migdia chinea cordova avenue glendale california march robert deegan general liability claims section los angeles unified school district s beaudry ave th floor los angeles ca dear mr deegan this letter shall constitute a claim pursuant to the california tort claims act section et seq of the california government code my address information in compliance with section a and b is set forth above per section c d and e the date of occurrence was october i was assaulted and battered by students t and i and possibly other students at markham middle school w th street los angeles the police report is dr lausd personnel specifically steven thomas rooney aided and abetted violations of the ralph and bane civil rights acts sections and of the california civil code and sections and of the california penal code by failing and refusing to report the matter to police authorities lausd violated my rights under article i section one of the california constitution to safety and my specific right to safety on a school campus under article i section of the california constitution i have suffered physical damages and extreme emotional trauma as a result david brewer and other personnel knew or should have known based upon my complaints and upon past known misconduct by rooney that rooney was unfit as a supervisory employee of lausd lausd therefore negligently hired trained assigned supervised and retained rooney and ignored my complaints about his misconduct lausd s conduct towards me is motivated by benign neglect of complaints of discrimination retaliation and harassment by latino employees as exemplified in past incidents by superintendent brewer and the general counsel s office failing to properly investigate and take appropriate action when complaints were levelled against anti hispanic ethnocentric misconduct against an attorney employed by the office of the general counsel and other incidents pursuant to section f this claim is for damages within the jurisdiction of the unlimited division of the los angeles superior court respectfully submitted migdia chinea cc california lulac civil rights commission united for education coalition