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Residential address for six months prior to the date of the incident (if different from
current address):
Same as No. 2. & 3.
INCIDENT INFORMATION
FACTS
On June 14th, 2017 King County Deputy Sheriff Caesar Molina, shot and killed
unarmed 120 pound Tommy Le in Burien, WA. Deputy Molina shot the unarmed student
twice in the back.
Tommy Le, a member of a large lawful Vietnamese refugee family residing here in
King County, was a thoughtful and kind high school student who was set to graduate later
that day.
After the shooting death of Tommy Le, the King County Sheriffs Office chose to
conceal the truth that Tommy Le was unarmed when he was shot in the back twice. The
Sheriff's Office and its Public Information Officer (PIO) - affirmatively released untrue
facts stating that Tommy Le was attacking the deputies with a knife when he was shot. The
King County Sheriffs Office knew within minutes of the shooting that Tommy Le was
unarmed and shot in the back. Several days later, the King County Sheriff John Urquhart
and King County Deputy Sheriffs went to the Les family home and deliberately lied to the
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family, telling them that Tommy Le was shot dead because he was attacking the deputies
with a knife. The family was not told that Tommy was unarmed when he was shot in the
back. This intentional fabrication caused the Le family predictable needless emotional
harm and humiliation.
LEGAL CLAIMS
Estate of Tommy Les Claim of Damages for Washington Wrongful Death & 42 USC
1983 and the Violations of Deceased Tommy Les Federal Civil Rights
Violation of Tommy Le and the Le Familys Civil Rights, 42 USC 1983, and
Washington Wrongful Death/Survivorship Claims, and Negligent Infliction of
Emotional Distress and the Tort of Outrage
Xuyen Le, the duly appointed Personal Representative of the Estate of Tommy Le,
(King County Superior Court Number 17-4-04798-5) hereby notifies Martin Luther King
Jr. (King) County, The King County Sheriffs Office, John Urquhart, King County Sheriff,
and Caesar Molina, Deputy King County Sheriff, of her intention to file suit for monetary
and punitive damages in the United States District Court for Western Washington at
Seattle. The suit will allege that under the color of state law, Caesar Molina, a King County
Deputy Sheriff, shot and killed Tommy Le, an unarmed 120 pound student in violation of
Tommy Les United States Constitutional 4th Amendment right to be free from the
application of excessive deadly force by police officers. Deputy Sheriff Molinas use of
deadly force under the circumstances constituted excessive force and an unreasonable
seizure. The Estate of Tommy Le seeks redress for his death under 42 USC 1983,
applicable Washington state wrongful death/survivorship laws, federal laws, and both state
and federal legal remedies.
-3-
Tommy Les Familys Civil Rights Claims
Tommy Les Father, Hoai Sunny Le; Mother, Dieu Ho; Aunts, Uyen Le and
Xuyen Le; Grandmother, Kim Tuyet Le; brothers and sister, Quoc Nguyen, Tam Nguyen,
Dung Nguyen, Julia Nguyen, and Jefferson Nguyen; of the deceased Tommy Le hereby
notify Martin Luther King Jr. County (King County), the King County Sheriffs Office,
John Urquhart, King County Sheriff, and Caesar Molina, Deputy King County Sheriff of
their intention to file suit for monetary & punitive damages in the United States District
Court for Western Washington at Seattle for the violation of civil rights including the
family members US Constitutional 5th and 14th amendment liberty right to the family
relationship and consortium with the deceased, Tommy Le, and as well as harms caused
by the negligence and outrageous conduct of the named King County Officials related to
the concealment. In addition to the private and public misrepresentation of the facts
surrounding the death of Tommy Le including, but not limited to: misstating that Tommy
Le was armed and attacking the deputy sheriffs and other individuals when he was shot
and killed by King County Deputy Sheriff Molina. It was foreseeable that such an untrue
statement would and in fact did cause emotional harm to the family members. Such
behavior of concealing the truth from the public and announcing misstatements to the
family constitute the Tort of Outrage under Washington state law.
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Parents of Tommy Le, Hoai Sunny Le and Dieu Ho, Claim for 42 USC 1983
deprivation of their US Constitution 5th and 14th Amendment Liberty Rights in the
Relationship with their Adult Child, Tommy Le.
9. Location of incident: 136th Avenue South and 3rd Avenue South, Burien, WA.
Yes, 136th Avenue South and 3rd Avenue South, Burien, WA.
12. Names, addresses and telephone numbers of all persons involved in or witness to this
incident:
The King County Sheriffs Office has compiled but refused to release witness
statements to the representatives of the deceased Tommy Le.
13. Names, addresses and telephone numbers of all entity employees having knowledge
about this incident:
Burien residents whose identities are known to King County Sheriff but whose
identities have been concealed from Tommy Les representatives.
14. Names, addresses and telephone numbers of all individuals not already identified in
No. 12 and No. 13 above that have knowledge regarding the liability issues involved in this
incident, or knowledge of the Claimants resulting damages. Please include a brief
description as to the nature and extent of each persons knowledge. Attach additional sheets
if necessary.
See above.
15. Describe the cause of the injury or damages. Explain the extent of property loss or
medical, physical or mental injuries. Attach additional sheets if necessary:
Factual Synopsis: On June 14th, 2017 in Burien, King County, Washington, at the
corner of 136th and 3rd Avenue South, King County Deputy Sheriff Caesar Molina
unlawfully shot and killed Tommy Le, an unarmed 120 pound student. Deputy
Molina shot Tommy in the back - twice. A cause of the killing was King County
Sheriff John Urquhart, King County Sheriffs Office and King Countys
unconstitutional policies and procedures and the negligent training, supervision, and
selection of Deputy Molina.
Causes include, but are not limited to: Tommy Les death was caused by the unlawful
use of deadly force by King County Deputy Sheriff Caesar Molina. Deputy Molina
shot the unarmed 120lb student, Tommy Le in the back. A cause of Tommy Les
killing was King County Sheriff John Urquhart, King County Sheriffs Office and
King Countys unconstitutional policies and procedures and the negligent selection
training, and supervision of Deputy Molina.
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THE USE OF LAWFUL DEADLY FORCE
Tommy Le
DOD: 06-14-17
Public Health 1:.fl
Seattle & King County n
King County Medical Examiner's Office
Harborview Medical Center
325 Ninth Avenue, Box 359792
Seattle, WA 98104-2499
DECLARATION OF
206-731-3232 Fax 206-731-8555
TIY Relay: 711 CUSTODIAN OF RECORDS
www.kingcounty.gov/health
I, Samantha Barbom, being the duly authorized Deputy Custodian of Reco rds for the
King County Medical Examiner's Office (KCMEO) declare as fo llows:
1. The KCMEO maintains records on the above named decedent. As of the day of
this declaration, the documents provided are a true and complete copy of the records of the
above-mentioned decedent which were kept and maintained by the KCMEO in the usual course
of business. To the best of my knowledge, no records have been omitted, except that no
specimens, evidence, or hun1an tissue are included.
I declare under penalty of perjury under the laws of the State of Washington that the
foregoing is true and correct.
SAMANTHA BARBOUR
PATHOLOGICAL DIAGNOSES:
OPINION:
The cause of death of this 20-year-old man who died in hospital is multiple
gunshot wounds sustained in a confrontation with police. The manner of death is
classified homicide.
~~r--2
Brian Mazrim , MD Richard Harruff, MD ,
Associate Medical Exam iner Chief Medical Examiner
BM:kld
CONFIDENTIAL
King County Medical Examiner
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AUTOPSY REPORT R.C.VV. f8.SO 105
Tommy LE
KCME 17-1179
Page 2
EXTERNAL EXAMINATION:
IDENTIFICATION:
GENERAL DESCRIPTION:
The head is normocephalic and is remarkable for the focal superficial injury
described below. The hair is black and measures up to 2.5 inches in length.
Facial hair consists of a sparse mustache and goatee style beard. The pupils
measure 5 millimeters bilaterally. The irides are brown. The conjunctivae are free
of lesions. The teeth a re natural and in an adequate state of repair. The oral
mucosa is free of lesions. Th e ears are normally formed and free lesions. No
pi ercings are evident. The trachea is midline and the neck is free of palpable
masses.
The chest is symmetrical. The abdomen is flat. The external genita lia are those
of a normal ad ult uncircumcised male. The testes are descended bilaterally.
The upper extremities are normally formed and remarkable fo r the injuries
described below. The fingerna ils are neatly trimmed to within 1/16 inch of the
nailbeds. The lower extremities are normally formed and remarkable for th e focal
superficial injury described below.
King County Medical Examiner CONFIDENTIAL
AUTOPSY REPORT
DO NOT copy
R.C.W. 6,3 OE105
Tommy
KCME 17-1179
Page 3
The back is remarkable for th e injury described below. The buttocks are
unremarkable.
1. A tattoo reading "S EGO" present across the proximal phalanges of the
right 2 nd through 51 fingers.
2. A tattoo reading "Deaf" present along the dorsal aspects of the proximal
phalanges of the left 2nd through 5th fingers.
MEDICAL THERAPY:
An endotracheal tube and orogastric tube enter the mouth. Intravenous access
line enter the left subclavian region and bilateral inguinal reg ions. Single chest
tubes enter bilateral axillae. A sutured thoracotomy incision extends transversely
across the left anterior and lateral chest. A flutter valve enters the left upper
chest.
Three gunshot wounds are present and are described below with reference to
the anatomic position.
PATH OF WOUND: Th e bullet track first traverses the subcutaneous soft ti ssues
posterior to the spinal column and enters th e body cavities through the ri ght
psoas muscle. The bullet track then perforates th e right kidney and th e li ver and
penetrates the right latera l chest wall below the costal margin .
PATH OF WOUND: The bull et track perforates the soft ti ssues of th e left w rist
and fractures the proximal 5th metaca rpal bone.
EXIT WOUND: A 2.4 x 0.6 inch stellate gunshot exit wo und is present on th e
palm of the left hand immediately distal to the wrist.
In addition to the gunshot wo unds descri bed above, multiple superficial blunt
force injuries and superficial probable puncture wo unds are also present. A 0. 75
x 0.5 inch abrasion is present on th e righ t temple. A 1.7 x 0.4 inch abrasion
extend s to the right from midline on the anterior mo st submental surface of the
chin. A 4 x 1. 75 inch collection of punctate abrasions is present on the superi or
CONFIDENTIAL
King County Medical Examiner
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AUTOPSY REPORT R.C.VV. 6?,.50.105
Tommy LE
KCME 17-1179
Pag e 5
right sho ulder. A punctu re wo und is present on the left anterior chest j ust above
and med ial to the left areol a. Embedded w ithin this superficial puncture wo und
appea rs to be a tiny fragment of coppe r co lored metal. A superficia l puncture
wo und is present in the rig ht lower quadrant of the abdomen near the midli ne.
Superficial abrasions up to 0. 2 inches in diameter are preset on the dorsal
aspects of the left 3rd and 4th knuckl es and 2nd and 3rd fingers. A 2 inch linea r
abrasion is present on the anteromed ial mid right thigh. S uperficial punctate and
oblong abrasion s are up to 0. 75 inches in greatest dimension are present on the
anterio r aspect of bilateral knees. 0.5 inch abrasions are present on the medial
right foo t and medial left great toe.
The scalp is unremarka_ b le and the skull is intact. Th ere is no epidural, subdural,
or subarachnoid hemorrhage. T he brain weighs 141 2 grams and has normall y
co nfigured gyri and sulci. Th e leptomeninges are thin and transparent. The
ce rebral vessels are unremarkable. The cortical gray ri bbon is intact and the
ventricular system is appropriate size. The deep cerebral nuclei and hippocampi
are unremarkable. Th e brain stem and ce rebellum are unremarkable. The skull
base has th e expected anatomic features. The proximal spinal cord, when
viewed through th e foramen magnum, is unremarkable.
NECK:
Exa mination of the anterior soft tissues, ca rtilaginous and bony structures of the
neck reveals no abno rm ali ties. The usual anatomic relationships are preserved
and the upper airway is not obstructed .
BODY CAVITIES:
The organs are normally situated and there are no fi brous adhesions. Associated
w ith the injuries previously describ ed are a 550 milliliter hemothorax and a 200
milliliter hemoperitoneum. The pleural and peritoneal surfaces are smooth and
glistening. T he mediastinum and retroperitoneum have the expected anatomic
fea tu res.
King County Medical Examiner
CONFIDENTIAL
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AUTOPSY REPORT
R.C.\-V. G~.~0.1C5
Tommy LE
KCME 17-1179
Page 6
CARDIOVASCULAR SYSTEM:
The larynx and trachea have no abnormalities and are co ntinuous in the usual
manner with the primary bronchi. The bronchi contain clear mucus. The right lung
weigh s 360 grams and the left lung weighs 501 grams. The parenchyma is deep
red and congested. There is no consolidation, hemorrhage, mass or cavitary
lesion. The bronchi and vasculature are normally distributed .
HEPATOBILIARY SYSTEM :
The live r weighs 11 70 grams and has a smooth glistening capsule. Injury has
been previously described. Cut surfaces are otherwise uniformly red-brown and
have th e usua l landmarks. The extrahepatic biliary system is unremarkable. The
gallbladd er contains approximately 5 milliliters of dark green viscous bile without
stones.
LYMPHORETICULAR SYSTEM :
The spleen we ighs 82 grams and is remarkabl e only for the injury previously
described. The thymus is involuted and replaced by fat. The lymph nodes, where
appreciated, are unremarkable.
URINARY SYSTEM:
The right kidney we ighs 117 grams and the left kidn ey weighs 11 8 grams. Injury
has been previously descri bed . The cortica l surfaces are smooth and the cortica l
architectu re is normal. T here is good cortico-med ullary differen ti ation. Th e pelves
have th e usual anatomic relationships and are co ntinuous into normal ureters
which insert into an unremarkable bl adder containing 10 milliliters of clear ye llow
urine.
King County Medical Exami ner CONFIDENTI
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AUTOPSY REPORT
R.r:.,"' ("'() ,_ 0_ 0 _
Tommy LE
KCME 17-1179
Page 7
INTERNAL GENITALI A:
GASTROINTESTINAL SYSTEM:
ENDOCRINE SYSTEM:
The pan creas, pituitary, thyroid, and adrenal glands are unremarkable.
MUSCULOSKELETAL SYSTEM:
The vertebrae, clavicles, sternum, ribs, and pelvis are without fracture. The
musculature is normally distributed and unremarkable. The abdominal fat
measures 1 centimeter at the level of the umbilicus.
MICROSCOPIC:
CYTOLOGY(ORAL AN D
ANAL SWABS): No sperm seen.
King County Medical Examiner CONFIDENTlft.L
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AUTOPSY REPORT
R. C . \fl'V. 6.., . ro ,l 05
.J
Tommy LE
KCME 17-1179
Page 8
Tox Case#: ST-17-07279 Case Type: Death Investigation Report Date: 7/26/2017
Evidence: The following evidence was submitted to the Laboratory by Zachary Porras-Foye of the King Co
Medical Examiner on 6/20/2017 via hand delivery:
(1) ST-1 7-07279-A: VLavender, Blood - Hospital
(2) ST-17-07279-B: PTubeSnap, Blood - Hospital
(3) ST-17-07279-C: SST, Serum - Hospital
(4) ST-1 7-07279-0: SST, Serum - Hospital
None Detect ed
None Detected
ST-17-07279-C was tested by Gas Chromatography/Mass Spectrometry for the presence of basic drugs and
metabolites on 07/20/2017. The following result(s) was obtained:
None Detected
COMMENTS
All testing was performed by the Forensic Scientist listed below except as otherv.tise indicated. The Forensic
Scientist has technically reviewed all relevant pages of testing documentation in the case record.
coNF\DENT\AL
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