WOODBINE, Ga. (AP) — Attorneys for the family of a Black man fatally shot by a Georgia deputy during an October traffic stop have given formal notice of plans to sue the sheriff’s office in a letter demanding $16 million in restitution.

Civil rights attorneys Ben Crump and Harry Daniels told reporters Tuesday that the sum represents $1 million for every year Leonard Cure spent imprisoned in Florida on a wrongful conviction. He was killed just three years after Florida authorities set him free.

“Everything was going right for Leonard, things were looking up, until he had this encounter with this sheriff’s deputy,” Crump said during a news conference with members of Cure’s family.

Camden County Staff Sgt. Buck Aldridge killed 53-year-old Cure during a violent struggle on the shoulder of Interstate 95 after pulling him over for speeding and reckless driving.

Dash and body camera video of the Oct. 16 shooting show Aldridge shocking Cure with a Taser after he refused to put his hands behind him to be cuffed. Cure fought back and had a hand at the deputy’s throat when Aldridge shot him point-blank.

Relatives have said Cure likely resisted because of psychological trauma from his imprisonment in Florida for an armed robbery he didn’t commit. Officials exonerated and freed him in 2020.

The lawyers for Cure’s family say Camden County Sheriff Jim Proctor should never have hired Aldridge, who was fired by the neighboring Kingsland Police Department in 2017 after being disciplined a third time for using excessive force. The sheriff hired him nine months later.

And video from a June 2022 chase that ended in a crash shows Aldridge punching a driver who is on his back as the deputy pulls him from a wrecked car. Records show no disciplinary actions against the deputy.

“We don’t believe he should have ever been a deputy at this point, when you look at the history of his violating the civil rights of citizens,” Crump said.

Georgia requires lawyers to give formal notice to state or local government agencies before they can file civil lawsuits against them in state courts. The letter, which the Cure family’s attorneys said they mailed Monday, gives Camden County 30 days to settle the case out of court.

Cure’s mother, Mary Cure, said spending the holidays without her son has been painful and that coming into Georgia on the highway where he was shot had filled her with anxiety Tuesday. But she vowed to get justice for his death.

“No, the money doesn’t mean a damned thing to me,” Mary Cure said. “I would rather have my child back.”

Capt. Larry Bruce, a spokesman for the sheriff, said the department had not yet received the attorneys’ letter Tuesday. He declined further comment.

An attorney for Aldridge, Adrienne Browning, has previously said he’s a “fine officer” who shot Cure in self-defense. She did not immediately return email messages seeking comment Tuesday.

Aldridge is on administrative leave pending a decision by Brunswick Judicial Circuit District Attorney Keith Higgins on whether to seek criminal charges in Cure’s death.

Three experts who reviewed video of the shooting told The Associated Press they believed it was legal, as Aldridge appeared to be in danger when he fired. But they also criticized how Aldridge began the encounter by shouting at Cure and said he made no effort to deescalate their confrontation.