MONETARY EXPOSURE & DAMAGES ESTIMATE

Internal Strategy Document: Restricted Distribution
Date: 2025-12-21
Case: FCFCU v. CODY RICE-VELASQUEZ

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🧮 PROJECTED SETTLEMENT/JUDGMENT BANDS

1. Direct Economic Damages (Strongest Evidence)

Item	Estimated Range (USD)	Notes
Utilities (Post-Possession)	$1,500–$4,000	Ongoing liability; AES bills + disconnects.
Personal Property Loss	$600–$1,200	Mini-fridge, food, contents, replacement cost.
Electronics/Tech Impacts	$1,000–$3,000	Routers, desk equipment, re-setup costs.
Property Damage (Baseline)	$8,000–$25,000	Burst pipes, water remediation, mold cleanup.
Subtotal (Economic)	$11,100–$33,200

2. Displacement & Consequential Damages

Item	Estimated Range (USD)	Notes
Emergency Housing	$5,000–$15,000	Lodging, shelter, transit since 12/09.
Lost Productivity	$3,000–$10,000	Interruption of work/business capacity.
Roommate Displacement (Zai)	$2,000–$6,000	Secondary liability for displacing ally.
Subtotal (Consequential)	$10,000–$31,000

3. Non-Economic Damages (Discretionary)

Item	Estimated Range (USD)	Notes
Emotional Distress	$10,000–$40,000	Trauma of armed removal + sentimental loss.
ADA/Accommodation Harm	$5,000–$20,000	Failure to accommodate known disabilities.
Subtotal (Non-Economic)	$15,000–$60,000

4. Punitive / Enhanced Exposure (Leverage)

Item	Estimated Range (USD)	Notes
Willful Conduct	$10,000–$50,000	Conduct after notice of void judgment.

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📊 TOTAL REALISTIC EXPOSURE SUMMARY

• LOW-END (Conservative Court): $35,000–$50,000
• MID-RANGE (Likely Scenario): $60,000–$90,000
• HIGH-END (Disturbed Court): $100,000–$150,000+

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💡 STRATEGIC NOTES

• Leverage: The goal is to anchor these numbers during negotiations and the Jan 9 hearing.
• Remediation: Formal contractor estimates for mold/water damage will likely push the “Property Damage” category into the high-end range.
• Mitigation: The Defendant’s denial of access locks them into these liability bands as they prevented Cody from reducing the loss.