March 17, 2023

VIA ELECTRONIC MAIL:

Ron.Kim@saratoga-springs.org
Ron Kim, Mayor
City of Saratoga Springs
474 Broadway
Saratoga Springs, NY 12866

Re: Our Client: Carrie Schermerhorn

Our File No.: 2047571

Dear Mayor Kim:

Please be advised that Harding Mazzotti LLP has been retained to represent
former employee Carrie Schermerhorn with respect to her claims against the City
of Saratoga Springs pursuant to New York Labor Law Sections 215 & 7401. These
claims include our client being retaliated against, including eventual termination,
by City Commissioner Dillon Moran for refusing to engage in unlawful conduct and
for reporting violations of the law including retaining a firm2 with ethical conflicts
to complete City assessment work at greatly inflated rates, as well as ordering our
client to grant tax privileges to his friends.

In the immediate future we will provide further details regarding the actions
taken against our client as well as the damages she has suffered as a result. Please
be aware that any act of retaliation directed at Ms. Schermerhorn will be strictly
scrutinized. Retaliation is palpably illegal under the above statutes.

The above-referenced text is merely a summary, should in no way be

construed as a complete recapitulation of all pertinent facts, and is written without
prejudice and without waiver of, and, indeed, with full reservation of all of our
client’s rights and remedies.

1
discloses, or threatens to disclose to a supervisor or to a public body an activity, policy or practice
of the employer that the employee reasonably believes is in violation of law, rule or regulation.
2
Gar Associates, LLC
 Please note this letter constitutes a notice of intent to sue and any and all documents,
including, but not limited to, contracts, reports, notes, memoranda, bills, receipts, e-mail
correspondence, and any other electronically stored information relating to Ms. Schermerhorn,
whether or not pertinent and/or material to the aforementioned claims, or to any potential claims
that she may have, should be preserved to every extent possible.

Should you wish to discuss this matter before further correspondence is issued, please
contact the undersigned.

We anticipate and appreciate a prompt response.

Very truly yours,

Kelly Magnuson
Toll Free: (518) 862-1200
Email: Kelly.Magnuson@1800law1010.com

KAM/pro

Cc: Tony Izzo, City Attorney @ tony.izzo@saratoga-springs.org