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OFFICE OF THE COMPTROLLER

CITY OF NEW YORK


--------------------------------------------------------------)(
VANESSA HICKS,

Claimant,

-versus-
NOTICE OF CLAIM
THE CITY OF NEW YORK: CAPTAIN JON
BLOCH, New York City Police Department;
SERGEANT SEAN WICK, New York City
Police Department, SERGEANT IV AN
GONZALEZ, New York City Police Department,

Respondents.
--------------------------------------------------------------)(

TO: THE COMPTROLLER OF THE CITY OF NEW YORK

PLEASE TAKE NOTICE that Vanessa Hicks intends to file claims for damages

against the City of New York, Captain Jon Block, Sergeant Sean Wick, and Sergeant

Ivan Gonzalez,

In support of her claims, Claimant states as follows:

1. The name of Claimant is Vanessa Hicks, and her address is 285 Macdougal

Street, Apartment 2, Brooklyn, New York 11233. The name of the attorney for Claimant

for purposes of this Notice of Claim is Christopher Dunn, New York Civil Liberties

Union Foundation, 125 Broad Street, 19th Floor, New York, New York 10004.

2. Claimant has suffered violations of her rights under New York Labor Law,
including but not limited to sections 215 and 2l5~a; under section 296 of the New York

Executive Law; and under sections 8-107, 8-502 of New York City Administrative Code.

3. The time, place, and manner in which the claims arose are as follows:

Claimant Vanessa Hicks began her employment as a member of


the New York City Police Department in July 2002. In January 2010, in
an act of discrimination on the basis of her race and gender and in
retaliation for having complained about her discriminatory treatment,
Officer Hicks was placed on dismissal probation on the basis of
unfounded charges against her arising from an incident at the 40th Precinct
involving the parking of her private car. That probation was scheduled to
end in January 2011.
In May 2010, while assigned to the 42nd Precinct in the Bronx,
Officer Hicks was approached by Captain Jon Bloch, the precinct
commanding officer, and informed that she needed to meet certain quotas
or else risk being placed on an undesirable tour. He also mentioned her
probationary status, which Officer Hicks understood to be a threat that she
risked losing her job if she did not meet the quotas. Captain Bloch
specifically told Officer Hicks that she needed to issue 25 summonses,
conduct 5 stop-and-frisks, and make 1 arrest every month.
Over the next seven months, Officer Hicks was constantly
pressured by her direct supervisor Sergeant Sean Wick to issue
summonses and conduct stop-and-frisks. She was also pressured by other
supervisors in the precinct. For instance, on three occasions in November
2010 Sergeant Ivan Gonzalez told her that she needed to issue five
summonses and conduct five stop-and-frisks in a single tour. Officer
Hicks frequently objected to and complained about being pressured to
comply with quotas during this period.
During this period, Officer Hicks, who is African-American, was
also subject to discriminatory treatment based on her race and gender.
For instance, male officers were not required to write as many summonses
as were female officers. As another example, on December 27,2010
(three days before she was suspended) Sergeant Wick said "that bitch can
walk" when referring to an order that Officer Hicks not be driven to a
distant foot post after a heavy snow falL The following day, as-an-
example of the abusive treatment she received because of her failure to
meet quotas and because of her race and gender, Sergeant Wick ordered
Officer Hicks to dig his personal vehicle out of the snow.
On December 29, 2010, another officer informed Officer Hicks
that he had overhead a conversation in which Sergeant Wick had said that,
as a result of her not producing as required by the precinct, he intended to
follow Officer Hicks around and find some reason to take action against
her. Later that day, Officer Hicks observed a department vehicle
following the patrol car she was driving while on duty. At some point,
Officer Hicks stopped her car and learned that she was being followed by
Sergeant Wiele Sergeant Wick signed the memo books of Officer Hicks
and her partner, and Officer Hicks then proceeded to the precinct with the
intent of meeting with Captain Bloch to complain about her mistreatment.
He refused to meet with her.
On December 29, 2010, following the encounter with Sergeant Wick,
Officer Hicks contacted the NYPD's employee management division and
complained that she was being harassed for her failure to meet quotas and was
being mistreated because of her race and gender. She was told that her complaint
would be relayed to officials at police headquarters (One Police Plaza).
On December 30, 2010, which was a regular day off for her,
Officer Hicks was ordered to report for an interview as part of a formal
department investigation. After the interview that day, she was suspended
from her job without pay. On February 3,2011, Officer Hicks was
notified that she had been terminated from her position with the police
department without explanation.

4. Claimant has suffered the following injuries: (1) unlawful dismissal from her job

and the related loss of salary and benefits; (2) emotional distress.

Based on the information known to Claimant at this time, Claimant has suffered

or, based upon her years of service in the NYPD, will suffer damages amounting to no

less than $1. 5 million for violations of her rights under laws and the Constitution of the

State of New York. Claimant reserves her right to supplement the nature of her claims,

the identity of New York City officials or employees named in her claims, the nature of

her damages, and the amount of total damages.

5. Please take notice that Claimant presents this claim for .adjustment and-payment-

and notifies Respondents that, unless this claim is adjusted and paid within the time

provided by law, Claimant intends to commence an action against Respondents.


(/)Ai~L
CHR1STOP
-:Jf>-
R DUNN
~
New York Civil Liberties Union Foundation
125 Broad Street, 19th Floor
New York, New York 10004
(212) 607-3300, ext. 326

Counsel for Claimant


Dated: New York, NY
March 29,2011
OFFICE OF THE COMPTROLLER
CITY OF NEW YORK
--------------------------------------------------------------)(
VANESSA HICKS,

Claimant,

-versus-
VERIFICATION
THE CITY OF NEW YORK: CAPTAIN JON
BLOCH, New York City Police Department;
SERGEANT SEAN WICK, New York City
Police Department, SERGEANT IVAN
GONZALEZ, New York City Police Department,

Respondents.
--------------------------------------------------------------x

State of New York )


): ss
County of New York)

VANESSA HICKS, being duly sworn, attests that she is the claimant in this
matter, that she has read the attached Notice of Claim, and that she attests that the
statements therein are true and correct to the best of her knowledge, information, and
belief.

fl) Ovv\fU}/ c,-- /~


VANESSA HICKS

Sworn and subscribed to me


this 29th day of March 2011
ADRIANA CECILIA PINON
- -~--~--------~- ---, ---~---~-~-~-~-~-No~02PI6223552---~---~--~~-~~
~~ Notary Public, State of New York ----.--~--------~----.~--------
. -
~J ' ~, Qualified In New York County
.f/l C
1/~ Commission expires 06/14/14
Nota Public

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