Full text is in Comments of this blog entry.
- Pay the family guardian of Police Chief David Brame & wife Crystal's children $12m
- Change facility "Tacoma-Pierce County Family Justice Center" name to "Crystal Judson Family Justice Center."
- Have the facility's full name on the outside and inside of the building
- Have the facility's full name on the letterhead, logos, graphics, stationary and seals
- Have plaque displayed prominently at or near the entrance to the facility, or within the lobby of the facility which will read: "The Family Justice Center is dedicated to the memory of Crystal Judson and other victims of domestic violence. Crystal Judson was fatally shot on April 26, 2003 by her estranged husband, the Chief of Police of Tacoma."
- If the facility gets a website provide for a dedicated page on the website to the memory of Crystal Judson.
- Mayor and The City Manager of the City of Tacoma will sign a letter to the plaintiffs which will state: On behalf of the City of Tacoma, we write this letter to express our deep regret to the family of Crystal Judson for her death. We are committed to actions, policies and changes which are aimed at preventing similar tragedies from occurring again.
- Continue King County cause number 04-2-00712-7KNT during which time any party may conduct depositions of such persons as they deem necessary
- Leave possibility of discovery open to depose others not yet listed.
- Depositions will be scheduled and conducted as expeditiously as possible.
- Any dispute arising during depositions will be resolved by Steve Scott.
- Tacoma will designate April 26 of each year as domestic violence awareness day.
- Tacoma will continue to support and advocate for passage of Senate Bill 6161, or its similar successors, until passage. The current City Manager and Mayor will continue to advocate in support of comparable federal legislation.
- City will continue to make reasonable efforts regarding review and improvement of its Code of Ethics.
- Tacoma Police Department will try to obtain accreditation.
- Tacoma will work on recommendations of the Citizens Oversight Committee.
- Tacoma will work on recommendations of the WASPC Citizen Advisory Panel.
- Tacoma will work on recommendations of the Carol Buracker & Associates Audit.
- Tacoma will work on psych evals for recruits and fitness for duty evals of police officers.
- Tacoma will give family back all personal pictures, video tapes and other personal items obtained from them.
- Lawsuit against Mayor William Baarsma will be dropped
- On completion of the depositions all claims among all remaining lawsuit parties will be free of being sued.
- City will make all discovery exchanged between the parties available for public inspection and copying, except medical, psychological, counseling or other treatment records of any individual, educational records, or other records to which an individual or group may have a right of privacy, or which a court may order not to be released.
- The City agrees to continue to work in good faith and make reasonable efforts to fulfill the terms and intent of these provisions.
THE AGREEMENT:
ReplyDeleteThis agreement is made by and between the undersigned current and former plaintiffs in King County cause number 04-2-00712-7KNT (hereafter plaintiffs) and the defendants City of Tacoma, William Baarsma, Catherine Woodard and Raymond Corpuz (hereafter the defendants). For and in consideration of the following described reciprocal promises, the plaintiffs and defendants hereby agree to resolve and settle King County cause number 04-2-00712-7KNT, and all claims, causes of action and damages which were or could have been asserted therein among the parties thereto and their past and present employees and insurers.
PROMISES:
1. The City of Tacoma and its insurers will, within 30 days following the approval of this agreement by the City Council, pay, by check or draft made payable to Luvera Trust Account, in trust for Julie Ahrens, as personal representative of the estate of Crystal Brame, and guardian of the children Haley Brame and David Brame Jr., or as may be ordered by the court, the sum of $12 million;
2. The City of Tacoma will, within 30 days following the approval of this agreement by the Court, by resolution authorize the Mayor of the City of Tacoma to sign an amendment of that certain interlocal agreement, made and entered into on May 11, 2005, between the City of Tacoma and Pierce County which committed Tacoma's participation along with Pierce County in the facility known as the "Tacoma-Pierce County Family Justice Center." Said amendment shall, with the consent of Pierce County, effect the following changes to the agreement as presently constituted:
A. Change all references within said agreement from "Tacoma-Pierce County Family Justice Center" or "Family Justice Center" to "Crystal Judson Family Justice Center."
B. Provide that exterior and interior signage of the facility reflect the full name as set forth above.
C. Provide that letterhead, logos, graphics, stationary and seals reflect the full name as set forth above.
D. Provide for a plaque of a size for reasonable readability in light of its surroundings to be displayed prominently at or near the entrance to the facility, or within the lobby of the facility which will read: "The Family Justice Center is dedicated to the memory of Crystal Judson and other victims of domestic violence. Crystal Judson was fatally shot on April 26, 2003 by her estranged husband, the Chief of Police of Tacoma."
E. In the event the facility maintains a website, provide for a dedicated page on the website to the memory of Crystal Judson. The contents of said page shall be approved by the facility's Executive Board.
3. The Mayor and The City Manager of the City of Tacoma will sign a letter to the plaintiffs which will state: On behalf of the City of Tacoma, we write this letter to express our deep regret to the family of Crystal Judson for her death. We are committed to actions, policies and changes which are aimed at preventing similar tragedies from occurring again.
4. The Plaintiffs and the Defendants will consent to the continuation of King County cause number 04-2-00712-7KNT during which time any party may conduct depositions of such persons as they deem necessary to their determination of the facts and circumstances surrounding the hiring, promotion, performance and supervision of David Brame, and the response of City employees to information concerning allegations, including but not limited to of domestic violence in the marriage of David Brame and Crystal Judson.
A. Within 7 days following the approval of this agreement by the City Council of the City of Tacoma, any party wishing to conduct such additional discovery will submit a list to all other parties identifying individuals they wish to depose pursuant to this agreement.
B. Depositions will be scheduled and conducted as expeditiously as possible.
C. Any dispute arising during the course of such depositions will be resolved by Steve Scott pursuant to the terms of the order entered in King County cause number 04-2-00712-7KNT on July 7, 2005.
5. The City of Tacoma will, within 30 days following the approval of this agreement by the City Council of the City of Tacoma, adopt a resolution designating April 26 of each year as domestic violence awareness day.
6. The City of Tacoma will, as part of its annual Legislative Priorities, continue to support and advocate for passage of Senate Bill 6161, or its similar successors, until passage. The current City Manager and Mayor will continue to advocate in support of comparable federal legislation.
7. The City will continue to make reasonable efforts regarding review and improvement of its Code of Ethics.
8. The City of Tacoma Police Department will continue to make reasonable efforts to obtain accreditation by the Washington Association of Sheriffs and Police Chiefs (WASPC).
9. The City of Tacoma will continue to make reasonable efforts regarding implementation of the Citizens Oversight Committee.
10. The City of Tacoma will continue to make reasonable efforts regarding implementation of the WASPC Citizen Advisory Panel.
11. The City of Tacoma will continue to make reasonable efforts regarding implementation of the recommendations contained in the Carol Buracker & Associates Audit.
12. The City of Tacoma will continue to make reasonable efforts to determine, establish and implement policies for psychological screening of police recruits and for administration of fitness for duty evaluations of police officers.
13. The City of Tacoma will return to plaintiffs all personal pictures, video tapes and other personal items obtained from plaintiffs through discovery.
14. Immediately following approval of this agreement by the City Council, Plaintiffs and Defendants will jointly execute and file with the Court a stipulation and order dismissing all claims against William Baarsma asserted in King County cause number 04-2-00712-7KNT with prejudice and without costs.
15. Plaintiffs and Defendants will, within 30 days following the later of (1) the approval of this agreement by the court or (2) the completion of the depositions described in paragraph 4 above, jointly execute and file with the Court, a stipulation and order dismissing all claims among all remaining parties to King County cause number 04-2-00712-7KNT, as well as all past or current employees of the City of Tacoma, and their insurers with prejudice and without costs.
16. Upon entry of the stipulation and order of dismissal dismissing all claims of all parties, the City will make all discovery exchanged between the parties available for public inspection and copying, except medical, psychological, counseling or other treatment records of any individual, educational records, or other records to which an individual or group may have a right of privacy, or which a court may order not to be released.
17. The parties to this agreement acknowledge and agree that the promises described in paragraphs 2 and 5 through 12 are of indefinite duration. The City agrees to continue to work in good faith and make reasonable efforts to fulfill the terms and intent of these provisions but no promises of a particular outcome are made except as set forth herein.
________________________
JULIE AHRENS, individually, as
personal representative of the estate
of Crystal Brame, and as guardian
of Haley Brame and David Brame Jr.,
on their behalf
___________________________
LANE JUDSON
___________________________
PATTY JUDSON
___________________________
JAMES DEGEL, guardian ad litem for
Haley Brame and David Brame Jr.,
on their behalf
______________________________
PAUL LUVERA
DAVID BENINGER
ANDY HOYAL
Attorneys for Julie Ahrens, Haley
Brame and David Brame, Jr.,
Lane Judson and Patty Judson,
and the Estate of Crystal Brame
___________________________
WILLIAM BAARSMA, individually,
and as Mayor of the City of Tacoma
___________________________
ERIC ANDERSON, City Manager of
the City of Tacoma
________________________
TIMOTHY R. GOSSELIN
ROBERT N. NOVASKY
JILL STONE
Attorneys for the City of Tacoma and
William Baarsma