SWORN NOTICE 01 To: —R.G. “Bob” Shuman, City Clerk Gary Fuller, Mayor City of Opelika 204 South Tih Street Opelika, Alabama 36801 Akinola Popoola, Director Opelika Housing Auth Post Office Box 786 Opelika, Alabama 36803-0786 Pursuant to Ala, Code §§ 11-47-190 and 11-47-192 (1975) and/or otherwise, please take notice that Felisha Core, individually, and as mother and next friend of Za'Kyhia Core, deceased; Keiyonna Core; Atira Core, deceased; Karmina Core, deceased; and Bryson Core, deceased (collectively, “Claimants”), hereby make a claim against the Opelika Housing Authority (SOHA”) for wrongful death and for personal injury, mental anguish/emotional distress, punitive damages, and all other damages recoverable by law and/or in equity resulting from OHA and/or its agents, servants, or employees’ negligent, wanton, and/or tortious acts and/or omissions as more fully described herein as follows: 1, In 2016 and early 2017, Claimants resided in a mobile home located at 1300 South Long Street, Lot 113, Opelika, Alabama (the “Premises”), which was owned by Vincent Lamar Kindred (“Kindred”). 2. Claimants resided at the Premises pursuant to the Housing Choice Voucher Program (Section 8), which was administered through OHA. 3. On or about January 12, 2017, a fire occurred at the Premises. The fire resulted in the deaths of Za’Kyhia Core, Atira Core, Karmina Core, and Bryson Core, all minor children Keiyonna Core, a minor child, suffered serious physical injury and other damages as a result thereof and remains hospitalized at Children’s Hospital in Birmingham.4, Upon information and belief, the fire was caused by a faulty electrical wiring device that had been placed on the Premises by Kindred and/or agents, servants, or employees under his direction and control. ‘The faulty wiring device had been placed on the Premises in or about the fall of 2015 5. As the recipient of federal funding from the U.S, Department of Housing and Urban Development (“HUD"), OHA was required to conduct periodic and/or annual health and safety inspections of the Premises. 6. In or about the summer of 2016, an agent, servant, and/or employee of OHA whose identity as unknown at present, but whose name Claimant believes to be “Ms. Summers,” purported to conduct an inspection of the Premises. 7. Said inspection was performed negligently, carelessly, and/or unskillfully. As a result thereof, the faulty electrical wiring device was allowed to remain on the Premises, which subsequently resulted in the aforementioned fire. 8. As a result of the neglectful, careless, or unskillful acts of the OHA, by and though its agent, servant, and/or employee who was engaged in work on behalf of OHA, and while acting in the line of his or her duty, Claimants have suffered substantial injuries and damages, for which the OHA is liable. As a direct proximate result of said wrongful and tortuous actions, Claimants have suffered the following damages and injuries, which include, but are in no way limited to the following: (a) Za’Kyhia Core, Atira Core, Karmina Core, and Bryson Core deceased; (b) Keiyonna Core suffered serious and permanent bodily injuries as set forth herein; (b) Keiyonna Core was caused to undergo medical treatment in and about an effort to cure her injuries and damages and, as a result of his injuries will be caused to undergo doctor, hospital, and medicaltreatment in the future; (c) Keiyonna Core suffered and continues to suffer great physical pain and mental anguish and will so suffer in the future; (d) Felisha Core, individually, suffered and continues to suffer great physical pain and mental anguish and will so suffer in the future; (e) Felisha Core has been caused to suffer worry, humiliation, fear, loss of sleep, anxiety, and mental anguish and emotional distress and will so suffer in the future; (f) Keiyonna Core has sustained a permanent disability and impairment to his body as a result of the injuries; and (g) Keiyonna Core was permanently injured and damaged as a result of his injuries and will remain permanently injured in the future, and was otherwise injured and damaged. WHEREFORE, Claimants demand payment from the OHA for reasonable and just compensation for their damages and injuries as set forth herein. Sworn to and subseribed this the //-4 day of February 2017. LISHA CORE, Individually, and as Mother and Next Friend of Za’ Kybia Core, a minor child, deceased, Altra Core, a minor child, deceased, Karmina Core, a minor child, deceased, Bryson Core, a minor child, deceased, Keiyonna Core, a minor childSTATE OF ALABAMA) COUNTY OF LEE ) 1, the undersigned authority, a Notary Public in and for said State at Large, hereby certify that ELISHA CORE, whose name is signed to the foregoing document and who is known to me, acknowledged before me on this day that, being informed of the contents, that each and every allegation contained within said document is true and correct to the best of his information Knowledge and belief, and that he executed the same voluntarily. GIVEN under my hand and official seal this the /¥ ed day of February 2017. “ ' "ARY PUBLIC iSEAL] My commission expires: 5-/4-/Z the Attomeys Tor OF COUNSEL: Davis B. Whittelsey Jonathan K. Corley WHITTELSEY, WHITTELSEY, POOLE & CORLEY, P.C. 600 Avenue A Opelika, Alabama 36801 Tel: (334) 745-7766 Fax: (334) 745-7666 Email: jcorley@ dwhittelsey@wwp-law.com swp-law.comVIA HAND-DELIVERY RG. “Bob” Shuman, City Clerk City of Opelika 204 South 7th Street Opelika, Alabama 36801 Gary Fuller, Mayor City of Opelika 204 South 7th Street Opelika, Alabama 36801 VIA U.S. MAIL Akinola Popoola, Director Opelika Housing Authority Post Office Box 786 Opelika, Alabama 36803-0786 VIA E-MAIL Jennifer Chambliss SAMFORD & DENSON, LLP 709 Avenue A Opelika, Alabama 36801 Attorneys for OHA Gunter P. Gunter, IIL City Attorney Post Office Box 390 Opelika, Alabama 36803-0390