WELCOME TO THE SABATINO REPORT

November 3, 2006

JUDGE STEPHENSON APPEARS INSTEAD OF NEW JUDGE

KEATING COULD ASK MIKE ZAGARIS TO HELP FROM CAMPAIGN FUND

CLAIM AGAINST THE CITY OF MODESTO

(Government Code Section 910 et.seq.)

Carmen Sabatino hereby makes claim against the City of Modesto and submits the following statements in support of the claim:

1. Claimant’s address is ------------------, Modesto, California 95350.

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

3. All damages incurred as a result of this claim occurred  prior to, during, and subsequent to the criminal complaint filed against the claimant, on or about, August of 2003.  The subject criminal charges against the claimant were ultimately dismissed, on  July 12, 2006.

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 and the County of Stanislaus acting with ulterior motives, intentionally encouraged, solicited, and or, conspired to commence criminal investigations for the purpose of slandering  and libeling the claimant.  These individuals attempted to interfere with the personal liberty of the claimant.  Additionally, said individuals violated claimant’s civil rights and the right of commerce he maintains as a citizen of the United States.  The aforementioned actions of these individuals led to the filing of a criminal complaint against the claimant.  All criminal charges were subsequently dismissed.

6. Claimant, by way of this claim, specifically requests that the City of Modesto reimburse the County of  Stanislaus for court appointed attorneys fees in an approximate amount of $ 52,000.00.

7. This claim is based on the fact that the claimant, at the time of the alleged criminal investigations and prosecutions, was the Mayor of the City of Modesto and the alleged criminal conduct took place while the claimant was acting in his official capacity, or as a result of  charges alleged in order to remove the Mayor from office. The claim, as of this date, is in an amount that would place it within the jurisdiction of the Superior Court. 

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