Document Type
Legal Notice — Notice of Claim and Litigation Hold (Exhibit A)
Date
April 26, 2021
Sent To
Virginia Beach City Attorney
Summary
This notice of claim was sent approximately one month after the shooting of Donovon Lynch. It formally notifies the City of Virginia Beach of impending legal action and demands preservation of all evidence related to the incident.
The letter identifies the shooting location near 20th Street and Pacific Avenue and asserts that Lynch was wrongfully shot by Officer Solomon Simmons.
Key Details
- Identifies date of loss: March 26, 2021
- Location: 20th Street and Pacific Avenue
- Alleges wrongful shooting by Officer Simmons
- Sent prior to filing of federal lawsuit
Evidence Preservation Requests
The letter demands preservation of:
- Police body-camera footage
- Surveillance video (businesses, traffic cameras)
- Witness statements
- Incident and investigative reports
- Communications (emails, texts, memos)
- Records of activity within a one-mile radius during the incident window
Why This Matters
This document shows how early the estate moved to preserve evidence, and what categories of evidence were believed to exist immediately after the shooting.
The Donovon Lynch Case 