberon who stated he was a Senior Officer, and was going

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to make himself Ms. Adams probation officer even though he was not assigned to her. Ms.

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Adams watched as Soberon went into the back, spoke with someone, and came back and said

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Now I am your probation officer.

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Soberon began molesting and sexually assaulting Ms. Adams on her third visit. The
majority of the molestations actually took place within the Probation Office itself, in the
corner. Other probation employees would sometime pass by. Additionally, the Probation
Department would notice that Ms. Adams would sign in frequently, on a monthly basis,

GERAGOS&GERAGOS, APC

HISTORIC ENGINE CO. NO. 28

644 South Figueroa Street
Los Angeles, California 90017-3411

despite the fact that unbeknownst to her she could mail the documentation in and did not
need to meet with Soberon personally. Additionally, the Probation Department supported

Mr. Soberons predatory conduct by allowing him to remain as Ms. Adams main point of

contact within the probation department despite the fact that she had been reassigned to a

new probation officer in 2014.

When Ms. Adams reported Mr. Soberon, several probation officers, as well as internal

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affairs investigators, all initially pressured her not to make a report, not to a hire an attorney,

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and not go to FBI. To this day, the Kern County Probation Department has issued no public

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statements or public releases regarding the criminal prosecution of Probation Officer

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Soberon or determined the extent of other victims, which is likely massive in numbers.

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Examples of Text Messages by Officer Soberon:

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EXHIBIT A