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In a notice of claim Tuesday, Jeffries’ attorney, Tom Horne, said a July 7 report by the Department of Public Safety contained a series of false statements. He said these ranged from a conclusion that Jeffries carried a gun onto state property, to claims that he wanted to create and control his own DES police force.

Jeffries’ reputation has been damaged along with his ability to earn a living, Horne said.

The Attorney General’s Office has 60 days to respond. If it does not offer a settlement acceptable to Jeffries, he is free to sue.

“We do not comment on pending litigation,� said DPS spokesman Bart Graves.

Jeffries had been Gov. Doug Ducey’s choice to head the agency of more than 7,000 employees, which oversees a host of programs including food stamps, welfare benefits and unemployment insurance, and is responsible for investigating cases of adult abuse.

Last November, the governor fired Jeffries after reports that he had flown to Nogales on a state plane to take several staffers out drinking at a restaurant during business hours. Jeffries was celebrating the fact these workers had agreed to become “at will� employees who could be fired for no reason at all.

Gubernatorial press aide Daniel Scarpinato said the firing of Jeffries from the $215,250-a-year post was the result of a series of incidents.

The DPS got involved after it was learned that DES, which had its own security force, had a cache of weapons and ammunition. State troopers eventually seized 55 handguns and nearly 89,000 rounds of ammunition stored in the basement. Henry Darwin, named by Ducey as interim DES director, said the officers followed Jeffries to his Scottsdale home where they confiscated a gun he had purchased for himself with public funds.

Ducey asked DPS to audit the stockpile and review the purchases and security procedures.

Among the findings was that the amount of ammunition “may reasonably be described as excessive,� with the report saying it is three or four times what a large police department might need in a year. Investigators also said they could not find about 4,000 rounds.

The report also said “policies and procedures� for purchases were violated, that “there was essentially no security� for the ammunition and that DES employees had “easy access� to the weapons.

Jeffries contends some other points in the report are lies.

One is the conclusion that Jeffries was building and wanted to control a police force at DES, partly in response to the 2015 terrorist attack on a San Bernardino, California, social-services center in which 14 people were killed.

“That was false,� Horne stated in his notice of claim.

Also false, Horne said, are conclusions in the report that Jeffries regularly took ammunition from the DES inventory, that he went to a gun range on a weekly basis and would leave early, and that he wanted to arm every DES employee.

Jeffries criticized the findings when they were released last month.

“This slipshod DPS audit is disjointed, disingenuous, deceitful, dishonest and dishonorable,� he said on Twitter.

Horne said the state and its taxpayers are liable because the statements in the report came from state employees. “The state is responsible for its employees,� he said. “And if they act with malice, the state is liable.�

Malice means either they knew the statements were false or acted with reckless disregard for the truth. “Some of the sources (for the DPS report) were former employees who were justly fired,� Horne said. “They’re getting back at him,� he continued. “I think we can prove malice.�

In a historic 1964 ruling, the U.S. Supreme Court concluded that the First Amendment protects the publication of even false statements about the conduct of public officials. Someone can sue for damages only when they can show the statements were made with “actual malice.�

That ruling was later expanded to cover public figures.

And while Jeffries is no longer a public official, he remains a public figure.

As to where the $5.1 million figure came from, Horne said ÃÛèÖÖ±²¥ law requires those threatening to sue the state to provide a specific figure for which they are willing to settle. He did not say how he arrived at that number.

Jeffries was involved in several controversial issues at DES before the plane trip to Nogales. He had fired close to 500 workers, including many who previously received high evaluations and raises. That led to allegations that the director was targeting women, minorities, older workers and gays.

It got to the point that Ducey removed Jeffries’ power to fire workers. The governor also set up a process for fired workers to get their jobs back.

Last year, Jeffries came under scrutiny for emailing staffers, offering to take their written “special intentions� to the holy shrine of Lourdes.

A month later, Jeffries sent a message to all DES employees on a state-owned email list with a link to a story with arguments against Proposition 205. That measure, since defeated, would have allowed the recreational use of marijuana.