June 30, 2020

Judge Nelson W. Wolff Sheriff Javier Salazar

County Judge, Bexar County Bexar County Sheriff’s Office
101 W. Nueva, 10th Floor 200 North Comal St.
San Antonio, TX 78205 San Antonio, TX 78207
via email and mail via email and mail

Sergio “Chico” Rodriguez Justin Rodriguez

County Commissioner
Bexar County, Precinct 1
101 W. Nueva, 10th Floor
San Antonio, TX 78205
via email and mail
County Commissioner
Bexar County, Precinct 2
101 W. Nueva, 10th Floor
San Antonio, TX 78205
via email and mail

Kevin A. Wolff Tommy Calvert

County Commissioner
Bexar County, Precinct 3
101 W. Nueva, Suite 1007
San Antonio, TX 78205
via email and mail
County Commissioner
Bexar County, Precinct 4
101 W. Nueva, Suite 1029
San Antonio, TX 78205
via email and mail

Lowell F. Denton Charles Frigerio

Benton, Navarro, Rocha, Bernal Law Offices of Charles S. Frigerio, P.C.
& Zech, P.C. Riverview Towers
2517 N. Main Avenue 111 Soledad, Ste. 840
San Antonio, TX 78212 San Antonio, Texas 78205
via email and mail via email and mail

RE: Case No. 5:19-CV-01392; Christopher Prescott & Rubi Prescott,

Individually and as personal representatives of the Estate of Kameron
Prescott, Deceased v. Bexar County, Javier Salazar, Individually and as
the Bexar County Sherriff, John Aguillon, George Herrera, Jesse Arias,
and Johnny Longoria; In the United States District Court, Western
District, San Antonio Division
June 30, 2020
Page 2 of 16

Dear Sirs:
We represent Christopher Prescott and Rubi Castillo Prescott, the parents of
six-year-old Kameron Prescott, who was killed by gunfire from deputies from the
Bexar County Sheriff’s Office, a few days before Christmas on December 21, 2017.
We are sure that you are aware of the general facts of this case, as it made
national news. 1 We write, however, so that you have a full picture of the event, and
so that you, as elected officials, may take the necessary steps to ensure no other family
has to endure what the Prescotts have with the loss of their young son.
We also write to give the County an opportunity to attempt to right this wrong
and to provide the Prescotts with some meaningful level of compensation for their
terrible loss. To that end, the Prescotts are willing to accept, at this time, a fraction
of what a jury would likely award as damages in the above-referenced lawsuit. They
make this offer in an attempt to move past this terrible tragedy and avoid prolonged
litigation, which will only force them to re-live its horror.
Closure here will also allow the County to take a hard look at this case, without
the cloak of a lawsuit and the inevitable entrenchment of positions attendant to such
a process. With all the events that are currently taking place in our country, now is
the time to conduct an honest evaluation of this event and to answer the question of
how something like this could possibly happen and what can be done to ensure it
never happens again.
The Events of December 21, 2017. A few days before Christmas, Kameron
Prescott was at home with his dad and his 14-year-old cousin in the Pecan Grove
mobile home community. He was playing Paw Patrol (his favorite) in his room. The
Christmas tree was up, and presents were under the tree waiting for Kameron to
open them a few days later. Not far away, Amanda Jones was at her own home with
two friends.
Prior to this incident, Amanda Jones was not a known violent criminal. She
had warrants out for non-violent crimes (credit card abuse and fraud). This entire
incident started because a local bounty hunter called into the Bexar County Sheriff’s
Office (BCSO) to have Jones picked up. Deputies arrived, detained Jones’ two friends,
and searched the house. While searching for Jones, Deputy Gonzalez claims Jones
said (from underneath a pile of clothes) that she had a gun. He also claimed that he
saw her “pointing a gun at me” as she ran out of the house. 2 In fact, Jones never had

1
E.g., Boy, 6, Killed in Deputy Shooting in Texas Days Before Christmas, New York Times, Dec. 23,
2017, available at https://www.nytimes.com/2017/12/23/us/texas-boy-police-shooting.html
2 Bates 0043
June 30, 2020
Page 3 of 16

a gun. During a follow-up interview, Deputy Gonzalez conceded he never actually

saw a gun, but rather closed his eyes and flinched when she ran past. 3
As a result of Deputy Gonzalez’s allegation, BCSO initiated a several hour
manhunt for Jones, complete with a helicopter, drone, K-9 teams, and assistance from
other agencies. Approximately twenty-seven deputies, officers, and troopers were
involved. The manhunt went on for so long that the helicopter had to refuel and,
according to one deputy, “water, juices and snacks” were brought in for the deputies. 4
Law enforcement eventually ended up searching the nearby Pecan Grove
Mobile Home community for Jones. After a DPS helicopter spotted Jones, five BCSO
deputies converged around Christopher Prescott’s home. Moments before they
engaged Jones, the trooper in the helicopter told the deputies over the radio, “I can’t
see any weapons,” only noting that Jones was grabbing her hip. 5 Even with this
warning, the deputies approached the Prescott home, guns drawn. Kameron’s bicycle
(with training wheels) and other toys were visible on the front porch

Christopher Prescott and his niece (Kameron’s cousin) were in the living room,
watching television. Six-year-old Kameron was playing in his room. Jones, who had
just entered the Prescott home through the unlocked patio door, then tried to exit
after Christopher told her to leave.
As Jones tried to exit through the glass patio door, Deputies Aguillon, Arias,
Herrera, and Reserve Deputy Longoria opened fire on Jones. The deputies initially
fired four rounds. Then after a two second pause, they fired at least fourteen more
rounds—all at an unarmed person standing in front of an occupied home. A home
constructed of sheet metal, which has no ability to stop a bullet. In total, the deputies

3 Bates 3728
4 Bates 0024
5 Bates 3745
June 30, 2020
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fired at least eighteen rounds from two AR-15 rifles and two Glock handguns. Deputy
Arias, armed with an AR-15, fired all but one bullet in his magazine:

Of the many rounds that penetrated the thin shell of the Prescott mobile home, two
struck Kameron:

Because of all the commotion, Kameron was standing near the entrance of his room.
He was apparently holding his toy light-up sword, which was later found next to his
body, still blinking:
June 30, 2020
Page 5 of 16

After Kameron was hit, he called out, “Ouch, Daddy, ouch.” Christopher tried to run
to his son, but deputies (with guns drawn) quickly detained Christopher and his
niece. Christopher instead watched, handcuffed from the ground, as his son was
carried out of the house and away from him forever. Kameron was transported to
University Hospital where he was pronounced dead. An autopsy found that two
bullets entered Kameron’s body, as evidenced by his bloodied shirt:

In an instant, Christopher and Rubi lost their only child. In the one place a
parent would expect their child to be safe—their own home—Kameron was taken
from them. And in that fleeting moment when Kameron called out to his daddy,
Christopher was not even to able to hold him one last time.
June 30, 2020
Page 6 of 16

This is the boy that Christopher and Rubi remember:

But this—sadly—is all they have left to see:

The Prescotts’ Legal Claims. This case is a tragedy, but it was a

preventable tragedy. For that reason, after allowing the County to have more than
ample time to investigate this case, the Prescotts filed suit late last year, asserting
various claims against the deputies, Bexar County, and Sheriff Salazar.

We do not contend that the deputies intended to shoot Kameron. As such, from
a legal perspective, we have not asserted a section 1983 civil rights claim premised
June 30, 2020
Page 7 of 16

on a violation of the Fourth Amendment. See U.S. CONST., AMEND. IV (prohibiting

“unreasonable . . . seizures”). Instead, we have asserted that the deputies’ actions
violated Kameron’s rights to substantive due process under the Fourteenth
Amendment. Id., AMEND. XIV. To prove such a claim, the Prescotts must show that
the deputies’ actions “shock the conscience and violate the decencies of civilized
conduct.” County of Sacramento v. Lewis, 523 U.S. 833, 846 (1998). Thus, in this
case, the jury (comprised of citizens, mothers, and fathers of this county) will
ultimately be asked—do the actions that the deputies of Bexar County took that day
shock your conscience? In answering that question, the jury will know:

• Amanda Jones did not have—and never had—a firearm.

• Amanda Jones was not a violent criminal.

• Bexar County was not looking for Amanda Jones. It pursued her only because
a bounty hunter—who had his own personal financial interest in capturing
Jones—asked it to do so.

• Deputy Gonzalez—who instigated the entire manhunt—never actually saw

Jones with a gun.

• In response to Jones fleeing her home, Bexar County and its deputies did not
try to de-escalate the situation. Instead, they applied their full force to capture
her—complete with helicopters and deputies roaming a neighborhood with
AR15s drawn.

• After Jones was located in Pecan Grove, the deputies did not surround the
home, take cover, and attempt to de-escalate the situation. They did not
temper their actions based on the helicopter trooper’s statement that “I can’t
see any weapons” or by the presence of toys and a child’s bicycle on the front
porch. They did not take precaution in light of the obvious presence of people
in the home, given that the door was open and a car was in the driveway. They
did not resist gunfire even though any bullet would easily penetrate the thin
walls of the mobile home. Rather, the deputies approached the entrance, guns
drawn and ready to engage.

• When Jones attempted to exit the home, deputies opened fire. Their alleged
justification was that the deputies themselves were in fear for their lives.
Ironically, the deputies’ failure to take cover and de-escalate the situation
became the justification for deadly force.
June 30, 2020
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• Deputy Arias, who was carrying an AR-15, was only feet away from the
elevated porch where Jones stood. He almost emptied his magazine, firing
approximately 15 times at the unarmed Jones:

• Deputies engaged in not one, but two, volleys of gunfire. 6 The deputies initially
fired four times. Then Jones slouched and fell to the ground. A few seconds
later, the deputies fired numerous more rounds. The deputies ultimately fired
almost twenty times at the unarmed Jones, who was standing in the doorway
of the occupied home. Whatever the alleged threat, why were this many rounds
needed to subdue Jones? And why was this second round of gunfire—which is
the set that likely struck Kameron—necessary after Jones fell to the ground?

• The deputies did not utilize the non-lethal option of a K-9, who was standing
only feet away next to the trailer. Deputy Tubbs, the K-9 handler, “was
prepared to deploy my K-9” but never was able to due to the numerous rounds
of gunfire. 7 Why was this option not utilized, especially with the risk of
innocent people in the home—a mobile home that would in no way stop a
bullet?

6 The audio of this gunfire and a partial video of it are captured on Deputy Aguillon’s body camera
and the DPS 107 video.
7 Bates 0049.
June 30, 2020
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The credibility of the deputies is also at issue here. Although BCSO confirmed after
the shooting that Jones did not have a firearm, Deputy Longoria swore under oath
that Jones fired at them and that he actually saw “smoke” coming from her gun. 8
Deputy Herrera also swore that “I heard gunfire and saw the glass door shatter as
she turned towards me and it appeared as though she was shooting through the glass
door. 9 Deputy Aguillon stated that he fired his AR15—not because he saw Jones
actually fire a weapon—but because he heard several other shots. 10 Each of these
shots, as we know, came from the other deputies.

Not only was a gun never found, but investigators have never even found the
alleged object that the deputies claim Jones was holding. Investigators ultimately
found a landscape stake under the porch later that evening. 11 But Christopher
Prescott denied Jones was holding that and the investigator that found it did not even
believe it matched the description of the alleged object. 12 Either way, the fact that
this object was not in Jones’ hand after the shooting, or even under or near her body
calls into question whether she was holding anything at all.

The jury will also wonder other things, such as:

• Why did reserve Deputy Longoria use a firearm at all, given that he was not
current with his training requirements? 13

• Why was Deputy Herrera’s body camera turned off during the actual
shooting? Why did Deputies Arias and Longoria not have a body camera at
all?

• Why was there no body camera footage of the initial encounter with Amanda
Jones, when she allegedly said she had a gun?

These facts “shock the conscience.” If you have any question in your mind
whether they do, ask any mother you know whether she is shocked by these facts.
Ask any resident of Bexar County whether what the deputies did was right or
warranted. This evidence is more than sufficient to present to a jury, and more than
sufficient for a jury to find the deputies liable. See, e.g., Bailey v. County of San
Joaquin, 671 F. Supp. 2d 1167, 1174 (E.D. Cal. 2009) (denying motion for summary

8 Bates 0039-40.
9 Bates 0035.
10 Bates 4212.
11 Bates 143-
12 Bates 143-46, 127-29.
13 Bates 4216
June 30, 2020
Page 10 of 16

judgment on due process claim where deputy fired weapon at a dog, which then
ricocheted and hit a child).

The Liability of the County and Sheriff Salazar. The County itself, and
its decision maker, Sheriff Salazar, are also subject to liability. There are underlying
constitutional violations—under both the Fourteenth Amendment (against Kameron
Prescott) and Fourth Amendment (against Amanda Jones). See Alpha v. Hooper, 440
F.3d 670, 672 (5th Cir. 2006). As such, the County and Sheriff Salazar are liable for
their contributions to those constitutional violations. Id. In particular, the County
and Sheriff are liable for a failure to have appropriate training and policies in place
to prevent this occurrence.

Immediately following this incident, Sheriff Salazar promised change. He

acknowledged that he knew, prior to this incident, the department’s use-of-force
policy was wordy and confusing, and that, “[w]hen you start getting into ambiguities
in your policy, I think you’re asking for trouble.” 14 He also insisted on new training
In particular, Sheriff Salazar mandated training in de-escalation after the incident.
The involved deputies had no training in that area prior to the incident, only after.
Sheriff Salazar told the press that he knew additional training was needed “prior to
my taking office.”
If the County and Sheriff Salazar knew, at least as early as when he took office,
that its use of force policy was wordy, confusing, and ambiguous, and that its deputies
needed additional training, why did that not take place prior to this terrible tragedy?
As part of this lawsuit, we have requested any documents, emails or correspondence
generated prior to this incident about proposed changes to the use-of-force policy. To
date, the County has been unable to locate any. Thus, the County was on notice of
an inadequate and confusing use-of-force policy, but took no action to remedy that
prior to this incident. Indeed, the use-of-force policy in place on the date of the
incident had not changed since 2014—well before Sheriff Salazar’s term in office.
We have requested similar documents about any changes to training
requirements pertaining to de-escalation, prior to this incident. Again, the County is
unable to locate any. Local commentators called for de-escalation training over a year

14Bexar County will review its training policies after shooting death of 6-year-old, San Antonio
Express News, Jan. 7, 2018, available at https://www.expressnews.com/news/local/article/Bexar-
County-will-review-its-training-policies-12479309.php
June 30, 2020
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before this incident. 15 National policing organizations did the same. 16 The United
States Justice Department warned, in 2015, that “[d]e-escalation tactics are essential
skills for police officers and departments both to help to ensure constitutional policing
and to improve public safety and officer safety.” The 2015 Final Report of The
President’s Task Force on 21st Century Policing recommended that “law enforcement
agency policies for training on use of force should emphasize de-escalation . . .” The
San Antonio Police Department (Sheriff Salazar’s former employer) even adopted
some form of de-escalation in its use-of-force policy prior to this incident. 17

Despite this consensus, none of the involved deputies received de-escalation

training until after this incident. Whether the County and Sheriff Salazar should
have instituted such training is a question for a jury in this case. See Thomas v.
Cumberland County, 749 F.3d 217 (3d Cir. 2014) (holding, in a Monell case against a
municipality, that triable issues existed on whether a lack of training in de-escalation
contributed to the plaintiff’s injuries); see also Sanchez v. Gomez, 283 F. Supp. 3d 524
(W.D. Tex. 2017) (denying a motion to dismiss based on the allegation that the
plaintiff’s son’s death was caused by a lack of implementation of de-escalation tactics).

One important de-escalation tactic is to slow things down so that deadly force
is not necessary. 18 Or to take cover in situations so that a threat to an officer is not
the event that triggers the alleged need for deadly force. 19 Here, the deputies did
neither. Once the deputies were told that Jones entered the Prescott home, they did
not try to de-escalate the situation or take cover and wait for her to come out.
Deputies Arias and Aguillon walked out into the open in front of the house. And once
Jones did come out, the alleged threat she posed to the uncovered deputies became
the event that allegedly justified lethal force.

Sheriff Salazar recently told the press that the BCSO would take a “deep dive”
into its use-of-force policy in light of the recent events across the country, including

15 Moravec, Eva R., De-escalation techniques for cops necessary, San Antonio Express News, Nov. 12,
2016, available at https://www.mysanantonio.com/opinion/commentary/article/De-escalation-
techniques-for-cops-necessary-10609008.php
16 See, e.g., , PERF’s 30 Guiding Principles on Use of Force , Police Executive Research Forum (Mar.

2016)
17 San Antonio Police Department General Manual, Procedure 501-Use of Force, available at

https://www.sanantonio.gov/Portals/0/Files/SAPD/OpenData/501-UseOfForce.pdf
18 See, e.g., , PERF’s 30 Guiding Principles on Use of Force , Police Executive Research Forum, at 54

(Mar. 2016) (“Whenever possible, officers should be trained to use distance and cover to ‘slow the
situation down’ and create more time for them to continue communicating and developing options.”),
available at https://www.policeforum.org/assets/30%20guiding%20principles.pdf
19 Id.
June 30, 2020
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the shooting of Rayshard Brooks in Atlanta. 20 According to Sheriff Salazar, “It made
us sit and say ‘what are we teaching our troops?’” Why didn’t Sheriff Salazar ask this
question in 2017 following the shooting of Kameron? Or before it?

The County’s “Investigations” and its Ratification of the Deputies’

Actions. The County and Sheriff Salazar cannot distance themselves from the
actions of its deputies, or claim their actions were inconsistent with Bexar County
policy or training. Bexar County and Sheriff Salazar have condoned and ratified the
conduct of the deputies in this matter. Indeed, the County and Sheriff Salazar have
stated, under oath:

Bexar County and Sheriff Salazar believe it was necessary to fire twenty
rounds at a person standing on the porch of an occupied home? A mobile home with
a sheet-thin exterior, where each bullet would easily glide through and hit whatever
and whomever was on the other side? With this official backing, it is apparent why
the deputies thought the use of gunfire and the amount of it was reasonable in these
circumstances. The County’s approval of this incident and the deputies’ actions risks
another event such as this occurring in the future.

The County’s response to question 6 above—that it does not feel the deputies
did anything wrong—apparently relies on investigations that took place after this
incident. The first, conducted by the Criminal Investigation Division, came to no
actual conclusion. More importantly, whether there was indictable criminal conduct
should not be the standard by which the County measures its deputies’ actions.

20Bexar County Sheriff’s Office will review its use-of-force policies following police killings in
Atlanta, Minneapolis, San Antonio Express News, Jun. 22, 2020, available at
https://www.expressnews.com/news/local/article/Bexar-County-Sheriff-s-Office-will-review-its-
15358629.php
June 30, 2020
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The second investigation is an undated and still-not-complete internal affairs

investigation. 21 This report does not even consider why it was necessary for the
deputies to fire almost twenty rounds, or why it was necessary for the deputies to fire
not one but two volleys of rounds at Jones and the occupied home. 22 It did not
consider whether deadly force was necessary in light of the occupied home behind
Amanda Jones. It did not consider whether BCSO could have used the K-9 that was
standing feet away from Jones at the time. And it did not consider whether BCSO
could have done anything to de-escalate the situation so that it never reached this
point. In fact, it is apparent from the context that this report was not even prepared
until well after this event.
Finally, the County relies on a report by an outside party—Charles “Chuck”
Joyner of Survival Sciences. Former Bexar County Criminal District Attorney Nico
LaHood commissioned Mr. Joyner to complete this report. Mr. Joyner holds himself
out as “protecting those who protect us.” 23 Far from impartial, Mr. Joyner touts one
of his speaking engagements as "Use of Force and Liability; or How Plaintiff’s
Attorneys Attack.” 24 According to one of his promotional videos, he “started Survival
Sciences to benefit law enforcement and to avoid liability issues.” 25 He even instructs
law enforcement to write any incident report with the mindset of “I’m going to get
sued.” 26 Was Mr. Joyner the proper person to provide an honest assessment of this
incident? Or was he already pre-disposed to writing a report for the purpose of
avoiding liability?27

Each of these “investigations” focus on alleged statements by persons that say

Amanda Jones had an object in her hand, or that certain people believed (wrongly)
that Jones had a gun. Based on these alleged statements and observations, the
County apparently concluded the deputies actions were not criminal and did not
violate any BCSO policy. But the answer cannot be to condone what happened that
day. We know the deputies did not intend to shoot Kameron, and we expect they each
have genuine remorse for what happened. But a County and a Sheriff’s office whose

21 The IA report produced to us has not been approved and has not even been signed by the Internal
Affairs Unit Commander of the Assistant Chief Deputy Chief of Staff, as is required. (IA Report
04206-19).
22 Bates 4206-19.
23 Survival Sciences, LLC, available at www.survivalsciences.com
24 Id.
25 Liability Issue in use of force, available at

https://www.youtube.com/watch?time_continue=124&v=A0WbaWPaJLc&feature=emb_logo
26 Id.
27 By way of example, Mr. Joyner conveniently leaves out the Deputy Longoria’s statement that he

saw “smoke coming from the firearm” that Jones allegedly fired. He also leaves out the fact that the
deputies fired almost twenty rounds.
June 30, 2020
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purpose is to provide for the safety of its residents cannot possibly condone how this
event unfolded. The easy way out is to blame Amanda Jones. But a true examination
would ask—why did it escalate to this? Why did a bounty-hunter-initiated event
result in the death of a child in an entirely different neighborhood? Why did our
deputies (who were the only people that actually had guns) end up firing twenty
rounds at an unarmed person and an obviously-occupied mobile home—a structure
that would provide no meaningful resistance to gunfire? Does the County really
believe almost twenty rounds fired at an occupied home was “only the amount of
deadly force necessary?” And why has the BCSO never taken a hard look at what
went wrong here, and how it can avoid another scenario like this in the future?
The Prescotts’ Offer. This case is not about financial compensation to the
Prescotts. There is no amount of money that will ever compensate for the loss of a
child. But financial compensation is all the law—and the County—can provide. You
cannot bring Kameron back.

This case is also about ensuring that Kameron’s life was not taken in vain. It
is as clear today as it was in 2017 that Bexar County needs to re-examine its use-of-
force policies, with a needed emphasis on de-escalation. How this event ever reached
the point that it did—with the shooting death of a child—must be studied and
rectified so that it never happens again.

The Prescotts are not anti-law enforcement. Kameron’s granddad was with
the San Antonio Police Department for decades. Christopher Prescott is a Marine.
They know and respect the role law enforcement must have in our community. But
they also know that its failure to learn lessons, adapt, and change will continue to
erode the public’s trust in it.

We are prepared to litigate this case further. And we are prepared to take it
to trial if necessary. But we also know that sometimes litigation has the unfortunate
effect of delaying needed remedial measures, as parties dig in to their positions. It
leads to paid outside experts writing reports for the purpose of “avoiding liability”
instead of providing an impartial assessment of the facts. With the recent events in
our country, now is the time to take a hard and honest look at doing better—without
delay. A full evaluation of the tragic events of this case is a great starting point.

The Prescotts would like to resolve this case. To that end, at this time, they
are willing to accept a fraction of what a jury would award to them should this case
proceed to trial. This event and Kameron’s death has consumed their lives, and they
are now ready to attempt to move forward without the pain of prolonged litigation.
The County recently offered $100,000 to resolve the Prescotts’ claims for the death of
June 30, 2020
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Kameron. To say this is inadequate is an understatement. If the County truly

wishes to resolve this matter, and offer some degree of closure to the Prescotts, a more
reasonable settlement offer is needed.

We are confident in our case. However, even if the County believes it is

immune from liability or suit in this matter, or that its damages are capped, the
County has the authority to waive that immunity or cap. See Wichita Falls State
Hosp. v. Taylor, 106 S.W.3d 692, 696 (Tex. 2003) (stating that the government may
waive immunity by statute or resolution). In other words, regardless of the County’s
view of this case from a legal perspective, it has the complete authority to fully
attempt to right this wrong. This is its opportunity to do so.

Keep in mind that if the County foregoes this opportunity, we will be forced to
proceed towards trial. If this case does reach a jury, the amount awarded to the
Prescotts will far eclipse the amount of insurance coverage available to the County.
The taxpayers of Bexar County will then be left to satisfy the excess judgment. Those
same taxpayers will wonder why the County failed to take this opportunity to resolve
this case now for a reasonable sum.

We would also remind you that the County and Sheriff Salazar recently filed a
motion to dismiss the Prescotts’ case. While we are confident that we will defeat this
motion, it is notable that the County did not file a motion to dismiss the Amanda
Jones case. While we understand the legal standard is different, consider what type
of message the County and the Sheriff are sending with this action. Should
Kameron’s life be treated as less than Amanda Jones?

Kameron did not have to die. There must be lessons learned from this event,
including questioning why it ever escalated to this outcome—where deputies fired
approximately twenty rounds towards an unarmed person and an occupied mobile
home. The Prescotts have suffered real pain. But they want to be part of the solution
so that no other parent has to endure what they have. In the event that the County
is willing to and does resolve this matter, the Prescotts welcome the opportunity to
meet with you to help move forward.

We appreciate your sincere attention to this matter and hope that you are able
to work with us to provide some closure to the Prescotts. We stand ready and willing
to meet with you and your attorney to determine how best to resolve this matter.
June 30, 2020
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Very truly yours,

Scott C. Krist Thomas A. Crosley

The Krist Law Firm, P.C.
The Krist Building
17100 El Camino Real
Houston, Texas 77058
(281) 283-8500
Counsel for Rubi Prescott
Crosley Law Firm, P.C.
3303 Oakwell Ct., Ste. 200
San Antonio, Texas 78218
(210) 529-3000
Counsel for Christopher Prescott