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EXHIBIT A
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In the Matter of the Claim of KAT URIA D'AMATO,


individually and as parent and natural guardian of
ALFONSO MARCELLO D' AMATO and
LUCIANA CIOFFARI D'AMATO,
NOTICE OF CLAIM
Claimants,

-against-

COUNTY OF NASSAU, NASSAU COUNTY


POLICE DEPARTMENT, NASSAU COUNTY
POLICE SERGEANT JAMES LORENZEN;
NASSAU COUNTY DEPUTY POLICE
INSPECTOR FRANCES M. BEIN; NASSAU
COUNTY POLICE OFFICER VINCENT
ADAMO, NASSAU COUNTY POLICE
OFFICER JIMMY LEE, NASSAU COUNTY
POLICE OFFICER PRINCE and NASSAU
COUNTY AMT "JOHN DOE",

Respondents.

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TO: COUNTY OF NASSAU


c/o Nassau County Attorney's Office
One West Street'
Mineola, New York 11501

NASSAU COUNTY POLICE DEPARTMENT


1490 Franklin Avenue
Garden City, New York 11530

NASSAU COUNTY POLICE SERGEANT JAMES LORENZEN


1490 Franklin Avenue
Garden City, New York 11530

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NASSAU COUNTY DEPUTY INSPECTOR FRANCES M. BEIN


1490 Franklin Avenue
Garden City, New York 11530

NASSAU COUNTY POLICE OFFICER VINCENT ADAMO


1490 Franklin Avenue
Garden City, New York 11530

NASSAU COUNTY POLICE OFFICER JIMMY LEE


1490 Franklin Avenue
Garden City, New York 11530

NASSAU COUNTY POLICE OFFICER PRINCE


1490 Franklin Avenue
Garden City, New York 11530

NASSAU COUNTY AMT "JOHN DOE"


1490 Franklin Avenue
Garden City , New York 11530

PLEASE TAKE NOTICE that the undersigned claimant hereby makes claim and demand

against you as follows:

1. The name and post~office address of each claimant and claimants' attorney is:

Katuria D' Amato Law Offices of Thomas F. Liotti


Alfonso Marcello D' Amato 600 Old Country Road, Suite 530
Luciana Cioffari D' Amato Garden City, New York 115300
67 Buxton Street (516) 794~4700
Lido Beach, New York 11561

2. The nature of the claim: False arrest and imprisonment; Assault; battery; abuse of

process; invasion of privacy; defamation, defamation per se, libel, slander and a denial of state

and federal civil rights.

On or about September 30, 2017 and continuing through the present, the respondents,

acting in concert with former United States Senator Alfonse D' Amato, the husband of the

claimant, caused his wife, KaturiaD' Amato to have her privacy invaded, to be wrongfully

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arrested and taken into custody~ falsely imprisoned her for three (3) days in South Nassau

Communities Hospital against her will and without consent of any kind; defamation and

defamation per se.libel and slander in that. among other things, the respondents wrote and

provided a report stating that the claimant was taking a prescribed medication known as Lithium.

The respondents swore to and testified to these and other facts knowing that they were untrue,

perjurious, unfounded and made on the basis of false information provided to them by fonner

Senator D'Amato. As a result of the lies perpetrated by the respondents, the claimant was

wrongfully detained in the aforementioned facility known as South Nassau Communities

Hospital.

As a result of these and other actions by the respondents, the respondents caused the

claimant to lose temporary custody of her children and to have an order of protection unlawfully

entered against her. The respondents gave false and perjurious testimony at the behest of former

Senator D' Amato and his attorneys in December, 2017 wherein they claimed, among other

things, that the claimant was suffering from an "episodic psychosis" on September 30, 2017

which opinion contained in the aforementioned report and testimony, they were unqualified and

untrained to make.

The respondents came to the claimants home on the basis of an unfounded and

unnecessary domestic incident call and thereafter invaded the premises and privacy of the

claimant against her wishes and will; intentionally inflicting great emotional distress upon her;

wrongfully engaged in an illegal search and seizure of her premises and property including an

unused shotgun. without probable or even reasonable cause to believe that the claimant had

committed any crime or that she presented any actual danger to herself or others including, but

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not limited to, her daughter who was sound asleep in the premises at the time .

.. The respondents breached the quiet enjoyment of the premises of the claimant by forcing

their entry into the premises in the early morning hours of September 30,2017. The respondents

were misled, influenced and deceived by the former Senator who is, upon information and belief,

neurologically impaired and who was vindictively motivated to have the claimant taken into

custody in order to gain a tactical and strategic advantage in his matrimonial case which he

brought against the claimant soon after she was taken to the hospital and wrongfully detained

there without the benefit or access to her counselor her children. The claimant was prevented

from leaving the hospital, a hospital that the former Senator currently represents, headed by

Richard Murphy, with whom he claimed to have lunch the day pdor and with whom he regularly

lunches. The hospital wrongfully admitted the claimant on the basis of a false report and

information engineered and given to the hospital by former Senator D' Amato and the

respondents.

Upon information and belief, former Senator D' Amato told the police to take claimant to

the hospital.

Upon information and belief, former Senator D' Amato used such contacts, among others,

to arrange for claimant to be held at such hospital for three days.

The respondents were no doubt influenced by the title of the former United States Senator

as well as his long standing political contacts and associations with elected and appointed

officials throughout the County. the State of New York and the nation. The former Senator is a

successful lobbyist who sells his influence and aforementioned contacts throughout the world.

The claimant was victimized by the former Senator and the respondents. The former Senator has

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not been charged with making a false statement to the police, although he should be, once again

due to his influence and contacts and sworn documents he filed in Nassau County Court in this

matter.

The claimant is an attorney and mother oftwo children. Her career, reputation and ability

to function as a parent and mother have 'all been severely damaged by these erroneous reports as

well as both the in court and out of court statements by the respondents, fanner Senator D' Amato

and his attorneys. Her children have been deprived of her nurturing and attendance. Both have

been damaged as a result of the actions of the respondents acting in concert with the former

Senator.

The respondents are poorly trained and unschooled in screening out or detennining

legitimate domestic violence cases or mentally aided calls from those such as this one which are

fabricated. Accordingly, the respondents were susceptible to the untoward and improper

influence of the former Senator.

3. The time when, the place where and the manner in which the claim arose: The

claimant was falsely detained by Nassau County Police Department on September 30, 2017 at her

home located at 67 Buxton Street, Lido Beach, Nassau County, New York.

4. The items of damage or injuries claimed are (do not state dollar amounts): Conscious

pain and suffering; wrongful detention; counsel fees; public ridicule and embarrassmeni"as well

as other physical and psychological injuries and damages to claimant and her young children yet

to be detennined.

The undersigned Claimant therefore presents this claim for adjustment and payment. You

are hereby notified that unless it is adjusted and paid within the time provided by law from the

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date of presentation to you, the Claimants intend to commence an action on this claim.

Dated: Garden City, New York


January 30, 2018

URIA D' A ATO, individually and


as parent and natural guardian of ALFONSO
MARCELLO D'AMATO and LUCIANA
CIOFFARI D' AMATO

W OFFICES OF THOMAS F. LIOTTI


Attorneys for Claimants
600 Old Country Road, Suite 530
Garden City, New York 11530

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~ .t ,I "

INDIVIDUAL VERIFICATION

STATE OF NEW YORK )


ss.:
COUNTY OF NASSAU )

KATURIA D' AMATO, being duly sworn, depose and say that deponent is the claimant

in the within action; that he has read the foregoing Notice of Claim and know the contents

thereof; that the same is true to deponent's own knowledge, except as to the matters therein

stated to be alleged on infOlmation and belief, and that as to those matters deponents believe it to

be true.

~~~ as parent and natural guardian of ALFONSO


MARCELLO D' AMATO and LUCIANA
CIOFFARID'AMATO

Sworn to before me this

THOMAS F. LlOTTI ,-
Notary Public, State of New York
No. 02L16080933
9U~/jfied in Nassau County
-C~mmlsslon Expires Sept. 23, 20 h,/ 0 .
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In the Matter ofthe Claim ofKATURlA D'AMATO,

NOTICE OF CLAIM
Claimant,

-against-

NASSAU COUNTY, THE NASSAU COUNTY


POLICE DEPARTMENT and POLICE OFFICERS
JOHN AND JANE DOE "1" through "6",

Respondents.

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TO: COUNTY OF NASSAU


c/o Nassau County Attorney's Office
One West Street
Mineola, New York 11501

NASSAU COUNTY POLICE DEPARTMENT


1490 Franklin Avenue
Mineola, New York 11501

NASSAU COUNTY POLICE OFFICERS JOHN & JANE DOE "I" through "6"
1490 Franklin Avenue
Mineola, New York 11501

PLEASE TAKE NOTICE that the undersigned claimant hereby makes claim and demand

against you as follows:

1. The name and post-office address of each claimant and claimant's attorney is:

Katuria D' Amato Law Offices of Thomas F. Liotti


67 Buxton Street 600 Old Country Road, Suite 530
Lido Beach, New York 11561 Garden City, New York 115300
(516) 794-4700

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2. The nature of the claim: False imprisonment; abuse of process; invasion of privacy;

defamation, defamation per se, libel, slander and a denial of state and federal civil rights.

On June 25,2018 following a verbal dispute, not physical, with a neighbor, James Cash

of 53 Buxton Street, Lido Beach, New York, representatives from the Nassau County Police

Department responded to the scene located at 67 Buxton Street, Lido Beach, Nassau County,

New York. The neighbor apparently reported a verbal dispute to the Police Department. The

police arrived, together with private investigators and former United States Senator Alfonse

D' Amato, the claimant's estranged husband. Mr. Cash's wife is a Suffolk County Police Officer.

Upon information and belief, Mr. Cash called his wife and she then called the Nassau Police

Department. While no physical contact occurred, upon information and belief, Mr. Cash and/or

the Nassau County Police Department notified Alfonse D' Amato. He and the Nassau County

Police Department have been charged in a prior Notice of Claim with wrongfully engineering a

"mentally aided" call of the claimant which caused the claimant to be falsely imprisoned from

September 30,2017 through October 2,2017 at South Nassau Communities Hospital. In this

prior claim it has been alleged that the Nassau County Police Department colluded with Alfonse

D' Amato to have Mrs. D' Amato taken from her home to South Nassau Communities Hospital

against her will in violation ofthe State's Mental Hygiene Law and claimant's civil rights.

On June 25,2018 Mr. Cash who has one to two cameras pointed at the claimant's home,

approached the claimant's son, Alfonso and repeatedly stated to him at the time in words and

substance: "1 am sorry that your mom is the way she is. She is so bad." Alfonso was on a public

sidewalk at the time and so was Mr. Cash. The claimant told Mr. Cash to "leave her son alone."

Alfonso and claimant's daughter, Luciana, were both fearful of Mr. Cash and concerned that

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their mother would be arrested after they overheard the police threaten the arrest.

When the police arrived they came to the claimant's front steps and told the claimant that

she should allow them entry to the home. They did not have a warrant and given the claimant's

prior history in September, 2017, she elected not to let them into her home.

The police then told the claimant that she would be contacted by aN assau Detective and

that she would be arrested for harassment unless she let them into her home and talked with

them. The claimant on June 26, 2018 has filed a complaint with the Nassau County District

Attorney against the police officers and the Nassau County Police Department for once again

wrongfully colluding with her husband to cause her to be falsely charged and arrested.

Among other things, the police threatened and tried to intimidate the claimant by stating

that she would be arrested if she did not allow them entry to her home. The police acted in an

ultra vires manner and attempted to gain entry to claimant's home under false pretenses and by

misstating the facts and the law when in fact the incident did not rise to the level of "harassment"

and Mr. Cash, his wife and Mr. D' Amato should have been investigated and charged with filing

or making a false police report, a Class "A" misdemeanor.

Mr. D'Amato has continued to have the claimant falsely arrested, threatened, stalked and

harassed by the Nassau County Police Department and others. He illegally uses his political

power and influence over the Nassau County Police Department and others in order to gain a

tactical advantage against the claimant in a matrimonial and custody case pending in Nassau

County.

The respondents have caused the claimant to be assaulted by fear of apprehension in that

they remained outside her home for more than three hours blocking her exit and stating that she

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would be arrested if she attempted to leave her home. The respondents invaded the claimant's

right of privacy; interfered with her freedom to travel and association.

The respondents attempted to gain entry into the claimant's home without probable cause

and by creating a ruse that she would be "arrested" for harassment, a violation and not a crime.

The claimant, an attorney, has documented all of the respondents' misconduct together with that

of her husband.

The claimant has filed a complaint against the police, Mr. Cash and her husband

regarding the June 25, 2018 incident. The claimant here filed a criminal complaint with the

Nassau District Attorney's Office on June 26, 2018 against her husband, the police and Mr. Cash.

As a result the claimant has sustained compensatory, punitive damages and attorney's

fees in violation of her state and federal civil rights.

3. The time when, the place where and the manner in which the claim arose: The

claimant was falsely detained by Nassau County Police Department on June 25, 2018 at her

home located at 67 Buxton Street, Lido Beach, Nassau County, New York.

4. The items of damage or injuries claimed are (do not state dollar amounts): Conscious

pain and suffering; wrongful detention; counsel fees; public ridicule and embarrassment as well

as other physical and psychological injuries and damages to claimant and her young children yet

to be determined.

The undersigned Claimant therefore presents this claim for adjustment and payment. You

are hereby notified that unless it is adjusted and paid within the time provided by law from the

date of presentation to you, the Claimants intend to commence an action on this claim.

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·.

Dated: Garden City, New York


June 28,2018

\
~/~
/LAW OFFICES OF THOMAS F. LIOTTI
- ---Attorneys for Claimants
600 Old Country' Road, Suite 530
Garden City, New York 11530

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INDIVIDUAL VERIFICATION

STATE OF NEW YORK )


ss.:
COUNTY OF NASSAU )

KATURIA D' AMATO, being duly sworn, depose and say that deponent is the claimant

in the within action; that he has read the foregoing Notice of Claim and know the contents

thereof; that the same is true to deponent's own knowledge, except as to the matters therein

stated to be alleged on information and belief, and that as to those matters deponents believe it to

be true.

Sworn to before me this

:J. '1-Jf;ay of June, 2018

~
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_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _0 _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ X
In the Matter of the Claim ofKATURlA D' AMATO,

NOTICE OF CLAIM
Claimant,

° -against-

NASSAU COUNTY, THE NASSAU COUNTY


POLICE DEPARTMENT and POLICE OFFICERS
JOHN AND JANE DOE "I" through "6",

Respondents.
------------------------------------------------------------------x
TO: COUNTY OF NASSAU
c/o Nassau County Attorney's Office
One West Street
Mineola, New York 11501

NASSAU COUNTY POLICE DEPARTMENT


1490 Franklin Avenue
Mineola, New York 11501

NASSAU COUNTY POLICE OFFICERS JOHN & JANE DOE "I" through "6"
1490 Franklin Avenue
Mineola, New York 11501

PLEASE TAKE NOTICE that the undersigned claimant hereby makes claim and demand

against you as follows:

1. The name and post-office address of each claimant and claimant's attorney is:

Katuria D' Amato Law Offices of Thomas F. Liotti


67 Buxton Street 600 Old Country Road, Suite 530
Lido Beach, New York 11561 Garden City, New York 115300
(516) 794-4700

2. The nature of the claim: False imprisonment; abuse of process; invasion of privacy;

defamation, defamation per se, libel, slander and a denial of state and federal civil rights.

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This claim is based upon the wrongful prosecution of Katuria D' Amato on August 10,

2018 in the Nassau County District Court for Criminal Contempt, a Class A misdemeanor, in that

she allegedly violated a court protective order wrongfully entered against her on July 16, 2018.

The order of July 16, 2018 directed her to refrain from harassment, etc. of the complainants, Mr.

& Mrs. James Cash, the neighbors of the claimant. On July 31,2018 the complainants alleged a

violation of a protective order of July 16, 2018 in that the complainant, Mrs. Catherine Cash, a

Suffolk County Police Officer with presumably some knowledge of the law, falsely claimed that

the claimant had violated the aforesaid protective order by allegedly making "obscene hand

gestures". The claimant was falsely arrested, charged and detained all in violation of her

Constitutional and civil rights under both state and federal law.

The original charges from June 25, 2018 never should have been issued in the first place.

In like manner the Nassau District Attorney's Office requested a Protective Order of the

arraigning Judge, Hon. William Hohauser on July 16, 2018 which never should have been

requested or granted due to the fact that the complainants, Mr. & Mrs. Cash would abuse and

have abused that protective order by alleging a violation of it and causing the wrongful arrest and

imprisonment of the claimant.

The claimant notes that previous notices of claim have been filed by this claimant which

are pending in both Nassau and Suffolk Counties.

The specific compensatory and punitive damages have yet to be determined. The

claimant in addition to the foregoing violations of Constitutional and civil rights is also alleging

defamation, intentional infliction of emotional distress, public embarrassment and ridicule. The

claimant alleges that these respondents have colluded with claimant's husband, former United

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States Senator Alfonse D' Amato and the Nassau County Police Department to discredit Mrs.

D' Amato and her claims against them both jointly and individually. Her consequential damages

include, but are not limited to, adverse inferences and impacts on her matrimonial and custody

proceedings currently pending in Nassau Supreme Court.

As a result the claimant has sustained compensatory, punitive damages and attorney's

fees in violation of her state and federal civil rights.

3. The time when, the place where and the manner in which the claim arose: The

claimant was falsely detained and charged by Nassau County Police Department on August 10,

2018.

4. The items of damage or injuries claimed are (do not state dollar amounts): Conscious

pain and suffering; wrongful detention; counsel fees; public ridicule and embarrassment as well

as other physical and psychological injuries.

The undersigned Claimant therefore presents this claim for adjustment and payment. You

are hereby notified that unless it is adjusted and paid within the time provided by law from the

date of presentation to you, the Claimants intend to commence an action on this claim.

Dated: Garden City, N ew York


September 5, 2018

Attorneys for Claimants


600 Old Country Road, Suite 530
Garden City, New York 11530

3
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INDIVIDUAL VERIFICATION

STATE OF NEW YORK )


ss.:
COUNTY OF NASSAU )

KATURIA D' AMATO, being duly sworn, depose and say that deponent is the claimant

in the within action; that he has read the foregoing Notice of Claim and know the contents

thereof; that the same is true to deponent's own knowledge, except as to the matters therein

stated to be alleged on information and belief, and that as to those matters deponents believe it to

be true.

Sworn to before me this


r~
/1 daYOfS~ternber,2018 ~
Notary Public ..
()
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------------------------------------------------------------------)(

In the Matter of the Claim ofKATURIA D' AMATO,


AMENDED
NOTICE OF CLAIM
Claimant,

-against-

NASSAU COUNTY, THE NASSAU COUNTY


POLICE DEPARTMENT, DETECTIVE JASON
HERNANDEZ and POLICE OFFICERS JOHN
AND JANE DOE "1" through "6",

Respondents.

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TO: COUNTY OF NASSAU


c/o Nassau County Attorney's Office
One West Street
Mineola, New York 11501

NASSAU COUNTY POLICE DEPARTMENT


1490 Franklin Avenue
Mineola, New York 115~)1

NASSAU COUNTY POLICE DETECTIVE JASON HERNANDEZ


1490 Franklin Avenue
Mineola, New York 11501

NASSAU COUNTY POLICE OFFICERS JOHN & JANE DOE "I" through "6"
1490 Franklin Avenue
Mineola, New York 11501

PLEASE TAKE NOTICE that the undersigned claimant hereby makes claim and demand

against you as follows:

1
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1. The name and post-office address of each claimant and claimant's attorney is:

Katuria D' Amato Law Offices of Thomas F. Liotti


67 Buxton Street 600 Old Country Road, Suite 530 .
Lido Beach, New York 11561 Garden City, New York 115300
(516) 794-4700

2. The nature of the claim: False imprisonment; abuse of process; invasion of privacy;

defamation, defamation per se, libel, slander and a denial of state and federal civil rights.

On June 25, 2018 following a verbal dispute, not physical, with a neighbor, James Cash

of 53 Buxton Street, Lido Beach, New York, representatives from the Nassau County Police

Department responded to the scene located at 67 Buxton Street, Lido Beach, Nassau County,

New York. The neighbor apparently reported a verbal dispute to the Police Department. The

police arrived, together with private investigators and fonner United States Senator Alfonse

D' Amato, the claimant's estranged husband. Mr. Cash's wife is a Suffolk County Police Officer.

Upon information and belief, Mr. Cash called his wife and she then called the Nassau Police

Department. While no physical contact occurred, upon infonnation and belief, Mr. Cash and/or

the Nassau County Police Department notified Alfonse D' Amato. He and the Nassau County

Police Department have been charged in a prior Notice of Claim with wrongfully engineering a

"mentally aided" call of the claimant which caused the claimant to be falsely imprisoned from

September 30,2017 through October 2,2017 at South Nassau Communities Hospital. In this

prior claim it has been alleged that the Nassau County Police Department colluded with Alfonse

D' Amato to have Mrs. D' Amato taken from her home to South Nassau Communities Hospital

2
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against her will in violation ofthe State's Mental Hygiene Law and claimant's civil rights.

On June 25, 2018 Mr. Cash who has one to two cameras pointed at the claimant's home,

approached the claimant's son, Alfonso and repeatedly stated to him at the time in words and

substance: "I am sorry that your mom is the way she is. She is so bad." Alfonso was on a public

sidewalk at the time and so was Mr. Cash. The claimant told Mr. Cash to "leave her son alone."

Alfonso and claimant's daughter, Luciana, were both fearful of Mr. Cash and concerned that

their mother would be arrested after they overheard the police threaten the arrest.

When the police arrived they came to the claimant's front steps and told the claimant that

she should allow them entry to the home. They did not have a warrant and given the claimant's

prior history in September, 2017, she elected not to let them into her home.

The police then told the claimant that she would be contacted by a Nassau Detective and

that she would be arrested for harassment unless she let them into her home and talked with

them. The claimant on June 26, 2018 has filed a complaint with the Nassau County District

Attorney against the police officers and the Nassau County Police Department for once again

wrongfully colluding with her husband to cause her to be falsely charged and arrested.

Among other things, the police threatened and tried to intimidate the claimant by stating

that she would be arrested if she did not allow them entry to her home. The police acted in an

ultra vires manner and attempted to gain entry to claimant's home under false pretenses and by

misstating the facts and the law when in fact the incident did not rise to the level of "harassment"

and Mr. Cash, his wife and Mr. D' Amato should have been investigated and charged with filing

or making a false police report, a Class "A" misdemeanor.

3
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Mr. D' Amato has continued to have the claimant falsely arrested, threatened, stalked and

harassed by the Nassau County Police Department and others. He illegally uses his political

power and influence over the Nassau County Police Department and others in order to gain a

tactical advantage against the claimant in a matrimonial and custody case pending in Nassau

County.

The respondents have caused the claimant to be assaulted by fear of apprehension in that

they remained outside her home for more than three hours blocking her exit and stating that she

would be arrested if she attempted to leave her home. The respondents invaded the claimant's

right of privacy; interfered with her freedom to travel and association.

The respondents attempted to gain entry into the claimant's home without probable cause

and by creating a ruse that she would be "arrested" for harassment, a violation and not a crime.

The claimant, an attorney, has documented all of the respondents' misconduct together with that

of her husband.

The claimant has filed a complaint against the police, Mr. Cash and her husband

regarding the June 25,2018 incident. The claimant here filed a criminal complaint with the

Nassau District Attorney's Office on June 26,2018 against her husband, the police and Mr. Cash.

As a result the claimant has sustained compensatory, punitive damages and attorney's

fees in violation of her state and federal civil rights.

3. The time when, the place where and the manner in which the claim arose: The

claimant was falsely detained by Nassau County Police Department on June 25,2018 at her

home located at 67 Buxton Street, Lido Beach, Nassau County, New York and forced to remain

4
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in her home under fear that she would be wrongfully arrested or that the police would come into

her home without a warrant as they had done in the past. Her children were terrified.

Detective Hernandez and Police Officers whose names are not yet known, improperly

charged the claimant without probable cause to believe that she committed any crime or violation

ofthe law, to wit: harassment. Detective Hernandez acted in concert with other Nassau County

Police personnel, former Senator Alfonse D' Amato and the complainant(s) on the underlying

harassment case as to embarrass the claimant in her ongoing custody and matrimonial case.

The respondents have deliberately advanced the return date for arraignment on the

appearance ticket issued to Mrs. D' Amato on July 11, 2018 for July 13, 2018 instead of 4-6

weeks hence which is the usual procedure. They have done so in order to embarrass her before

the media.

Their actions are a violation of the claimant's civil rights. She has been falsely and

wrongfully arrested, imprisoned, charged, defamed and needlessly embarrassed by the respondent

and by those with whom they acted in concert as heretofore indicated.

4. The items of damage or injuries claimed are (do not state dollar amounts): Conscious

pain and suffering; wrongful detention; counsel fees; public ridicule and embarrassment as well

as other physical and psychological injuries and damages to claimant and her young children yet

to be determined.

The undersigned Claimant therefore presents this claim for adjustment and payment. You

are hereby notified that unless it is adjusted and paid within the time provided by law from the

date of presentation to you, the Claimants intend to commence an action on this claim.

5
Case 2:19-cv-01398-JMA-ARL Document 1-1 Filed 03/11/19 Page 24 of 34 PageID #: 221

Dated: Garden City, New York /'"

~E~,~
July 18,2018

KA RIAD'AMATo

Attorneys for Claimants


600 Old Country Road, Suite 530
Garden City, New York 11530

6
Case 2:19-cv-01398-JMA-ARL Document 1-1 Filed 03/11/19 Page 25 of 34 PageID #: 222

INDIVIDUAL VERIFICATION

STATE OF NEW YORK )


ss.:
COUNTY OF NASSAU )

KATURlA D'AMATO, being duly sworn, depose and say that deponent is the claimant

in the within action; that he has read the foregoing Amended Notice of Claim and know the

contents thereof; that the same is true to deponent's own knowledge, except as to the matters

therein stated to be alleged on information and belief, and that as to those matters deponents

believe it to be true.

Sworn to before me this

l~ili day ofJuly, 201~

~~
(JOtary PUbic
Jt::.AN rM. LA G-aA5"ffl yost
l\lIOtary Pub-\Ic. State of Nell"
.No. 30-4669304
tmaItfted to N118SBU Cognty d 11/1'7
~ EJq;tl'e@ Oct. ~1. i?- V 0
Case 2:19-cv-01398-JMA-ARL Document 1-1 Filed 03/11/19 Page 26 of 34 PageID #: 223

------------------------------------------------------------------)(

In the Matter of the Claim ofKATURIA D'AMATO,

NOTICE OF CLAIM
Claimant,

-against-

CATHERINE CASH, as a Suffolk County Police


Officer,

Respondent.

------------------------------------------------------------------)(

TO: POLICE OFFICER CATHERINE CASH


Suffolk County Police Department
30 Yaphank Avenue
Yaphank, New York 11980

PLEASE TAKE NOTICE that the undersigned claimant hereby makes claim and demand

against you as follows:

1. The name and post-office address of each claimant and claimant's attorney is:

Katuria D' Amato Law Offices of Thomas F. Liotti


67 Buxton Street 600 Old Country Road, Suite 530
Lido Beach, New York 11561 Garden City, New York 115300
(516) 794-4700

2. The nature ofthe claim: False imprisonment; abuse of process; invasion ofprivacy;

defamation, defamation per se, libel, slander and a denial of state and federal civil rights.

The Respondent is a Suffolk County police officer residing with her husband, James Cash

at 53 Buxton Street, Lido Beach, New York, County of Nassau, State of New York. They are the

neighbors of Mrs. D' Amato, an attorney and the wife of Alfonse D' Amato, a former United

1
Case 2:19-cv-01398-JMA-ARL Document 1-1 Filed 03/11/19 Page 27 of 34 PageID #: 224

States Senator and since 1999, a lobbyist.

On June25, 2018 James and Catherine Cash filed a false police report against Katuria

D' Amato alleging Harassment in the Second Degree, a violation. They falsely claimed that Mrs.

D' Amato gave Mr. Cash a "chest bump". As a result of these patently false allegations Mrs.

D' Amato has had to retain counsel; go to the Fourth Precinct in Nassau County to pick up an

Appearance Ticket where she was placed in a holding cell and threatened with the application of

handcuffs if she did not keep her hands behind her back. She was then compelled to appear at an

arraignment where she was held up to public ridicule; embarrassed and defamed.

Upon information and belief, Mrs. Cash called and summoned Nassau County Police to

Buxton Street by stating that she is a Suffolk County Police Officer and that her husband was

being threatened with assault and battery by Mrs. D' Amato. These statements by her were

patently false and untrue. No assault or battery occurred or was threatened. Mrs. Cash abused

her title as a Suffolk Police Officer in an attempt to engineer the arrest of Mrs. D' Amato. This

was ultra vires and not in the performance of her official duties as a Suffolk County Police

Officer. Instead, she sought favoritism as a member of the "thin blue line" from her fellow

officers in Nassau. This was an abuse of authority and a violation of Mrs. D' Amato's State and

Federal civil rights under color oflaw. No crime or violation occurred.

Upon information and beliefMr. & Mrs. Cash also called Mr. D' Amato to the scene.

They together with Mr. D' Amato, their friend and neighbor, sought the arrest of Mrs. D' Amato

and encouraged the Nassau Police to charge and arrest her. Some oftheir improper threats to

arrest Mrs. D' Amato occurred in the presence of Mrs. D' Amato's children and nanny who were

then fearful that Mrs. D' Amato would go to jailor be arrested. This also amounted to the

2
Case 2:19-cv-01398-JMA-ARL Document 1-1 Filed 03/11/19 Page 28 of 34 PageID #: 225

intentional infliction of emotional distress by Mr. & Mrs. Cash against Mrs. D' Amato and her

children.

3. The time when, the place where and the manner in which the claim arose: The

claimant was falsely detained by Nassau County Police Department on June 25,2018 at her

home located at 67 Buxton Street, Lido Beach, Nassau County, New York.

4. The items of damage or injuries claimed are (do not state dollar amounts): Conscious

pain and suffering; wrongful detention; abuse of process; malicious prosecution; defamation and

defamation per se; counsel fees; public ridicule and embarrassment as well as other physical and

psychological injuries and damages to claimant and her young children yet to be determined.

The undersigned Claimant therefore presents this claim for adjustment and payment. You

are hereby notified that unless it is adjusted and paid within the time provided by law from the

date of presentation to you, the Claimants intend to commence an action on this claim.

Dated: Garden City, New York


July 30,2018

Attorneys for Claimants


600 Old Country Road, Suite 530
Garden City, New York 11530

3
Case 2:19-cv-01398-JMA-ARL Document 1-1 Filed 03/11/19 Page 29 of 34 PageID #: 226

INDIVIDUAL VERIFICATION

STATE OF NEW YORK )


ss.:
COUNTY OF NASSAU )

KATURIA D'AMATO, being duly swom, depose and say that deponent is the claimant

in the within action; that he has read the foregoing Notice of Claim and know the contents

thereof; that the same is true to deponent's own knowledge, except as to the matters therein

stated to be alleged on information and belief, and that as to those matters deponents believe it to

be true.

~u£tlAulJ UR" D'AMAT "

Sworn to before me this

30 th dayofJuly,2018 PJ "
-~'"""'''----'''--,t-f---,~=.j,~~
Case 2:19-cv-01398-JMA-ARL Document 1-1 Filed 03/11/19 Page 30 of 34 PageID #: 227

------------------------------------------------------------------)(
In the Matter ofthe Claim ofKATURIA D'AMATO,

NOTICE OF CLAIM
Claimant,

-against-

COUNTY OF SUFFOLK and CATHERINE CASH,


as a Suffolk County Police Officer, .

Respondents,
------------------------------------------------------------------)(
TO: COUNTY OF SUFFOLK
H. Lee Dennison Building
100 Veterans Memorial Highway
Hauppauge, New Y~rk 11788

POLICE OFFICER CATHERINE CASH


Suffolk County Police Department
30 Yaphank Avenue
Yaphank, New York 11980

PLEASE TAKE NOTICE that the undersigned claimant hereby makes claim and demand

against you as follows:

1. The name and post-office address of each claimant and claimant's attorney is:

Katuda.D' Amato Law Offices of Thomas F ,'Liotti


67 Buxton Street 600 Old Country Road, Suite 530
Lido Beach, New York 11561 Garden City, New York 115300
(516) 794-4700

2. The nature of the claim: False imprisonment; abuse of process; invasion of privacy;

intentional infliction of emotional distress, defamation, defamation per se, libel, slander and a

denial of state and federal civil rights,

The Respondent is a Suffolk County police officer residing with her husband, James Cash

at 53 Buxton Street, Lido Beach, New York, County ofN'assau, State of New York. They are the

1
Case 2:19-cv-01398-JMA-ARL Document 1-1 Filed 03/11/19 Page 31 of 34 PageID #: 228

neighbors of Mrs. D' Amato, an attorney and the wife of Alfonse D' Amato, a former United

States Senator and since 1999, a lobbyist.

On June 25,2018 James and Catherine Cash filed a false police report against Katuria

D' Amato alleging Harassment in the Second Degree, a violation. They falsely claimed that Mrs.

D' Amato gave Mr. Cash a "chest bump". As a result ofthese patently false allegations Mrs.

D' Amato has had to retain counsel; go to the Fourth Precinct in Nassau County to pick up an

Appearance Ticket where she was placed in a holding cell and threatened with the application of

handcuffs if she did not keep her hands behind her back. She was then compelled to appear at an

arraignment where she was held up to public ridicule; embarrassed and defamed.

Upon information and belief, on June 25, 2018 Mrs. Cash called and summoned Nassau

County Police to Buxton Street by stating that she is a Suffolk County Police Officer and that her

husband was being threatened with assault and battery by Mrs. I)'Ainato. These statements by

her were patently false and untrue. No assault or battery occurred or was threatened. Mrs. Cash

abused her title as a Suffolk Police Officer in an attempt to engineer the arrest of Mrs. D' Amato.

This was ultra vires and not in the performance of her official duties as a Suffolk County Police

Officer. Instead, she sought favoritism as a member of the "thin blue line" from her fellow

officers in Nassau. This was an abuse of authority and a violation of Mrs. D' Amato's State and

Federal civil rights under color oflaw. No crime or violation occurred.

Upon information and beliefMr. & Mrs. Cash also called Mr. D'Amato to the scene.

They together with Mr. D' Amato, their friend and neighbor, sought the arrest of MIs. D' Amato

and encouraged the Nassau Police to charge and arrest her. Some oftheir improper threats to

arrest Mrs. D' Amato occurred in the presence of Mrs. D' Amato's children and nanny who were

2
Case 2:19-cv-01398-JMA-ARL Document 1-1 Filed 03/11/19 Page 32 of 34 PageID #: 229

then fearful that Mrs. D' Amato would go to jailor be arrested. This also amounted to the

intentional infliction of emotional distress by Mr. & Mrs. Cash against Mrs. D' Amato and her

children. This incident of June 25 th resulted in a Notice of Claim being filed against Mrs. Cash

and Suffolk County. A copy ofthat notice of claim is attached as Exhibit "A". Additional

notices of claim have been filed against the Nassau County Police Department and its officers

related to those allegations and others.

On July 31,2018 and August 10, 2018 Mrs. Cash once again filed a false police report

improperly using her title as a Suffolk County Police Officer in that regard and thereby causing

this claimant to be wrongfully prosecuted, arrested, charged with a crime, incarcerated and

defamed, all in violation of Mrs. D' Amato's civil rights under color oflaw. Mrs. Cash's actions

were ultra vires and initiated in complete derogation of claimant's Constitutional and civil rights

under both state and federal law. Mrs. Cash's actions show a pattern by her of violating both

state and federal rights of this claimant and others.

3. The time when, the place where and the manner in which the claim arose: The

claimant was falsely detained by Nassau County Police Department on August 10, 2018 due to

Mrs. Cash's filing of a false police report on July 31,2018. Mr. & Mrs. Cash erroneously

obtained a Temporary Order of Protection (hereinafter TOP) on July16, 2018 arising out of the

June 25,2018 incident. This TOP was then abused by Mrs. Cash in causing the arrest of Mrs.

D' Amato pursuant to Nassau's "zero tolerance policy" with which Mrs. Cash is familiar as a

Suffolk County Police Officer. Mrs. Cash's actions caused Mrs. D'Amato to be handcuffed,

arrested, falsely imprisoned, defamed and charged all in violation of her First, Second, Fourth,

Fifth, Eighth and Fourteenth Amendment rights under the Federal Constitution.

3
Case 2:19-cv-01398-JMA-ARL Document 1-1 Filed 03/11/19 Page 33 of 34 PageID #: 230

4. The items of damage or injuries claimed are (do not state dollar amounts): Conscious

pain and suffering; wrongful detention; abuse of process; malicious prosecution; abuse of

process; defamation and defamation per se; counsel fees; public ridicule and embarrassment as

well as other physical and psychological injuries, counsel fees, disbursements, pre and post

judgment interest and costs and damages to claimant and her young children yet to be

determined.

The undersigned Claimant therefore presents this claim for adjustment and payment. You

are hereby notified that unless it is adjusted and paid within the time provided by law from the

date of presentation to you, the Claimants intend to commence an action on this claim.

Dated: Garden City, New York


October 22, 2018

Attorneys for Claimants


600 Old Country Road, Suite 530
Garden City, New York 11530

4
Case 2:19-cv-01398-JMA-ARL Document 1-1 Filed 03/11/19 Page 34 of 34 PageID #: 231

INDIVIDUAL VERIFICATION

STATE OF NEW YORK )


ss.:
COUNTY OF NASSAU )

KATURIA D'AMATO, being duly sworn, depose and say that deponent is the claimant

in the within action; that he has read the foregoing Notice of Claim and know the contents

thereof; that the same is true to deponent's own knowledge, except as to the matters therein

stated to be alleged on information and belief, and that as to those matters deponents believe it to

be true.

Sworn to before me this

tl.. r~ay of October, 20