'I

Adam M. Fried, Esq.

Direct Dial: (216) 430-2193
Direct Fax: (216) 430-2284
Email: afried@reminger.com

Reminger
ATTORNEYS AT LAW

csll95i

www. willcontestfinmcom

February 11,2016
Via Email cmever(city.cieveland.oh.us &
Regular Mail
Carl E. Meyer
Assistant Director of Law
601 Lakeside Avenue, Room 106
Cleveland, OH 44114-1015
RE:

Estate of Tamir Rice

Dear Mr. Meyer:

Please allow this letter to serve as a demand upon you to withdraw the insensitive and callous
claim filed against the Estate of Tamir Rice for emergency services rendered as a result of Tamir
being shot and killed by a City of Cleveland police officer. Having cited to R.C. 2117.06 as a
component of your presentation of claim, you must have been aware of the time limit requirements
set forth in R.C. 2 117.06(C) which provides: "except as provided in Section 2117.061 of the Revised
Code, a claim that is not presented within six months of the death of a decedent shall be forever
barred as to all parties, including, but not limited to, devisees, legatees, and distributees. No payment
shall be made on the claim and no action shall be maintained on the claim, except as otherwise
provided in Section 2117.37 to 2117.42 of the Revised Code with reference to contingent claims."
I represent Samaria Rice in relation to the probate proceedings of the Estate of Tamir Rice.
To say that she, as a grieving mother, has had a difficult time dealing with the tragic circumstances of
her son's death, is an understatement. It is curious that more than a year after Tamir died, you chose
to rip wider these ugly wounds by filing a time barred claim.
I remind you of the obligations under an attorney under Civil Rule 11 whereby the signature
of an attorney upon a document represents that to the best of the attorney or party's knowledge,
information and belief, there is good ground to support it and that it is not interposed for delay.
Because the claim is time barred, there is no good faith basis upon which you can support the claim
that was filed. So that I can avoid having to pursue questions as to whether the claim was filed
willfully in violation of Rule 11 and done for the purpose of interfering in the administration of the
probate estate for reasons unrelated to the claim, I hereby demand that you withdraw the claim by
close of business on Friday, February 12, 2016.
Very truly yours,

AMF/ts
cc:

Barbara A. Langhenry (via email)

Subodh Chandra (via email)
Timothy Pettorini (via email)
Douglas Winston (via email)
REMINGER CO., LPA

101 West Prospect Avenue Suite 1400 Cleveland, OH 44115-1093 'phone: 216.687.1311 fax: 216.687.1841 . www.reminger.com
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