AR V Interim Care Foster Family Agency Civil Complaint June 25 2015

CIV 150625 CIV DS1508999 CASEEN 150202
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System Code
CIV
Case Number
DS1508999
CaseType
CIV
Action Code
CASEEN
Action Date
06 25 15
ActionTime
Action
Seq
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by
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PURPOSES ONLY AND THIS IS NOT
A PART OF THE OFFICIAL RECORD
YOU WILL NOT BE CHARGED FOR
0002
TH I S PAG E
VGONZ
Complaint and Party information entered
NEW FILE
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2
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BRIAN E CLAYPOOL SBN 134674

THE CLAYPOOL LAVV IRM
1055 E Colorado Blvd Sth Floor
Pasadena California 91106
beces
aol com
626 240 4616
Telephone
626 796 995
Facsimile
Attorney
for Plaintiffs
f L
rCa
nti r A
ON
J
Y
4
5
sU
ry
ti
r
GV
d PU
N
SUPERIOR COURT OF THE STATE OF CALIFORNIA

7
8
COUNTY OF SAN BERNARDINO

CIVDS1508994
9
A R
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11
a minor through
his
guardian ad
litem RAQUEL ESTES
STARQUISHA BUNN individually
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COMPLAINT FOR DAMAGES

1
NEGLIGENCE
NEGLIGENCE PER SE
INTENTIONAL INFLICTION
OF EMOTIONAL DISTRESS
CONSPIRACY
Plaintiffs
13
14
Case No
15
16
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TERIM CARE FOSTER FAMILY

AGENCY a California Corporation
SUKHWINDER SINGH an individual
FREDDIE WILSON an individual
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AJAY MALHOTRA an individual

BHUPINDER CHHUDU an
individual KHUSHANUD AZARIAH
19
an individual JOEL DOMINGUEZ an

individual SHAHZIA RAMNIT an
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individual LISA OATES an
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individual NAWAB WILSON an

individual and DOES 1 throug 50
DEMAND FOR JURY TRIAL
inclusive
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23
Defendants
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26
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VENUE AND JURISDICTION
1
2
Venue is proper in the Superior Court of the State of California for the
County of San Bernardino in that the underlying wrongdoing acts omissions

4
5
6
injuries and related facts and circumstances upon which the present action is based
occurred in the County of San Bernardino California within the judicial boundaries
7
of
this Superior Court
This Superior Court has jurisdiction over the present matter
8
9
10
because as described herein the nature of the claims and amounts in controversy
meet the requirements for unlimited damages jurisdiction
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PARTIES
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2
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14
At all relevant times Plaintiff A R was a minor child residing in San
Bernardino
County
A R
date
of
birth is August 1
1999 Raquel Estes has been
15
petitioned to be the court appointed Guardian ad Litem A R is currently a foster

16
1
child and was caught in an illegal abusive violent concealed unconscionable
1g
for
cash
kids
operation from 2010 to 2011 run by defendant INTERIM CARE FOSTER
19
FAMILY AGENCY
INTERIM
and defendants uncertified LISA OATES
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21
22
OATES
and
NAWAB WILSON
WILSON
At all times herein plaintiff
A R suffered ongoing unrestrained terror torture corporal punishment physical
23
and mental abuse and neglect at the hands of defendants OATES and WILSON
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26
covered up and unchecked by INTERIM

3
At
all relevant
times Plaintiff STARQUISHA BUNN
BUNN
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28
a minor child residing in San Bernardino County during the abuse BUNN is
2
was
currently an adult residing in San Bernardino County Her date of birth is July 23
1993 She is a former foster child caught in an illegal abusive violent concealed
3
unconscionable
kids for
cash
operation from 2007 2009run by defendant
4
5
6
INTERIM CARE FOSTER FAMILY AGENCY
uncertified
LISA OATES
OATES
and
INTERIM
and defendants
NAWAB WILSON
WILSON
At all
times herein plaintiff A R suffered ongoing unrestrained terror torture corporal

8
9
10
punishment physical and mental abuse and neglect at the hands of defendants
OATES and WILSON covered up and unchecked by INTERIM
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4
At all times herein defendant INTERIM was a California Corporation
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13
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licensed and existing under the laws of California with its principal place of
business in the County of San Bernardino 10251 Trademark Street A Rancho
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Cucamonga California 91730
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5
1
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At all times herein between 1 1 06 and 1 1 13 defendants OATES and
WILSON residents of San Bernardino County defendants INTERIM defendant
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board members defendant CEO and defendants Administrators held out uncertified
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OATES and WILSON and seven uncertified facilities as certified by INTERIM in

violation ofHealth and Safety Code Section 1508
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6
At all times herein defendants INTERIM defendants board members
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25
defendant CEO defendants Administrators and defendants OATES and WILSON
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bilked hundreds of thousands of foster care dollars from the U S Dept of Health
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and
Human Services Title IV E
Federal Foster Care Funds California Dept of
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3
Social Services DSS State Foster Funds and San Bernardino County Child
Protective Services Foster Care Funds for plaintiffs on pretext that defendant
INTERIM certified defendants OATES and WILSON and defendants
seven
4
5
facilities
At all times herein defendant INTERIM defendants board members
defendant CEO and defendants Administrators knew plaintiffs foster children

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9
10
were evicted from four 4 of the seven uncertified facilities while holding said
defendants and said facilities out as certified by INTERIM in violation of Health
11
Safety Code Section 1508 placed more defendant children collected lucrative
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13
federal
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state and
county foster
care
funds perpetrating the
kids for
cash
scam
15
defendant CEO and defendants Administrators knew defendants OATES and

16
1
WILSON
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foster
and plaintiffs
children
foster
children
were
homeless for
six months
homeless
tool no action held out said homeless defendants as certified by
19
INTERIM in violation of Health and Safety Code Section 1508 placed more
20
21
22
dependent collected lucrative federal state and county foster care funds
perpetrating the
kids for
cash
scam
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26
defendant CEO and defendants Administrators knew or should have known
plaintiffs foster children suffered ongoing unrestrained relentless torture trauma
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severe mental and emotional abuse at the hands of defendants OATES and
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4
1
2
WILSON took no action held out said uncertified dangerous violent abusive
defendants as certified by INTERIM
3
10
At
all
times herein Defendant SUKHWINDER SINGH
SINGH
4
5
6
defendant Interim s Chief Financial Officer and Administrator
10251 Trademark
Street A Rancho Cucamonga California 91730 bilked hundreds of thousands of

foster care dollars from the U S Dept of Health and Human Services California
8
9
10
DDS and San Bernardino County Child Protective Services on pretext uncertified
defendants OATES and WILSON and defenadnts facilities were certified by
11
INTERIM in violation of Health and Safety Code Section 1508

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13
14
11
At
all
times herein
Defendant FREDDY WILSON
WILSON
defendant Interim s director 10251 Trademark Street A Rancho Cucamonga
15
California 91730 bilked hundreds of thousands of foster care dollars from the U S
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1
Dept of Health and Human Services California DDS and San Bernardino County
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Child Protective Services on pretext uncertified defendants OATES and WILSON
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22
and defendants facilities were certified by INTERIM in violation of Health and

Safety Code Section 1508
12
At
all
times herein Defendant AJAY MALHOTRA
MALHOTRA
23
defendant Interim s director 10251 Trademark Street A Rancho Cucamonga

24
25
26
California 91730 bilked hundreds of thousands of foster care dollars from the U S
Dept of Health and Human Services California DDS and San Bernardino County
27
Child Protective Services on pretext uncertified defendants OATES and WILSON

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5
and defendants facilities were certified by INTERIM in violation of Health and
Safety Code Section 1508
3
13
At all times herein Defendant BHUPINDER CHHUDU
4
CHH JDU
5
6
defendant Interim s director 10251 Trademark Street A Rancho
Cucamonga California 91730 bilked hundreds of thousands of foster care dollars
from the U S Dept of Health and Human Services California DDS and San
8
9
Bernardino County Child Protective Services on pretext uncertified defendants
10
OATES and WILSON and defendants facilities were certified by INTERIM in
11
violation of Health and Safety Code Section 1508

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14
13
14
At all times herein between 11 29 06 and 12 03 10 Defendant
SHANUD AZARIAH
AZARIAH
employed as defendant Interim s
15
Administrator 10251 Trademark Street A Rancho Cucamonga California 91730

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and Human Services California DDS and San Bernardino County Child Protective
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Services on pretext uncertified defendants OATES and WILSON and defendants

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facilities were certified by INTERIM in violation of Health and Safety Code Section
22
1508
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15
At all times herein between 12 03 10 and 7 22 11 Defendant JOEL
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DOMINGUEZ
DOMINGLTEZ
employed as defendant Interim s Administrator
10251 Trademark Street A Rancho Cucamonga California 91730 bilked hundreds
27
of thousands of foster care dollars from the U S Dept of Health and Human
28
6
COMPL
INT FOR DAMAGES
Services California DDS and San Bernardino County Child Protective Services on
pretext uncertified defendants OATES and WILSON and defendants facilities were
certified by INTERIM in violation of Health and Safety Code Section 1508

4
16
5
6
At all times herein between 10 18 11 and 8 30 14 Defendant
SHAHZIA R AMNIT
RAMNIT
employed by defendant as Interim s
Administrator 10251 Trademark Street A Rancho Cucamonga California 91730

8
9
10
and Human Services California DDS and San Bernardino County Child Protective
11
Services on pretext uncertified defendants OATES and WILSON and defendants

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13
facilities were certified by INTERIM in violation of Health and Safety Code Section
14
1508
15
FIRST CAUSE OF ACTION FOR NEGLIGENCE

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By All Plaintiffs Against All Defendants
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17
Plaintiffs repeat and reallege each and every allegation contained in
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paragraphs 1 16 of this Complaint and incorporate said allegations herein with the
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21
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same force and effect as if fully set forth

18
On 8 18 06 the Department sent written notification to defendants F
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WILSON MALHOTRA and CHHUDU that defendant INTERIM applied for a

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license to operate a foster family agency and named defendants as its board
members
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7
1
2
3
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The Department
s notification
further
It is important for you to
stated
understand that if approved this license will be issued in the name of the
corporation This means that the corporation will be held accountable for the care
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5
6
and supervision of all clients in care

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The Department
s notification
further
Regular board of
stated
directors meetings is essential if the board members are to ensure that the care
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facility is operating properly and in substantial compliance with licensing laws and
regulation In some instances board members may be held accountable for the
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conduct of or damages caused by the facility corporate licensee

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21
California Code of Regulations Title 22 Section 88063 imposed
mandatory statutory duties on defendant ITNERIM s directors defendants F
15
WILSON MALHOTRA
and
CHH TDU to
actively ensure accountability and
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perform
the
at a minimum
policies and procedures
following
governing the
responsibilities
operation of
establish and approve
defendant INTERIM
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approve and monitor a
budget for defendant INTERIM
access and maintain the
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level of funding necessary to cover the costs of operating defendant INTERIM

22
Title 22 Sections 80001
c 3 and 88018 d imposed mandatory
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statutory duties on defendants directors F WILSON MALHOTRA and

CHHLTDU to sign a written resolution stating the board shall operate defendant
INTERIM in full conformity with applicable licensing statutes and regulations
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8
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1
2
Title 22 Section 88035 imposed responsibility on defendants directors
F WILSON MALHOTRA and CHHLTDU for dependent children placed in
defendant INTERIM s custody

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5
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Title 22 Section 88063 a imposed mandatory statutory duties on
defendant INTERIM to account for the general supervision of defendant s facility

and certified family homes to establish policies concerning operation and to ensure
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operations comply with applicable regulations and statutes
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The U S Department of Health and Human Services under Social
11
Security Act Title IV E California Department of Social Services and San

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Bernardino Department of Social Services paid defendant INTERIM millions for
foster care for dependent children placed in defendant s custody including plaintiffs
15
26
16
be
Administrator means the person designated by the board of directors

for defendant INTERIM
to
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Regulation Title 22 section 88001 a 2
responsible
s operation
California Code of
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27
Title 22 Sections 88001
88030 b imposed mandatory statutory
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22
duties on defendants administrators AZARIAH DOMINGUEZ and R AMNIT to
sign Certificates ofApproval on defendant INTERIM s family homes
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Title 22 Section 88001 c imposed mandatory statutory duties on
defendants administrators AZARIAH DOMINGUEZ and RAMNIT to issue
Certificates of Approval on defendant INTERIM s family homes
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9
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1
2
Under Section 88001
a certified family home means a
residence certified by a licensed FFA and issued a Certificate of Approval by the
agency as meeting licensing standards a certified parent is an adult residing in the

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5
6
home certified by the FFA to provide court supervision to children placed by that
agency
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Title 22 Section 88030 b imposed mandatory statutory duties on
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defendants administrators AZARIAH DOMINGUEZ and RAMNIT to provide
each certified family home used by defendant with a Certificate of Approval
11
properly completed and signed by the administrator of his her designee a Certificate
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f Approval is not transferable and is void upon a change of location or certified
parents
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Under Section 89201 11
Completed Application
means A the
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applicant has submitted and the licensing agency has received all required material
and B the licensing agency has completed a site visit to the facility
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Under Section 89218
T he application and supporting documents
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shall
include 1 Name
of premises
and address of
if applicant is
leasing
or
the
applicant
renting
2 Name and address of owner
3 a copy of the document s that
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26
establish the applicant has control of the property to be licensed

33
Under Section 80001
an application for a Certificate of Approval
includes a Plan of Operation completed by the applicant
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10
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1
2
Under Sections 80022 and 83087 2 the Plan of Operation includes a
sketch ofthe building and the grounds including the dimensions of all areas used by
3
the clients
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6
Under Sections 80022 g and 80061 changes in the Plan of Operation
shall be submitted for licensing agency approval and shall be reported to the
7
Department
8
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10
Under Section 89218
The application shall be filed with the
licensing agency which services the geographical area in which the home is
11
located
12
37
13
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Title 22 Section 89227
imposed mandatory statutory duties on
defendants administrators AZARIAH DOMINGUEZ and RAMNIT to ensure a
15
site visit to the proposed foster family home is completed as part ofthe application
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review process and a determination that all of the requirements of Article 3 of this
chapter have been satisfied
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38
Title 22 Section 89231 a imposed mandatory statutory duties on
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21
defendants administrators AZARIAH DOMINGUEZ and RAMNIT to issue a
22
license to the applicant after an application has been completed an in home visit has
23
been
made pursuant
to Section 89227
subsection
and
upon determination
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26
that all licensing requirements set forth in Article 3 ofthis chapter have been met
39
Section 89234 imposed mandatory statutory duties on defendants
27
OATES and EILSON to provide defendant INTERIM with reasonable notice prior
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11
1
2
to any change in the location of the home as specified in Section 89361 subsection
d
3
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Under Health and Safety Code section 1503 5 a facility shall be
4
5
6
deemed an unlicensed community care facility maintained and operated to provide

non medical care
if it is unlicensed and not exempt from licensure and the facility
is held out as or represented as providing care or supervision as defined by this

8
9
chapter or the rules and regulations adopted pursuant to this chapter
10
41
Under Title 22
Sections 80001 2
89201 C and Health and Safety
11
Code
section
1503 5
a home that is held out as or represented as providing care
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13
14
and supervision
42
includes
Health
and
3 A licensed home that moves to a new location
Safety
Code 1531 5
states
child abuse
means a
15
situation
in
physical
injury
which a child suffers
from any
one or more of
the
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reason of
inflicted
intentional
upon
the
child
by
other
than
following
accidental means
neglect or malnutrition or sexual abuse
Serious
2 Harm by
3 Going without
19
necessary
and
basic
physical care
4 Willful mental injury negligent treatment or
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21
maltreatment of a child under the age of 18 by a person who is responsible for the
22
child s welfare under circumstances that indicate that the child s health or welfare is
23
24
25
harmed or threatened thereby as determined in accordance with regulations

prescribed by the Director of Social Services
26
27
28
12
43
1
2
Under Health
and
Safety
Code Sections 1531 5
3 and
necessary and basic physical care means care provided in a current and validly
licensed or administrator certified community care facility

4
44
5
6
Penal Code Section 11166 imposed mandatory statutory duties on
defendant INTEIM to report the abuse of a dependent child pursuant to Health and
Safety Code Section 1531 5 c 3 and 4 based on placement in uncertified

8
9
community care facilities in violation of Health and Safety Code Section 1508
10
45
Section 88061 b imposed mandatory statutory duties on all defendant
11
INTERIM s personnel to report the abuse of a dependent child pursuant to Health

12
13
14
and
Safety
Code Section 1531 5
3 and 4 based on placement in uncertified
community care facilities in violation of Health and Safety Code Section 1508
15
46
A child placed in an uncertified home in violation for Health and Safety
16
1
1 g
Code Section 1508 constitutes an unusual incident under Section 88061 c
4 that
threatens the physical or emotional health or safety of any child constituting child
19
abuse under
Health
and
Safety
Code Section 1531 5
4 mandating a report
20
21
22
under Penal Code Section 11166
47
Section 88061 g imposed mandatory statutory duties on defendant
23
24
25
26
INTERIM to report child abuse under Health and Safety Code Section 1531 5 c 3
4 based on placement in uncertified homes in violation of Health and Safety Codes
Section 1508
27
28
13
1
2
48
Section 88061 h imposed mandatory statutory duties on defendant
INTERIM to provide a log of family homes certified and decertified during the
month to the Department by the tenth of the following month

4
5
6
49
Section 88068 imposed mandatory statutory duties on defendant
INTERIM to complete and maintain current admission agreements with each
certified parent with whom the children were placed

8
9
10
50
Start with Section 89200 a imposed mandatory statutory duties on
defendant INTERIM to ensure compliance with all applicable law and regulation
11
51
Under Section 89201 d
Deficiency means any failure to comply
12
13
14
ith any provision of the Community Care Facilities Act commencing with Section
1500 of the Health and Safety Code and or regulations adopted by the Department
15
pursuant to the Act

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52
Under Section 89201
Serious
Deficiency means any deficiency
that presents an immediate or substantial threat to the physical health mental health
19
or safety of any child in the home

20
21
22
53
Under Section 89201 p
Provision
or
provide
means whenever
any regulation required that provision be made for or that there be provided any
23
service personnel or other requirements the caregiver shall do so directly or

24
25
26
present evidence to the licensing agency that the requirements have been met by
some other means
27
28
14
Under Section 89201 1
54
means a home that is
Licensed Home
licensed by Community Care Licensing in accordance with the standards set forth in
Article 3 of this chapter The license cannot be transferred to another person or

4
5
location
Under Section 89201
55
means a
facility
as
Unlicensed Community Care Facility
defined in Section 1503 5
of
Safety Code
the Health
10
Under Section 89201
56
Community
Care
89201 U
Unlicensed
Facility means a licensed home that moves to a new location
11
Section 89205 imposed mandatory statutory duties on defendant
57
12
13
14
TERIM not to operate establish manage conduct or maintain a foster family
home or hold out advertise or represent by any means to do so without first
15
obtaining a current valid license from the licensing agency

16
18
Under Section 89206
58
17
89201
An unlicensed facility as defined in Section
is in violation of Section 1503 5 and or 1508 ofthe Health and Safety
19
Code
20
21
22
59
Section 89206 d imposed mandatory statutory duties on defendant
INTERIM to issue an immediate civil penalty on parents for operating an illegal
23
unauthorized uncertified home pursuant to Title 22 section 89255 and Section 1547
24
25
of the Health and Safety Code
26
27
28
15
1
2
60
Section 89206
imposed mandatory statutory duties on defendant
INTERIM to notify the appropriate placement or protective service agency of an
immediate threat to clients health and safety

4
5
6
61
Health and Safety Code Section 1508 imposed mandatory statutory
duties on defendant INTERIM not to operate establish manage or maintain

uncertified homes
8
9
10
62
duties on defendants administrators AZARIAH DOMINGUEZ and RAMTIIT not
11
to operate establish manage or maintain uncertified family homes

12
13
14
63
duties on defendant CEO SINGH not to operate establish manage or maintain
15
uncertified family homes

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64
duties on defendant directors F WILSON MALHOTRA and CHHUDU not to
19
operate establish manage or maintain uncertified family homes

20
21
22
65
Section 89240 a imposed mandatory statutory duties on defendants
administrators AZARIAH DOMINGUEZ and RAMNIT to deny an application for
23
certification if it is determined the applicant is not in compliance with applicable

24
25
laws and regulations
26
27
28
16
COMPLAINT FOR DAMAGE
Under Section 89242
66
the Department shall have the authority to
suspend or revoke any license on any ofthe grounds specified in Health and Safety
Code section 1550

4
67
5
6
Under Health
and
Safety
Code
section
T he department may
1550
deny an application for or suspend or revoke any license or any administrator

certificate issued under this chapter upon any of the following grounds and in the
8
9
10
manner provided
the licensee
of
in this
the
for any
chapter
of
the
following
grounds
rules and regulations promulgated under
this
a Violation by
chapter
11
Aiding abetting or permitting the violation of this chapter or of the rules and
12
13
14
regulations promulgated under
this
c Conduct which is inimical to the
chapter
health morals welfare or safety of wither an individual in or receiving services
15
from
the
16
1
facility
or
the
people of
the State
of
California
Engaging in acts of
malfeasance concerning the operation of a facility including but not limited to
1g
fraudulent appropriation for personal gain of facility moneys or property or
19
willful or negligent failure to provide services

20
68
21
22
Under Section 89361
each caregiver shall furnish such reports to the
licensing approval agency and the child s authorized representative required by the
23
Department
including but not
limited to the
following
3 Any unusual incident or
24
25
26
child absence that threatens the physical or emotional health or safety of any child
4
Any
suspected physical or psychological
abuse of
any
27
28
17
child
d When there is a
1
2
change in the location of the home the caregiver shall notify the licensing approval
agency 30 days prior to the move or as soon as the information is available
Under Section 89372 each child shall have personal rights which
69
4
5
6
include but
are not
limited to the
following
To be accorded safe healthful and
comfortable home accommodations furnishings and equipment appropriate to

his her
needs
2 To be treated with respect and to be fee from physical sexual
8
9
10
4 To be free from corporal or unusual punishment
emotional or other abuse
infliction of pain humiliation intimidation ridicule coercion threat mental abuse
11
or other actions of a punitive nature including but not limited to interference with
12
13
14
the daily living function of eating sleeping or toileting or withholding of shelter

clothing
or aids of physical
5 To receive adequate and healthy food
functioning
15
6 To be provided adequate clothing and personal items in accordance with Section

16
1
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89372 C
To
B To possess and use his her own personal items including toiletries
receive
necessary
medical
dental
vision
and mental
health
10
services
To
19
have social contacts with people outside of the foster care system such as teachers
20
21
22
church members
To
contact
family
mentors and
members
friends in
accordance with
unless prohibited
by
Section 89372
court order
16
11
To make and
23
receive confidential phone calls and send and receive unopened mail unless
24
25
26
prohibited
by
court order
20 To attend school and participate in extracurricular
cultural and personal enrichment activities consistent with the child s age and
27
28
18
1
2
developmental level that is
consistent with state
law
23 To be accorded dignity in
his her personal relationships with other persons in the home
3
70
Section 89376 a imposed mandatory statutory duties on certified
4
5
6
parents to provide or ensure at least three nutritious meals per day

71
parents to ensure foster children have their meals with foster family members in a
8
9
10
family setting
72
11
parents to provide care and supervision as necessary to meet each child s needs
12
13
14
parents to provide opportunity for and encourage participation in group sports
15
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leisure time family special school and daily living skills activities
74
On 12 01 06 the Department of Social Services Department issued
defendant INTERIM a license to operate a Foster Family Agency FFA to certify
19
foster parents and their homes as meeting all licensing requirements to provide
20
21
22
foster care for dependent children entrusted to defendant INTERIM s custody

75
Prior to the issuance of defendant INTERIM s FFA license to certify
23
family homes defendants issued defendants OATES and WILSON a Certificate of

24
25
26
Approval on 11 16 06
76
OATES and WILSON lived with foster children INTERIM placed with
27
them in
28
Facility
1 located at 13945 Topmast Drive Helendale CA 92342

19
2
3
In or about 6 07 defendants OATES and WILSON moved to Facility
77
2 on 12547 Dulce Street Victorville Dulce with the dependent foster children
under their care The Certificate of Approval Defendant INTERIM issued on 11 16
4
5
6
06 was void by the operation of law upon change of location under Title 22 Section
88030 e and Health and Safety Code Sections 1524 1503 5
On or about 6 07 defendant INTERIM placed plaintiff BUNN DOB
78
8
9
10
July 23 1993 then 13 years old with defendants OATES and WILSON in Facility
2 on 12547 Dulce Street Victorville
11
Defendant INTERIM knew or should have known defendants OATES
79
12
13
and WILSON violated plaintiff BUNN s personal rights enumerated in Sections
14
g9372 1
10
11
16
20
23
in Facility
15
by but not
Dulce
16
1
1g
limited to
forcing them to scrub walls floors vacuum and
sweep floors lift rugs move and replace furniture clean toilets kitchen and
bathrooms nightly in violation of Section 89378 suffering extreme pain fatigue and
19
severe
sleep deprivation
2 not allowing them to eat the same food as defendants
20
21
OATES
22
the
and
same
WILON in
table
as
violation of
Section 89376
defendants OATES
and
WILON in
3 not allowing them to eat at

violation of
Section 89376
23
24
25
26
depriving them of adequate food in violation of Section 89276 causing a constant

state of
hunger
5 prohibiting them from opening the refrigerator or entering the
food pantry in violation
of
Section 89376
6 barring them from court ordered
27
28
20
1
2
contact with relatives in violation of Section 89379 and 7 forcing them to wear ill
fitting shoes causing permanent injuries
Defendants OATES and WILSON breached mandatory statutory duties
80
4
5
imposed by Health and Safety Code Section 1534 and Title 22 Sections 89234 d by
failing to report a change in location to defendant INTERIM
81
8
9
10
imposed by Section 89218 c by failing to submit an application for approval on

Facility
Dulce
11
82
12
13
14
imposed by Health and Safety Code Section 1534 and Title 22 Sections 89234 d
and
89361 d
by failing to
obtain a
Certificate
of
Approval
on
Facility
Dulce
15
83
Defendant INTERIM provided no supervision over defendant OATES
16
1
1g
and
WILSON
no site visit
to
Facility
2 Dulce
little or no contact with plaintiffs
putting plaintiffs at risk of foreseeable harm when they knew or should have
19
known plaintiffs suffered ongoing abuse and neglect

20
21
22
84
could not
Defendant INTERIM s administrator defendant AZARIAH di not and

issue
Certificate
of
Approval
on
Facility 2 Dulce given defendants
23
24
25
OATES and WILSON s violations of mandatory statutory duties as alleged in

paragraphs 80 82
26
27
28
21
COMPLAINT FOR DAM
GES
Facility 2 Dulce was not a certified family home pursuant to
85
Sections 88001
88005 89201 1
89201
89201
C 3
89206 a and Health and Safety Code sections 1503 5 and 1508
4
Defendants OATES and WILSON were not certified parents who met
86
licensing requirements
88005
89201 1
in
uncertified
89201
Facility 2 pursuant to Sections 88001 c 4
89201
C 3
89206
Health and Safety
8
9
Code sections 1503 5 and 1508 putting plaintiffs at risk of foreseeable harm
10
Defendant INTERIM breach mandatory statutory duties imposed by
g 7
11
Sections 88005
88030 b
80001
80005
89201
89205 89206
89231 a
12
13
14
Health and Safety Code Sections 1503 5 and 1508 by operating uncertified Facility
2 Dulce with no supervision over and little if any contact with plaintiffs putting
15
plaintiffs at risk of foreseeable harm when they knew or should have known
16
1
plaintiffs suffered ongoing abuse and neglect
1g
Defendants directors F WILSON MALHOTRA and CHHUDU
88
19
breached mandatory statutory duties imposed by Health and Safety Code Section
20
Facility
Dulce
with no supervision over and
21
1508
22
little if any contact with plaintiffs putting plaintiffs at risk of foreseeable harm
by
operating
uncertified
23
24
25
26
when they knew or should have known plaintiffs suffered ongoing abuse and
neglect
89
Defendant administrator AZARIAH breached mandatory statutory
27
28
duties imposed by Health and Safety Code Section 1508 by operating uncertified
22
1
2
Facility 2 Dulce with no supervision and little if any contact with plaintiffs
putting plaintiffs at risk of foreseeable harm when it knew or should have known
3
4
Defendant CEO SINGH breached mandatory statutory duties imposed
90
by Health
and
Safety
Code Section 1508
by
operating
uncertified
Facility
Dulce with no supervision and little if any contact with plaintiffs putting
8
9
10
plaintiffs at risk of foreseeable harm when it knew or should have known plaintiffs
suffered ongoing abuse and neglect
11
Defendant INTERIM breached mandatory statutory duties imposed by
91
12
13
14
89255 and Health and Safety Code Section 1547 by failing to
Sections 89206 d
issue an immediate civil penalty against defendants OATES and WILSON on
15
uncertified
Facility
2 Dulce
16
92
1
1g
Section 86206
by failing to notify the CPS placement agency that plaintiffs were
19
in
uncertified
Facility 2 in violation of Health and Safety Code Sections 1505 and
20
21
1508 with no supervision and little if any contact with plaintiffs putting plaintiffs
22
at risk of foreseeable harm when it knew or should have known plaintiffs suffered
23
ongoing abuse and neglect
24
93
25
26
by
Defendant INTERIM s breach ofmandatory statutory duties imposed
Section 86206
by failing to notify CPS that defendants OATES and WILSON
27
moved
to
an uncertified
Facility 2 caused plaintiffs to remain in uncertified
28
23
Facility 2 in violation of Health and Safety Code Section 1508 as opposed to
immediate removal mandated by law with no supervision and little if any contact
with plaintiffs putting plaintiffs at risk of foreseeable harm when it knew or should
4
5
6
have known plaintiffs suffered ongoing abuse and neglect
Defendant INTERIM s breach of mandatory statutory duties imposed
94
by Section 86206 j constituted inimical conduct that caused plaintiffs to remain in

8
9
10
uncertified
Facility 2 in violation of Health and Safety Code Section 1508 as
opposed to immediate removal as mandated by law with no supervision and little
11
if any contact with plaintiffs putting plaintiffs at risk of foreseeable harm when it
12
13
ew or should have known plaintiffs suffered ongoing abuse and neglect
14
95
15
Section 89205 holding uncertified defendants OATES and WILSON and uncertified
16
1
1g
Facility 2 out as certified to CPS causing plaintiffs to remain in uncertified Facility
2 in violation of Health and Safety Code section 1508 as opposed to immediate
19
removal mandated by law with no supervision and little if any contact with
20
21
22
plaintiffs putting plaintiffs at risk of foreseeable harm when it knew or should have
23
96
24
25
26
by Section 88061 c holding out uncertified defendants OATES and WILSON and
uncertified
Facility 2 Dulce as certified to CPS constituted a serious deficiency
27
under
Section 89201
causing
plaintiffs
to
remain
28
24
C
MPLAINT FOR DAMAGES
in uncertified
Facility 2 in
1
2
violation of Health and Safety Code Section 1508 as opposed to immediate removal
mandated by law with no supervision and little if any contact with plaintiffs
4
5
97
by
Section 89206
for failure to report defendants OATES and WILSON and
8
9
10
Facility
2 Dulce were uncertified in violation of Health and Safety Code Section
1508 as opposed to immediate removal mandated by law with no supervision and
11
12
13
14
hen it knew or should have known plaintiffs suffered ongoing abuse and neglect
98
Plaintiffs
placement
in
uncertified
Facility 2 Dulce in violation of
15
Health and Safety Code Section 1508 was child abuse under Health and Safety Code
16
l
1g
Section 1531 5 c 3 and 4 and Welfare and Institutions Code Section 300 b
reportable under Penal Code Section 11166 mandating plaintiffs immediate
19
removal
20
21
22
99
Penal Code Section 11166 imposed mandatory statutory duties on
defendant INTERIM to
report plaintiffs
placement
in uncertified
Facility
23
24
25
26
Dulce in violation of Health and Safety Code Section 1508 mandating plaintiffs
immediate removal
100
27
28
by Penal Code Section 1166 for failure to report plaintiffs placement in uncertified
25
Dulce
to
remain
in
uncertified
Facility 2 in violation
Facility
of Health and Safety Code Section 1508 as opposed to immediate removal
causing
plaintiffs
4
5
101
8
9
10
by Penal
Code Section 11166 for failure to
uncertified was a
serious
deficiency
report
Facility
under section
89201
2 Dulce
was
caused plaintiffs to
11
remain
in
uncertified
Facility 2 in violation of Health and Safety Code Section
12
13
14
15
when it knew or should have known plaintiffs suffered ongoing abuse and neglect
16
1
ig
102
by Penal Code Section 1166 and Title 22 Sections 89205 86206 j 88661 c
19
20
21
22
among others with no supervision and little if any contact aided abetted and
permitted
defendants OATES
and
WILSON
s operation of uncertified
Facility
Dulce in violation of Health and Safety Code Section 1508 as opposed to
23
plaintiffs immediate removal mandated by law putting plaintiffs at risk of

24
25
26
foreseeable harm when they knew or should have known plaintiffs suffered
27
28
26
103
1
2
3
Defendant INTERIM engaged in acts of financial malfeasance based on
payments from the U S Department of Health and Human Services California

Department of Social Services and San Bernardino Department of Social Services
4
5
6
for
plaintiffs
placement
in
uncertified
by Facility 2 in violation of Health and
Safety Code Section 1508 unbeknownst to said government fudnign agencies as

opposed to immediate removal mandated by law with no supervision and little if
8
9
10
any contact with plaintiffs putting plaintiffs at risk of foreseeable harm when it
11
104
12
by
Section 88063
2 by approving
13
breached mandatory statutory duties imposed
14
and monitoring a budget based on payments from the U S Department of Health
15
and Human Services California Department of Social Services and San Bernardino
16
1
1g
Department
of
Social Services for plaintiffs
placement
in
uncertified
Facility
2 in
violation of Health and Safety Code Section 1508 unbeknownst to said government
19
funding agencies with no supervision and little if any contact with plaintiffs
20
21
22
23
105
Defendants directors F WILSON MALHOTRA and CHI UDU
24
25
breached mandatory statutory duties imposed by Section 88063 c 3 by approving
26
and monitoring a budget to cover operation costs based on payments from the U S
27
Department of Health and Human Services California Department of Social

28
27
1
2
Services and San Bernardino Department of Social Services for plaintiffs

placement
in
uncertified
Facility 2 in violation ofHealth and Safety Code Section
1508 unbeknownst to said government funding agencies with no supervision and

4
5
little ifany contact with plaintiffs putting plaintiffs at risk of foreseeable harm
106
8
9
10
11
by
Section 88063
3 by accessing
and maintaining defendant INTERIM s level of funding to cover operation costs

based on payments from the U S Department of Health and Human Services
12
13
California Department of Social Services and San Bernardino Department of Social
14
Services for
plaintiffs
placement
in uncertified
Facility 2 in violation of Health
15
16
and Safety Code Section 1508 unbeknownst to said government funding agencies
with no supervision and little if any contact with plaintiffs putting plaintiffs at risk
1g
of foreseeable harm when it knew or should have known plaintiffs suffered ongoing
19
abuse and neglect
20
21
22
107
by
Section 80000 1
3 nad 88018 by
23
operating
uncertified
Facility 2 Dulce in violation of Health and Safety Code
24
25
26
Section 1508 unbeknownst to said government funding agencies with no

supervision and little if any contact with plaintiffs putting plaintiffs at risk of
27
28
28
1
2
foreseeable harm when it knew or should have known plaintiffs suffered ongoing
abuse and neglect
Defendant SINGH engaged in acts of financial malfeasance based on
108
4
5
6
payments form the U S Department of Health and Human Services California

for
plaintiffs
placement
in
uncertified
Facility 2 in violation of Health and Safety
8
9
10
11
Code Section 1508 unbeknownst to said government funding agencies with no

foreseeable harm as opposed to immediate removal mandated by law when it knew
12
13
14
or should have known plaintiffs suffered ongoing abuse and neglect
Defendants OATES and WILSON engaged in conduct inimical to
109
15
plaintiffs
health
morals
welfare
and
safety
by operating uncertified Facility
16
17
1g
Dulce in violation of Health and Safety Code Section 1508 unbeknownst to above
alleged governmental funding agencies
19
Defendants OATES and WILSON engaged in acts of financial
110
20
21
22
malfeasance
on pretext
based
on payments
defendants OATES
for
and
plaintiffs
WILSON
placement
and
in uncertified Facility
Facility
Dulce
were certified
23
111
Defendant INTERIM knew or should have known and defendant
24
25
26
WILSON observed defendant OATES and plaintiffs to either fight over foster
children or for plaintiffs to be beaten tortured by defendant forced to steal food or
27
28
go hungry forced to walk and run in competitions of her design while carrying large
29
loads took away their personal belongings forced plaintiffs to ask defendant for a
glass of water toilet paper and toothpaste among other things demeaned and
cursed plaintiffs forced plaintiffs to clean defendant s house several hours each
4
5
6
night to wear used clothes to wear clothes that were too small causing shame and
embarrassment beat plaintiffs with belts shows and anything else defendant could
find effused to allow plaintiffs to wash clothes in defendant s machine in Facility
8
9
10
2 forced plaintiffs to walk or ride a bike carrying plastic bags of clothes miles to
and from the Laundromat in all kinds of weather
11
112
In or about 9 07 defendants OATES WILSON and plaintiffBLJNN
12
13
14
moved
to location to
113
facility
Pool
15
16
1
1g

114
19
20
21
22

Facility
115
Pool
23
24
25
26
imposed by Health and Safety Code Section 1534 and Title 22 Sections 89234 d
and 89361 d by failing to obtain a Certificate of Approval from defendant
AZARIAH
on
Facility
Pool
27
28
30
COMPLAINT FOR D
MAGES
1
2
3
116
Defendant INTERIM s administrator defendant AZARIAH did not
and could not
issue
Certificate
of
Approval
on
Facility 3 Pool under Section
89240 a given defendants OATES and WILSON s licensing violations defendant
4
5
6
INTERIM made no site visit provided no supervision little or no contact with
plaintiffs putting plaintiffs at risk offoreseeable harm as opposed to immediate

removal mandated by law when they knew or should have known plaintiffs
8
9
10

117
Facility 3 Pool was not a certified family home pursuant to Title 22
11
Sections 88001
88005
89201 1
89201
89201
12
13
g9206 a and Health and Safety Code sections 1503 5 and 1508 putting plaintiffs at
14
a foreseeable risk of harm
15
118
Defendants OATES and WILSON were not certified parents who met
16
1
licensing requirements in uncertified Facility 3 pursuant to Sections 88001 c 4
1g
88005 89201 1
89201
89201
89206
Health and Safety
19
Code sections 1503 5 and 1508 while defendant INTERIM provided no

20
21
supervision little is any contact putting plaintiffs at risk of foreseeable harm as
22
opposed to immediate removal mandated by law when it knew or should have
23

24
25
26
119
Defendant INTERIM breach mandatory statutory duties imposed by
Sections 88005
88030 b
80001
80005 89201
89205 89206
89231 a
27
28
Health and Safety Code Sections 1503 5 and 1508 by operating uncertified Facility
31
1
2
3 Pool with no supervision over and little if any contact with plaintiffs putting
plaintiffs at risk of foreseeable harm when they knew or should have known

4
120
5
6
breached mandatory statutory duties imposed by Health and Safety Code Section
7
1508
by
operating
uncertified
Facility 3 Pool with no supervision over and little
8
9
10
if any contact with plaintiffs putting plaintiffs at risk of foreseeable harm when
they knew or should have known plaintiffs suffered ongoing abuse and neglect
11
121
Defendant administrator AZARIAH breached mandatory statutory
12
13
duties imposed by Health and Safety Code Section 1508 by operating uncertified
14
Facility 3 Pool with no supervision and little if any contact with plaintiffs
15
16
1
1g

122
Defendant CEO SINGH breached mandatory statutory duties imposed
19
20
by Health
and
Safety
Code Section 1508
by
operating
uncertified
Facility
Pool
21
22
23
abuse and neglect
24
25
26
123
Sections 89206 d
89255 and Health and Safety Code Section 1547 by failing to
27
28
32
COMPLAINT FOR DAM
GES
1
2
issue an immediate civil penalty against defendants OATES and WILSON on

uncertified
Facility
3 Pool
124
4
5
Section 86206 j by failing to notify the CPS placement agency that plaintiffs were
in
uncertified
Facility 3 in violation ofHealth and Safety Code Sections 1505 and
1508 with no supervision and little if any contact with plaintiffs putting plaintiffs
8
9
10
at risk of foreseeable harm when it knew or should have known plaintiffs suffered
11
125
12
Section 86206
13
by
14
moved
to
by failing to notify CPS that defendants OATES and WILSON
an uncertified
Facility
3 caused plaintiffs to remain in uncertified
15
Facility 3 in violation ofHealth and Safety Code Section 1508 as opposed to

16
1
immediate removal mandated by law with no supervision and little if any contact
1g
with plaintiffs putting plaintiffs at risk of foreseeable harm when it knew or should
19
have known plaintiffs suffered ongoing abuse and neglect

20
126
21
22
by
Section 86206
constituted inimical conduct that caused plaintiffs to remain in
23
uncertified
Facility 3 in violation ofHealth and Safety Code Section 1508 as
24
25
26
opposed to immediate removal as mandated by law with no supervision and little
if any contact with plaintiffs putting plaintiffs at risk of foreseeable harm when it
27
knew or should have known plaintiffs suffered ongoing abuse and neglect
28
33
127
1
2
3
Section 89205 holding uncertified defendants OATES and WILSON and uncertified
Facility 3 out as certified to CPS causing plaintiffs to remain in uncertified Facility
4
5
6
7
3 in violation of Health and Safety Code section 1508 as opposed to immediate

removal mandated by law with no supervision and little if any contact with
plaintiffs putting plaintiffs at risk of foreseeable harm when it knew or should have
8
9
10
128
11
by Section 88061 c holding out uncertified defendants OATES and WILSON and
12
13
14
uncertified
under
Facility 3 Pool as certified to CPS constituted a serious deficiency
Section 89201
causing
plaintiffs
to
remain
in
uncertified
Facility
3 in
15
violation of Health and Safety Code Section 1508 as opposed to immediate removal
16
1
1g
19

20
129
21
22
by
Section 89206
for failure to report defendants OATES and WILSON and
23
24
Facility 3 Pool were uncertified in violation ofHealth and Safety Code Section
25
26
27
28
34
2
3
Plaintiffs
130
placement
in
uncertified
Facility 3 Pool in violation of
Health and Safety Code Section 1508 was child abuse under Health and Safety Code
Section 1531 5 c 3 and 4 and Welfare and Institutions Code Section 300 b
4
5
6
reportable under Penal Code Section 11166 mandating plaintiffs immediate

removal
131
8
9
10
Penal Code Section 11166 by failing to report plaintiffs placement in uncertified

Facility 3 Pool in violation of Health and Safety Code Section 1508 causing
11
plaintiffs
to
remain
in uncertified facility
3 with no supervision and little if any
12
13
contact putting plaintiffs at risk of foreseeable harm as opposed to immediate
14
removal mandated by law when it knew or should have known that plaintiffs
15

16
132
1
1g
by Penal
Code Section 11166 for failure to
report
Facility
19
was a
serious
deficiency
under section
89201
Pool was uncertified
caused plaintiffs to remain in
20
Facility 3 in violation of Health and Safety Code Section 1508 as
21
uncertified
22
23
24
25
26
133
27
28
by Penal Code Section 11166 and Title 22 Sections 89205 86206 j 88661 c
35
1
2
among others with no supervision and little if any contact aided abetted and
permitted
defendants OATES
and
WILSON
s operation of uncertified
Facility
Pool in violation of Health and Safety Code Section 1508 as opposed to plaintiffs
4
5
immediate removal mandated by law putting plaintiffs at risk of foreseeable harm
when they knew or should have known plaintiffs suffered ongoing abuse and
7
neglect
8
134
9
10
11

12
13
14
for
plaintiffs
placement
in
uncertified
by Facility
3 in violation of Health and
Safety Code Section 1508 unbeknownst to said government funding agencies as
15

16
1
1g
19
135
20
21
22
by
Section 88063
2 by approving
23
24
25
26
Department
of
Social Services for
plaintiffs
placement
27
28
3 in
36
136
4
5
6
Section 88063
by
3 by approving

8
9
10

placement
in
uncertified
11

12
13
14
When it knew or should have known plaintiffs suffered ongoing abuse and neglect
15
137
16
1
1g
by
Section 88063
3 by accessing
19

20
21
22

Services for
plaintiffs
placement
in
uncertified
23
24
25
26
27
abuse and neglect
28
37
Defendants directors F WILSON MALHOTRA and CHHLTDU
138
3
operating
uncertified
by
Section 80000 1
3 and 88018 by
Facility 3 Pool in violation of Health and Safety Code
4
5
8
9
abuse and neglect
10
Defendant SINGH engaged in acts of financial malfeasance based on
139
11
payments form the U S Department of Health and Human Services California

12
13
14

for
plaintiffs
placement
in uncertified
Facility
3 in violation of Health and Safety
15

16
1
1g
19

20
21
22
140
plaintiffs

health
morals
welfare
and
safety
23
Dulce in violation of Health and Safety Code Section 1508 unbeknownst to above
24
25
alleged governmental funding agencies
26
27
28
38
1
2
141
malfeasance
based
on payments
for
3
on pretext
defendants OATES
and
placement
plaintiffs
WILSON
and
in
Facility
uncertified
Pool
Facility
were certified
4
5
6
In or about 11 20 07 defendants OATES WILSON and plaintiff
142
BLTNN
moved
to
Facility 4 on 14594 Woodworth Way Victorville California
143
8
9
10
11
144
12
13
14

Facility
4 Woodworth
15
The identical factual
145
scenario
in
76 111 with regard to uncertified
16
17
1g
Facility
Dulce
and
112 141
to
uncertified
repeated with regard
with regard
Facility
to
uncertified
4 Woodworth
Facility 3 Pool
Defendant INTERIM s
19
administrator defendant AZARIAH did not and could not issue a Certificate of
20
Facility 4 Woodworth under Section 89240 a given defendants
21
Approval
22
OATES and WILSON were not in compliance with licensing regulations defendant
on
23
INTERIM made no site visit provided no supervision little if any contact putting
24
25
26
plaintiffs at a risk of foreseeable harm as opposed to immediate removal mandated
by law knowing or should know plaintiffs suffered ongoing abuse and neglect
27
28
39
146
1
2
3

4
5
6
for
plaintiffs
placement
in
uncertified
by Facility
4 in violation of Health and
Safety Code Section 1508 unbeknownst to said government funding agencies as

8
9
10
11
147
Defendant SINGH continued to engage in acts of financial malfeasance
12
13
14
based on payments form the U S Department of Health and Human Services
15
Services for
plaintiffs
placement
in
uncertified
16
17
1g
19
of foreseeable harm as opposed to immediate removal mandated by law when it

20
21
22
148
Defendants directors F WILSON MALHOTR A and CHHUDU
23
by
Section 88063
2 by approving
24
25
26
27
Department
of
Social Services for
plaintiffs
placement
28
40
in uncertified
Facility 4 in
1
2
3
4
5
6

149

8
9
10
11
12
13
14
Placement
in
uncertified
15
16
1
1g
150
19
by
Section 88063
3 by accessing
20
21
22
23

24
in
25
Services for
26
plaintiffs
placement
uncertified
27
28
41
1
2
abuse and neglect
151
4
5
6
operating
uncertified
by
Section 80000 1
3 and 88018 by
Facility 4 Woodworth in violation of Health and Safety

8
9
10
11
abuse and neglect
12
13
14
152
health
plaintiffs
morals
welfare
and
safety
by
operating
uncertified
Facility
15
woodworth in violation of Health and Safety Code Section 1508 unbeknownst to

16
1
1g
above alleged governmental funding agencies

153
19
malfeasance
based
on payments
for
plaintiffs
placement
in
uncertified
Facility
20
21
22
on pretext
defendants OATES
and
WILSON
and
Facility
4 Woodworth
were
certified
23
154
On 11 11 07 unlawful detainer Case No UDVS 701833 was filed
24
25
26
against
Facility
defendants OATES
and
WILSON for
nonpayment of rent
13945 Topmast Drive Helendale California 92342
27
28
42
3 534 96 on
On 11 11 07 plaintiffs and defendants OATES and WILSON resided in
155
uncertified
3
156
facility
4 Woodworth
On 12 04 07 defendants OATES and WILSON were evicted from
4
5
Facility
1 by court order Case No UDVS701833
157
Defendants OATES
and
WILSON
s eviction
from
Facility
1 while
7
also
residing in
uncertified
Facility
4 Woodworth
was an unusual incident
8
9
reportable under Section 88061
10
158
Defendants INTERIM breached mandatory statutory duties imposed by
11
Section 88061 by failing to report defendants OATES and WILSON s eviction from
12
13
Facility
14
1 on 12 04 07
159
On 2 1 08 unlawful detainer Case No UDVS800320 was filed against
15
defendants OATES
WILSON for
and
nonpayment of rent
4 870 00
on uncertified
16
1
Facility
1g
160
Woodworth
On 2 20 08 defendants OATES WILSON and plaintiffs were evicted
19
from
uncertified
Facility 4 Woodworth Case No UDVS800320 for nonpayment
20
21
22
of rent
4 870 00 unbeknownst to the alleged governmental agencies due to
financial malfeasance of defendants INTERIM defendant directors F WILSON
23
MALHOTRA CHHUDU defendant CEO SINGH defendant administrator

24
25
26
AZARIAH and defendants OATES and WILSON

161
Plaintiffs
eviction
from
uncertified
Facility 4 Woodworth for
27
nonpayment of rent was child abuse under Health and Safety Code Section
28
43
1
2
1531 5
4 and Welfare and Institutions Code Section 300 b reportable under
Penal Code Section 11166
3
162
4
5
6
Penal Code Section 11166
by failing to report
plaintiffs
eviction
from
Facility
Woodworth
7
163
8
9
10
Penal Code Section 11166 by failing to report plaintiffs placement in uncertified

Facility 4 Woodworth in violation of Health and Safety Code Section 1508
11
causing
plaintiffs
to
remain
in
uncertified
Facility 4 with no supervision and little
12
13
14
if any contact putting plaintiffs at risk of foreseeable harm as opposed to immediate

removal mandated by law when it knew or should have known that plaintiffs
15
16
164
1
1g
Plaintiffs and defendants eviction from unauthorized uncertified
Facility 4 Woodworth due to financial malfeasance of defendants INTERIM
19
defendant directors F WILSON MALHOTRA CHHUDU defendant CEO

20
21
22
SINGH defendant administrator AZARIAH and defendants OATES and WILSON
constituted an unusual incident under Section 88061 4 and a serious deficiency
23
under
Section 89201
24
25
26
165
by Section 88061 4 by failing to report to the Department that plaintiffs were
27
evicted
28
from
uncertified
Facility
4 Woodworth
44
166
by
Section 88061
by failing
to
report plaintiffs
3
Woodworth
was a
serious
deficiency
under
eviction
from
Section 89201
uncertified
Facility
that caused
4
5
6
plaintiffs to remain in the custody ofuncertified defendants OATES and WILSON

in violation ofHealth and Safety Code section 1508 and to remain in uncertified
Facility 4 also in violation of Health and Safety Code Section 1508 with no
8
9
10
11

12
14
On 3 1 08 plaintiff BUNN and defendants OATES and WILSON
167
13
moved
to
Facility 5 on 13547 Silversand Street Victorville
15
168
16
17
1g
19
169
20
21
22

Facility 5 Silversand
23
170
scenario
in
24
25
26
Facility
158
112 141
Dulce
with regard
to
uncertified
with regard
to
uncertified
Facility
Pool
142
Facility 4 Woodworth repeated with regard to
27
uncertified
Facility
Silversand
Defendant INTERIM s administrator defendant
28
45
1
2
AZARIAH did
not and could not
issue
Certificate
of
Approval
on
Facility
Silversand under Section 89240 a given defendants OATES and WILSON were
not in compliance with licensing regulations defendant INTERIM made no site

4
5
visit provided no supervision little if any contact putting plaintiffs at a risk of
foreseeable harm as opposed to immediate removal mandated by law knowing or

should know plaintiffs suffered ongoing abuse and neglect
8
171
9
10
Defendant INTERIM continued to engage in acts of financial
malfeasance based on payments from the U S Department of Health and Human
11
Services California Department of Social Services and San Bernardino Department

12
Social Services for plaintiffs
placement
in
uncertified
by Facility 5 in violation
13
of
14
ofHealth and Safety Code Section 1508 unbeknownst to said government funding
15
agencies as opposed to immediate removal mandated by law with no supervision

16
1
and little if any contact with plaintiffs putting plaintiffs at risk of foreseeable
1g
harm when it knew or should have known plaintiffs suffered ongoing abuse and
19
neglect
20
21
22
172
based on payments form the U S Department ofHealth and Human Services
23

24
in
25
Services for
26
plaintiffs
placement
uncertified
27
28
46
1
2

173
4
5
6

8
9
10
Department
of
Social Services for
plaintiffs
placement
in
uncertified
Facility
5 in
11
12
13
14
Putting plaintiffs at risk of foreseeable harm when it knew or should have known
15
174
16
by
Section 88063
3 by approving
1g
19

20
21
22

placement
in
uncertified
23

24
25
26
27
28
47
1
2
175
by
Section 88063
3 by accessing

4
5
6
7
Services for
plaintiffs
placement
in
uncertified
Facility
5 in violation of Health
8
9
10
With no supervision and little if any contact with plaintiffs putting plaintiffs at risk
11
12
13
14
abuse and neglect
176
15
by
Section 80000 1
3 and 88018 by
16
uncertified
Facility 5 Silversand in violation of Health and Safety Code
operating
1g
19
20
21
22
abuse and neglect
23
177
24
25
26
plaintiffs
health
morals
welfare
and
safety
Silversand in violation of Health and Safety Code Section 1508 unbeknownst to
27
28

48
178
malfeasance
based
on payments
for
plaintiffs
placement
in
3
on pretext
defendants OATES
and
WILSON
and
Facility
uncertified
Facility
Silversand
were
4
5
certified
179
from
uncertified
Facility 5 Silversand for nonpayment of rent for six months
8
9
10
8 400 00 Case No UDVS902368
180
San Bernardino Sheriffs locked plaintiffs and defendants OATES and
11
WILSON
our of uncertified
Facility 5 Silversand exercising a Writ of Possession
12
13
14
Permitting plaintiffs five minutes to retrieve few if any personal belongings carried
away in plastic bags
15
181
Defendants OATES WILSON and dependent foster children were
16
1
1g
homeless for five months from on or about 8 25 09 to 1 1 10

182
Defendants OATES WILSON and plaintiffs eviction from uncertified
19
20
21
22
Facility 5 followed by five months ofhomelessness was due to financial

malfeasance of all defendants
183
Plaintiffs
eviction
from
uncertified
Facility 5 for nonpayment and
23
homelessness for five months was child abuse under Health and Safety Code
24
25
26
Section 1531 5 c and Welfare and Institutions Code Section 300 b reportable
under Penal Code Section 11166
27
28
49
COMPLAINT FOR DAMA
ES
2
3
184
Penal Code Section 11166 by failing to report plaintiffs eviction from uncertified
Facility 5 and homelessness which caused plaintiffs to remain homeless in the
4
5
custody of homeless uncertified defendants OATES and WILSON with no
supervision and little if any contact putting plaintiffs at risk of foreseeable harm as
opposed to immediate removal mandated by law knowing or should know
8
9
10
185
11
by Penal Code Section 11166 by failing to report plaintiffs eviction from

12
13
14
uncertified
g9201
Facility
and
homelessness
were
serious deficiencies
under Section
causing plaintiffs to remain homeless in the custody of homeless
15
uncertified defendants OATES and WILSON with no supervision and little if any
16
1
1g
contact putting plaintiffs at risk offoreseeable harm as opposed to immediate

removal mandated by law when it knew or should have known plaintiffs suffered
19
20
21
22
186
uncertified
Plaintiffs and defendants OATES and WILSON s eviction from
Facility 5 and homelessness was due to the financial malfeasance of
23
defendants INTERIM defendant directors F WILSON MALHOTRA and

24
25
CHHUDU defendant CEO SINGH defendant AZARIAH and defendants OATES
26
and WILSON constituted an unusual incident under Section 88061 4 and a serious
27
28
deficiency under Section
89201
50
COMPLAINT FOR D
MAGES
187
1
2
3
Section 88061 4
by failing to report the
eviction
from
uncertified
home
5 and
homelessness and the no supervision and little if any contact causing foster
4
5
6
children to remain homeless with uncertified homeless defendants OATES and
WILSON in violation ofHealth and Safety Code Section 1508 unbeknownst to said
government funding agencies as opposed to immediate removal mandated by law

8
9
10
188
11
by Section 88061 by failure to report plaintiffs eviction and the homelessness of

12
13
14
foster
children was a
serious
deficiency
under
Section 89201
that caused
foster children to remain homeless with uncertified homeless defendants OATES
15
and WILSON in violation of Health and Safety Code Section 1508 with no
16
1
supervision and little if any contact putting plaintiffs at risk of foreseeable harm as
1g
opposed to immediate removal mandated by law when it knew or should have
19

20
189
21
22
by
Section 89206
by failing to notify CPS ofplaintiffs eviction and the
23
homelessness
of
foster
children constituted a
serious
deficiency under Section
24
1 that caused plaintiffs to remain homeless in the custody of uncertified
25
89201
26
homeless defendants OATES and WILSON in violation of Health and Safety Code
27
28
Section 1508 with no supervision and little if any contact putting plaintiffs at risk
51
1
2

At some point between defendant OATES and WILSON moved from
190
4
5
6 plaintiff BUNN was transferred to another foster home This was
Facility
following two successful attempts at running away that went unreported by OATES
and
WILSON and defendant INTERIM

8
10
On 1 1 lOdefendants OATES
191
and
WILSON
moved
to
Facility
6 on
13141 Snowview Road Victorville
11
On or about January 2010 defendant INTERIM placed plaintiff A R
192
12
13
14
DOB August 1
1999 then age 10 with defendants OATES and WILSON in
Facility 6located at 13141 Snowview Road Victorville
15
Defendant INTERIM knew or should have known defendants OATES
193
16
1
and WILSON violated plaintiff BLJNN s personal rights enumerated in Sections
18
89372 1
10
11
16
20
23
in
Facility
19
Snowview
20
21
22
by but not
limited to
forcing them to scrub walls floors vacuum
and sweep floors lift rugs move and replace furniture clean toilets kitchen and
bathrooms nightly in violation of Section 89378 suffering extreme pain fatigue and
23
severe
sleep deprivation
2 not allowing them to eat the same food as defendants
24
25
26
OATES
the
and
same
WILON in
table
as
violation of
Section 89376
defendants OATES
and
WILON in
3 not allowing them to eat at

violation of
Section 89376
27
28
depriving them of adequate food in violation of Section 89276 causing a constant

52
1
2
3
state of
5 prohibiting them from opening the refrigerator or entering the
hunger
food pantry in
violation of
6 barring them from court ordered
Section 89376
contact with relatives in violation of Section 89379
194
10
195
11
Facility
Silversand
12
14
196
13
Facility
112 141
Dulce
scenario
in
with regard
to
uncertified
Facility
3 Pool
142
15
158
with regard
to
uncertified
Facility
168 186 with regard to
4 Woodworth
16
1
1g
uncertified
Facility
Snowview
Silversand
repeated with regard
to
uncertified
Facility
Defendant INTERIM s administrator defendant AZARIAH did not
19
and could not
issue
Certificate
of
Approval
on
Facility 6 Snowview under
20
21
22
Section 89240 a given defendants OATES and WILSON were not in compliance
with licensing regulations defendant INTERIM made no site visit provided no
23
24
25
26
supervision little if any contact putting plaintiffs at a risk of foreseeable harm as

27
28
53
197
1
2

4
5
6
of
Social Services for
plaintiffs
placement
in
uncertified
by Facility
6 in violation
of Health and Safety Code Section 1508 unbeknownst to said government funding

8
9
10
11
neglect
12
13
14
198
15

16
in
Services for
1g
plaintiffs
placement
uncertified
19
20
21
22

23
199
24
25
26

27
28
54
COMPLAINT FOR DAMAGE
1
2
Department
of
Social Services for
plaintiffs
placement
in
uncertified
Facility 6 in
4
5
6
200
8
9
10
by Section
88063
3 by approving
11

12
13
14

placement
in
uncertified
15

16
1
1g
19
201
20
21
22
by
Section 88063
3 by accessing
23

24
25
26

Services for
plaintiffs
placement
in
uncertified
27
28
55
COMPLAINT FOR D
MAGES
3
abuse and neglect
4
5
6
202
operating
uncertified
by
Section 80000 1
3 and 88018 by
Facility 6 Snowview in violation of Health and Safety Code
8
9
10

11
12
13
14
abuse and neglect
203
15
plaintiffs
health
morals
and
welfare
safety
by
operating
uncertified
Facility
16
17
1g
Snowview in violation of Health and Safety Code Section 1508 unbeknownst to
19
204
20
21
22
malfeasance
on pretext
based
on payments
defendants OATES
for
and
plaintiffs
WILSON
placement
and
in
uncertified
Facility
Facility 6 Snowview were
23
certified
24
25
26
205
In or about 12 10 defendant DOMINGUEZ came on board as
defendant INTERIM s administrator
27
28
56
C
MPLAINT FOR DAMAGES
2
3
Defendant DOMINGUEZ
206
continued
to
operate uncertified
Facility
Snowview as certified in breach of mandatory duties imposed by Health and
Safety Code Section 1508 unbeknownst to said governmental funding agencies
4
5
6
alleged herein with no supervision and little if any contact putting plaintiffs at risk
of foreseeable harm as opposed to immediate removal mandated by law when

defendant knew or should have known plaintiffs suffered ongoing abuse and
8
9
neglect
10
On 12 8 10 unlawful detainer Case No UDVS1004160 was filed
207
11
against
defendants OATES
and
WILSON
on uncertified
Facility
Snowview
12
14
208
13
from
uncertified
Facility 6 Snowview by court order No UDVS 1004160
15
unbeknownst to governmental funding agencies alleged herein

16
1
1g
Defendants OATES and WILSON s and plaintiffs eviction for
209
nonpayment of rent was due to financial malfeasance of defendants INTERIM
19
directors F WILSON MALHOTRA CCHUDU CEO SINGH and administrator

20
21
22
DOMINGUEZ alleged hereinabove with particularity

210
23
Penal Code Section 11166 by failing to report defendants eviction from uncertified
24
6 and homelessness which caused defendants OATES WILSON and
25
Facility
26
foster children to remain homeless in the custody of homeless uncertified defendants
27
OATES and WILSON with no supervision and little if any contact putting
28
57
1
2
plaintiffs at risk of foreseeable harm as opposed to immediate removal mandated by

law knowing or should know plaintiffs suffered ongoing abuse and neglect
3
211
4
5
by Penal Code Section 11166 by failing to report plaintiffs eviction from
uncertified
Facility
was a
serious
deficiency
under
Section 89201
causing
plaintiffs to remain homeless in the custody of homeless uncertified defendants
8
9
10
OATES and WILSON with no supervision and little if any contact putting
11
law when it knew or should have known plaintiffs suffered ongoing abuse and
12
13
neglect
14
212
Plaintiffs and defendants OATES and WILSON s eviction from
15
uncertified
Facility 6 was due to the financial malfeasance of defendants
16
1
1g
INTERIM defendant directors F WILSON MALHOTR A and CHHLTDU

defendant CEO SINGH defendant DOMINGUEZ and defendants OATES and
19
WILSON constituted an unusual incident under Section 88061 4 and a serious

20
21
deficiency under
22
213
Section 89201
23
24
25
26
Section 88061 4 by failing to report defendants eviction and that of foster children
from
uncertified
214
home
27
28
by Section 88061 by failure to report the eviction and homelessness of defendants

58
1
2
3
and
foster
children was a
serious
deficiency
under
Section 89201
that caused
plaintiffs to remain homeless with uncertified homeless defendants OATES and
WILSON in violation of Health and Safety Code Section 1508 with no supervision
4
5
6
and little if any contact putting plaintiffs at risk of foreseeable harm as opposed to
immediate removal mandated by law when it knew or should have known plaintiffs

8
215
9
10
by
Section 89206
by failing to notify CPS ofplaintiffs eviction and homelessness
11
constituted a
serious
deficiency
under
Section 89201
that caused plaintiffs to
12
13
14
15
remain with uncertified defendants OATES and WILSON in violation of Health and
Safety Code Section 1508 with no supervision and little if any contact putting
16
1
1g
law when it knew or should have known plaintiffs suffered ongoing abuse and
neglect
19
216
In 3 11 plaintiff A R and defendants OATES and WILSON moved to
20
21
22
Facility 7 on Bluegrass in Victorville

217
23
24
25
26
27
28
59
218
Facility
Bluegrass
4
219
5
6
Facility
2 Dulce
112 141
scenario
in
with regard
to
uncertified
7
158
with regard
to
uncertified
Facility
Facility
Pool
142
168 186 with regard to
4 Woodworth
8
9
10
uncertified
Facility
Snowview
186 212 with regard to uncertified Facility
Silversand
and repeated with regard
to
uncertified
Facility 7 Bluegrass
11
Defendant INTERIM s administrator defendant DOMINGLJEZ did not and could

12
13
14
not
issue
Certificate
of
Approval
on
Facility
7 Bluegrass under Section
g9240 a given defendants OATES and WILSON were not in compliance with
15
licensing regulations defendant INTERIM made no site visit provided no

16
1
supervision little if any contact putting plaintiffs at a risk of foreseeable harm as
1g
19

20
220
21
22
23

24
25
26
of
Social Services for
plaintiffs
placement
in
uncertified
by Facility
7 in violation
ofHealth and Safety Code Section 1508 unbeknownst to said government funding
27

28
60
3
neglect
4
5
6
221

8
9
10
Services for
plaintiffs
placement
11
12
13
14

15
222
Defendants directors F WILSON MALHOTR A and CHH JDU
16
1
1g

19
20
Social Services for
in uncertified
Facility 7 in
21
Department
22
of
plaintiffs
placement
23
24
25
26
27
28
61
1
2
3
223
by
Section 88063
3 by approving
4
5
6

7
placement
in
uncertified
7 in violation of Health and Safety Code Section
Facility
8
9
10
little ifany contact with plaintiffs putting plaintiffs at risk of foreseeable harm
11
12
13
14
224
by
Section 88063
3 by accessing
15

16
17
based on payments from the U S Department ofHealth and Human Services
1g
19
Services for
plaintiffs
placement
in
uncertified
Facility
20
21
22
23
24
25
26
abuse and neglect
225
27
by
Section 80000 1
28
62
3 and 88018 by
1
2
operating
uncertified
7 Bluegrass in violation ofHealth and Safety Code
Facility
3
supervision
and
little if any
with plaintiffs
contact
p utting p laintiffs at risk of
4
5
6
abuse and neglect
Defendants OATES and WILSON continued to engage in conduct
226
8
9
10
inimical to plaintiffs health morals welfare and safety by operating illegal

uncertified
Facility
7 Bluegrass in violation ofHealth and Safety Code Section
11
1508 unbeknownst to above alleged governmental funding agencies

12
13
14
22
malfeasance
based
on payments
for
plaintiffs
placement
in
15
on pretext
defendants OATES
and
WILSON
and
Facility
uncertified
Facility
Bluegrass
were
16
1
1g
certified
228
On 3 4 1 l the state licensed defendant OATES to operate a family
19
child care
home
at
the
same
location
as uncertified
Facility
7 Bluegrass
20
21
apparently unaware defendant was uncertified and operated at least six uncertified
22
homes since 6 07 with four evictions and five months of homelessness due to
23
defendants financial malfeasance alleged above with particularity

24
25
26
229
In or about 10 18 1 l defendant P AMNIT came on board as defendant
INTERIM s administrator
27
28
63
1
2
3
Defendant RAMNIT continued to hold out uncertified defendants
230
OATES and WILSON to the placement CPS as certified in breach of mandatory
statutory duties imposed by Section 89250 to procure and maintain placements for
4
5
6
uncertified
Facility
7 Bluegrass in violation of Health and Safety code Section
1508 unbeknownst to said governmental funding agencies
Defendant RA
231
continued
to
operate uncertified
Facility
8
9
10
Bluegrass as certified in breach of mandatory duties imposed by Health and Safety

Code Section 1508 unbeknownst to said governmental funding agencies alleged
11
herein with no supervision and little if any contact putting plaintiffs at risk of
12
13
14
foreseeable harm as opposed to immediate removal mandated by law when

defendant knew or should have known plaintiffs suffered ongoing abuse and
15
neglect
16
17
1 g
232
On 1 20 12 defendant administrator P AMNIT issued defendant
WILSON a Certificate ofApproval to operate a certified family home located at a
19
different location than uncertified Facility
7 Bluegrass
20
21
22
233
imposed
by
Defendant P AMNIT thereby breached mandatory statutory duties

Section 89240
namely defendant WILSON was in noncompliance
23
24
25
26
with applicable licensing regulation since 6 07 operated six uncertified facilities for
a period of five years including numerous evictions for nonpayment of rent and
homelessness due to financial malfeasance
27
28
64
1
2
On 10 3 12 defendant INTERIM revoked defendants OATES and
234
WILSON S Certificate
of
Approval
on
Facility
1 issued on 11 16 06
On 6 25 13 the California Department of Social Services Department
235
4
5
6
filed and served ACCUSATION CDSS No 6712269202 against defendants OATES

and WILSON to revoke the Certificate of Approval defendant INTERIM issued on
7
11 16 06
on
Facility
1 purportedly located on Bluegrass
8
9
10
11
236
According to the ACCUSATION defendant INTERIM issued
defendant OATES one Certificate of Approval on 11 16 06 in effect until revoked
10 3 12 whereas defendant OATES lived in 8 different locations between 11 16 06
12
13
to 10 3 12 evicted from four with foster children and homeless for five months with
14
foster children
15
237
Unbeknownst to the Department
Facility
1 was not located on
16
1 was located on 1394 Topmast Drive Helendale California
Bluegrass
1g
92342 defendants OATES
Facility
and
WILSON
were evicted
from
Facility
Topmast
19
on 12 4 07 UDVS701833 defendants OATES and WILSON did not reside on

20
21
Bluegrass until 2011
22
238
ACCUSATION CDSS No 6712269202 petitioned to Rescind
23
Previous Criminal Record Exemption
of defendant WILSON
24
239
25
26
under
ACCUSATION CDSS No 6712269202 alleged Conduct inimical
Health
and
Safety
Code
section
1558
On or about April 16 2012
27
defendant WILSON forcible and against her will grabbed Raquel Estes arm
28
65
1
2
3
pushed her against a wall and pinned her arms above her head and committed a
battery upon her with sexual intent Additionally defendant WILSON made a
statement to the effect that he was going to cemmit a forcible sex act upon her
4
5
person making Estes fearful that she was going to be raped
6
7
ACCUSATION CDSS No 6712269202 alleged Physical
240
abuse personal rights violations under Health and Safety Code sections 1534 b
8
9
10
1558
1596 885
Among
the
allegations of abuse are
18 Between and on or
about November 16 2006 to October 12 2012 defendant Wilson struck three foster
11
Other allegations include OATES slamming children to the ground
children
12
13
14
choking them dragging them upstairs hitting to the point of causing bleeding
beating with a belt and bat stabbing with a spoon handle making the children squat
15
and or run while holding heavy objects as a form of discipline

16
1
1g
241
ACCUSATION CDSS No
Requirements Health
and
Safety
6712269202
alleged
Code Sections 1534 b
and
Reporting
1558
Regulation
19
section
89361
On several occasions during the period from in or about 2011
20
21
22
through in or about March 2012 defendant Wilson failed to report incidents of

physical abuse or corporal punishment that he witnessed or had been informed of
23
24
25
26
To wit seeing defendant Oates strike foster children being told defendant Oates had
struck a foster child
242
In addition to the findings in the ACCUSATION defendants OATES
27
and WILSON assaulted battered and terrorized plaintiffs forced plaintiffs to fight
28
66
1
2
3
other foster children or be beat by defendant OATES not allowed to eat the same
food as defendants OATES and WILSON s family not allowed to eat at the same
table as defendants OATES and WILSON deprived of adequate food prohibited
4
5
6
from opening the refrigerator or entering the food pantry forced to steal food or go
hungry forced to run away to try and contact family members
7
243
In addition defendants OATES and WILSON forced plaintiffs to ask
8
9
10
11
defendant for a glass of water toilet paper sanitary napkins toothpaste demeaned
and cursed plaintiffs forced plaintiffs to scrub walls floors vacuum and sweep
floors lift rugs move and replace furniture clean toilets kitchen and bathrooms
12
13
nightly several hours in the early morning before school suffered sleep deprivation
14
forced plaintiffs to wear used clothes took plaintiffs personal possession beat
15
plaintiffs with belts shoes anything defendant OATES could find refused to allow
16
1
1 g
plaintiffs to wash clothes in defendants washing machine forced plaintiffs to walk

or ride one bike to wash their clothes hit in the face causing bleeding slammed to
19
the ground dragged down stairs beat with belts forced to run around the block for
20
21
hours carrying heavy milk gallons filled with water
22
244
In addition defendants OATES and WILSON forced plaintiffs to
23
witness the abuse and terror of each other and all the other children in the facility
24
245
25
26
The ACCUSATION further
alleged
Rescission of Previous Criminal
Record Exemption and Lack of Good character Health and Safety Code Section
27
1522
and
1558
Regulation Section 89319 defendant WILSON violated the
28
67
1
2
3
conditions of the previous criminal record exemption in that he failed to comply
with licensing laws or regulations failed to continue to demonstrate good character

engaged in conduct inimical as alleged in paragraphs 17 18 19 and 25 above
4
5
6
246
On August 29 2013 the Department issued a default decision against
defendant WILSON finding the factual allegations in the ACCUSATION to be true

correct and constitute violations of the Health and Safety Code Sections 1522
8
9
10
1534 b and 1558 a and California Code of Regulations Title 22 Sections 89319
g9361 and 89372 and grounds under Health and Safety Code section 1522 to
11
rescind defendant WILSON s previously granted criminal exemption

12
13
14
15
247
The Department s duly served Default Decision informed defendant
LSON of the right to request the decision be vacated within seven days after the
Department mailed the default decision and order to defendant WILSON and the
16
1
1g
procedure to said request
248
In or about January 2014 the Department issued a default decision
19
against defendant OATES finding the factual allegations in the ACCUSATION to

20
21
be true correct and constitute violations of the Health and Safety Code Sections
22
1522 1534 b and 1558 a and California Code ofRegulations Title 22 Sections
23
89319 893 61 and 893 72

24
25
26
249
The Department s duly served Default Decision informed defendant
OATES of the right to request the decision be vacated within seven days after the
27
28
68
Department mailed the default decision and order to defendant WILSON and the
1
2
procedure to said request
3
250
Defendants OATES and WILSON did not request the default decisions
4
5
6
7
to be vacated
251
Defendant INTERIM maintained little if any contact with plaintiffs
providing no supervision over plaintiffs care in multiple uncertified community
8
9
10
11
care facilities over the period they were with defendants OATES and WILSON
252
As a direct result of above alleged acts and omissions plaintiffs
suffered severed physical and mental abuse trauma humiliation intimidation
12
13
14
15
threats embarrassment and shame deprivation of liberty and freedom and

substantial hurt and injury to plaintiffs health strength activity and substantial
enduring shock and injury to plaintiffs nervous system mental anguish depression
16
1
anxiety inability to sleep loss of focus and concentration confusion anger
1g
indignity nervousness hopelessness shame fear panic and desperation all of
19
which injuries caused and continue to cause plaintiffs severe mental pain and
20
21
22
suffering for which defendants are liable

253
Plaintiffs are informed believe and thereupon allege that said injuries
23
will result in some permanent disability and general damages in an amount which
24
25
will be stated according to proof pursuant to California Code of Civil Procedure
26
Section 425 10
which amount
is in excess
of
twenty five
27
28
69
OMPLAINT FOR DAMAGES
thousand
dollars
25 000

AR V Interim Care Foster Family Agency Civil Complaint June 25 2015

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AR V Interim Care Foster Family Agency Civil Complaint June 25 2015

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CIV 150625 CIV DS1508999 CASEEN 150202

Scanned Document Coversheet

THIS COVERSHEET IS FOR COURT

Complaint and Party information entered

BRIAN E CLAYPOOL SBN 134674

SUPERIOR COURT OF THE STATE OF CALIFORNIA

COUNTY OF SAN BERNARDINO

litem RAQUEL ESTES

STARQUISHA BUNN individually

COMPLAINT FOR DAMAGES

TERIM CARE FOSTER FAMILY

AJAY MALHOTRA an individual

an individual JOEL DOMINGUEZ an

individual LISA OATES an

individual NAWAB WILSON an

DEMAND FOR JURY TRIAL

COMPLAINT FOR DAMAGES

VENUE AND JURISDICTION

County of San Bernardino in that the underlying wrongdoing acts omissions

this Superior Court

This Superior Court has jurisdiction over the present matter

At all relevant times Plaintiff A R was a minor child residing in San

1999 Raquel Estes has been

petitioned to be the court appointed Guardian ad Litem A R is currently a foster

child and was caught in an illegal abusive violent concealed unconscionable

operation from 2010 to 2011 run by defendant INTERIM CARE FOSTER

and defendants uncertified LISA OATES

At all times herein plaintiff

A R suffered ongoing unrestrained terror torture corporal punishment physical

covered up and unchecked by INTERIM

times Plaintiff STARQUISHA BUNN

operation from 2007 2009run by defendant

INTERIM CARE FOSTER FAMILY AGENCY

times herein plaintiff A R suffered ongoing unrestrained terror torture corporal

OATES and WILSON covered up and unchecked by INTERIM

At all times herein defendant INTERIM was a California Corporation

At all times herein between 1 1 06 and 1 1 13 defendants OATES and

WILSON residents of San Bernardino County defendants INTERIM defendant

OATES and WILSON and seven uncertified facilities as certified by INTERIM in

At all times herein defendants INTERIM defendants board members

defendant CEO defendants Administrators and defendants OATES and WILSON

Human Services Title IV E

Federal Foster Care Funds California Dept of

INTERIM certified defendants OATES and WILSON and defendants

At all times herein defendant INTERIM defendants board members

defendant CEO and defendants Administrators knew plaintiffs foster children

defendants and said facilities out as certified by INTERIM in violation of Health

funds perpetrating the

At all times herein defendant INTERIM defendants board members

defendant CEO and defendants Administrators knew defendants OATES and

tool no action held out said homeless defendants as certified by

At all times herein defendant INTERIM defendants board members

defendant CEO and defendants Administrators knew or should have known

plaintiffs foster children suffered ongoing unrestrained relentless torture trauma

defendants as certified by INTERIM

times herein Defendant SUKHWINDER SINGH

defendant Interim s Chief Financial Officer and Administrator

Street A Rancho Cucamonga California 91730 bilked hundreds of thousands of

INTERIM in violation of Health and Safety Code Section 1508

Defendant FREDDY WILSON

defendant Interim s director 10251 Trademark Street A Rancho Cucamonga

Child Protective Services on pretext uncertified defendants OATES and WILSON

and defendants facilities were certified by INTERIM in violation of Health and