Professional Documents
Culture Documents
CIV
Case Number
DS1416170
CaseType
CIV
Action Code
CASEEN
Action Date
10 27 14
A t o
me
oo
Action Seq
0002
Printed by
LHEND
TH I S PAG E
I I I I I IIII I I I I I I I I I I I I I I I IIII I I I I
NEW FILE
f
1
L Wallace Pate
SBN 79523
Esq
Beverly
Hills CA 90212
Telephone
I L
SUPERIOR COUR7
Cp
NTY
pF
FQ
RNARp I p
4
5
OF SAN
d K
csi
cL
7
S
9
10
11
COUNTY OF SAN BERNADINO
12
13
CASE NO
70
14 MARK GALVAN
SURPRISE ADAMS
15
SUAVE
16
1
1g
19
20
21
Plaintiffs
DEMAND IN CONTROVERSY EXCEEDS
vs
25 000
INTERIM CARE FOSTER FAMILY
23
Defendants
24
25
COME NOW plaintiffs DEANDRE JONES REANDRANE JONES ISAIAH SAIS SALEENA
26
GALVAN MARK GALVAN SURPRISE ADAMS SHAWNA ADAMS individuals
SUAVE DYSON
2
28
a minor by and through his Guardian Ad Litem Robert Miller complain and allege on information and
belief as follows
1
GENERAL ALLEGATIONS
1
2
3 GALVAN MARK GALVAN SURPRISE ADAMS SHAWNA ADAMS minor SUAVE DYSON dob
4
5 10 97
Robert Miller court appointed Guardian Ad Litem herein residents of San Bernadino County
5
are eight
former foster
children caught
in
an
illegal
abusive
violent concealed
unconscionable
kids for
cash operation from 2006 to 2013 run by defendant INTERIM CARE FOSTER FAMILY AGENCY
g
9
INTERIM
and
defendants
uncertified
LISA OATES
and
NAWAB
WILSON
plaintiffs suffered ongoing unrestrained terror torture corporal punishment physical and mental abuse
10
and neglect at the hands of defendants OATES WILSON covered up unchecked by defendant INTERIM
11
2
12
13
At all times herein defendant INTERIM was a California Corporation licensed and existing
under the laws of California with its principal place of business in the County of San Bernadino 10251
residents of San Bernadino County defendants INTERIM defendants board members defendant CEO
17
and defendants Administrators held out uncertified OATES WILSON and seven uncertified facilities as
18
19
20
21
22
At all times herein defendants INTERIM defendants board members defendant CEO
defendants Administrators and defendants OATES WILSON bilked hundreds of thousands of foster care
dollars from
the
U S Dept
of
Health
and
Human
Services
Title IV E
23
California Dept of Social Services DSS State Foster Funds and San Bernadino County Child Protective
24
Services Foster Care Funds for plaintiffs on pretext that defendant INTERIM certified defendants
25
At all times herein defendant INTERIM defendants board members defendant CEO
and defendants Administrators knew plaintiffs foster c zildren were evicted frorrc four 4 ofthe seven
COMPLAINT
GENERAL ALLEGATIONS
1
2
3 GALVAN MARK GALVAN SURPRISE ADAMS SHAWNA ADAMS SUAVE DYSON residents of
4
San Bernadino County are eight former foster children caught in an illegal abusive violent concealed
5
unconscionable
kids for cash operation from 2006 to 2013 run by defendant INTERIM CARE FOSTER
6
FAMILY AGENCY
INTERIM
g At all times herein plaintiffs suffered ongoing unrestrained terrar torture corporal punishment physical
9
10
and mental abuse and neglect at the hands of defendants OATES WILSON covered up unchecked by
defendant INTERIM
11
2
At all times herein defendant INTERIM was a California Corporation licensed and existing
12
13
under the laws of California with its priricipal place of business in the County of San Bernadino 10251
residents of San Bernadino County defendants INTERIM defendants board members defendant CEO
17
and defendants Administrators held out uncertified OATES WILSON and seven uncertified facilities as
18
19
20
21
22
At all times herein defendants INTERIM defendants board members defendant CEO
defendants Administrators and defendants OATES WILSON bilked hundreds of thousands of foster care
dollars from the U S Dept
of
Health
and
23
California Dept of Social Services DSS State Foster Funds and San Bernadino County Child Protective
24
25
Services Foster Care Funds for plaintiffs on pretext that defendant INTERIM certified defendants
At all times herein defendarit INTERIM defendants board members defendant CEO
and defendants Administrators knew plaintiffs foster children were evicted from four 4 ofthe seven
COMPLAINT
1
2
3
uncertified facilities while holding said defendants and said facilities out as certified by INTERIM in
violation of
S Code Section 1508 placed more dependent children collected lucrative federal state
and county foster care funds perpetrating the kids for cash scam
At all times herein defendant INTERIM defendants board members defendant CEO
6
5
and defendants Administrators knew defendants OATES WILSON and plaintiffs foster children were
6
homeless for
by
six months
INTERIM in
homeless foster
violation of
children
certified
collected lucrative federal state and county foster care funds perpetrating the kids for cash scam
10
At all times herein defendant INTERIM defendants board members defendant CEO
11
and defendants Administrators knew or should know plaintiffs foster children suffered ongoing
12
13
unrestrained relentless torture trauma severe mental and emotional abuse at the hands of defendants
14 OATES WILSON took no action held out said uncertified dangerous violent abusive defendants as
15 certified by INTERIM
16
17
Administrator 10251 Trademark Street A Rancho Cucamonga California 91730 bilked hundreds of
18
thousands of foster care dollars from the U S Dept of Health and Human Services California DSS and
19
20 San Bernadino County Child Protective Services on pretext uncertified defendants OATES WILSON and
21
22
defendants
facilities
were certified
by
INTERIM in
violation of
23
Rancho Cucamonga California 91730 bilked hundreds of thousands of foster care dollars from the U S
24
Dept of Health and Human Services California DSS and San Bernadino County Child Protective
25
26 Services on pretext uncertified defendants OATES WILSON and defendants facilities were certified by
27
INTERIM in
violation of
28
COMPLAINT
At all times herein defendant AJAY MALHOTRA defendant Interim s director 10251
10
2 Trademark Street A Rancho Cucamonga California 91730 bilked hundreds ofthousands of foster care
3 dollars from the U S Dept of Health and Human Services California DSS and San Bernadino County
4
Child Protective Services on pretext uncertified defendants OATES WILSON and defendants facilities
5
were certified
by
INTERIM in
violation of
11
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 DSS and San Bernadino
10
County Child Protective Services on pretext uncertified defendants OATES WILSON and defendants
11
facilities
were certified
by
INTERIM in
violation of
12
13
Human Services California DSS and San Bernadino County Child Protective Services on pretext
17
uncertified defendants OATES WILSON and defendants facilities were certified by INTERIM in violation
18
of
19
20
21
defendant Interim s Administrator 10251 Trademark Street A Rancho Cucamonga California 91730
22
bilked hundreds of thousands of foster care dollars from the U S Dept of Health and Human Services
23
California DSS and San Bernadino County Child Protective Services on pretext uncertified defendants
24
OATES WILSON
and
defendants
by
INTERIM in
violation of
S Code
25
26 Section 1508
27
28
RESERVED 14
17
16
COMPLAINT
3 Human Services California DSS and San Bernadino County Child Protective Services on pretext
4
uncertified defendants OATES WILSON and defendants facilities were certified by INTERIM in violation
5
of
6
7
g
9
10
11
12
13
14
18
18
19
19
AJAY MALHOTRA and BHUPINDER CHHUDU that defendant Interim applied for a license to operate
20
The Department
s notification
further
stated
22
23 approved this license will be issued in the name of the corporation This means that the corporation will be
24 held accountable for the care and supervision of all clients in care
25
21
The Department
s notification
further
stated
26
essential if the board members are to ensure that the care facility is operating properly and in substantial
27
28
compliance with licensing laws and regulations In some instances board members may be held
accountable for the conduct of or damages caused by the facility corporate licensee
5
COMPLAINT
22
2
3
duties on defendant Interim s directors defendants FREDDIE WILSON AJAY MALHOTRA and
BHUPINDER CHHUDU
1 establish and approve policies and procedures governing the operation of defendant
responsibilities
5
Interim
9 defendants directors FREDDIE WILSON AJAY MALHOTRA and BHUPINDER CHHUDU to sign a
10
r itten resolution stating the board shall operate defendant Interim in full conformity with applicable
11
13
14 WILSON AJAY MALHOTRA and BHUPINDER CHHUDU for dependent children placed in defendant
15 Interim s custody
16
17
account for the general supervision of defendant s facility and certified family homes to establish policies
18
19
concerning operations and to ensure operations comply with applicable regulations and statutes
26
20
21
22
The U S Department of Health and Human Services under Social Security Act Title IV E
California Department of Social Services and San Bernadino Department of Social Services paid
defendant Interim millions for foster care for dependent children placed in defendant s custody including
23
plaintiffs
24
27
25
Administrator means the person designated by the board of directors to be responsible for
26 defendant Interim
27
28
s operation
6
COMPLAINT
2
3
licensed FFA and issued a Certificate of Approval by the agency as meeting licensing standards a certified
g parent is an adult residing in the home certified by the FFA to provide court supervision to children placed
9 by that agency
10
31
11
each certified family home used by defendant with a Certificate of Approval properly completed and
14 signed by the administrator or his her designee a Certificate of Approval is not transferable and is void
15
16
32
Completed Application
11
means
17
submitted and the licensing agency has received all required material and B the licensing agency has
18
19
20
21
Name
and address of
22
renting
the
applicant
A copy of the document s that establish that the applicant has control of the property to be
23
licensed
24
34
25
35
Under Sections 80022 and 83087 2 the Plan of Operation includes a sketch of the building
and the grounds including the dimensions of all areas used by the clients
COMPLAINT
36 Under Sections 80 022 g and 80061 changes in the Plan of Operation shall be submitted
37
determination that all of the requirements of Article 3 of this chapter have been satisfied
10
11
license to the applicant after an application has been completed an in home visit has been made pursuant
14
to Section 89227
15
16
40
subsection
and
17
provide defendant Interim with reasonable notice prior to any change in the location of the home as
18
specified
in Section 89361
subsection
19
41
20
Under H
21 community care facility maintained and operated to provide non medical care if it is unlicensed and not
22
exempt from licensure and the facility is held out as or represented as providing care or supervision as
23
defined by this chapter or the rules and regulations adopted pursuarit to this chapter
24
42
25
26
27
28
home
that
89201 C
is
providing
held
out as or represented as
and
includes
A licensed
43
child abuse
states
COMPLAINT
1
2
3
child suffers
other
from any
one or more of
and
2 Harm
basic
the
following
by
reason of
physical care
maltreatment of a child under the age of 18 by a person who is responsible for the child s welfare under
5
circumstances that indicate that the child s health or welfare is harmed or threatened thereby as determined
6
44 Under H
and
care means care provided in a current and validly licensed or administrator certified community care
10
facility
11
12
Penal Code Section 11166 imposed mandatory statutory duties on defendant Interim to
45
13
report
14
placement
in
uncertified
community
care
facilities in
violation of
15
16
46 Section 88061 b imposed mandatory statutory duties on all defendant Interim s personnel
17
to
report
the
abuse of a
dependent
child pursuant
to H
3 and 4 based on
18
placement
in
uncertified
community
care
facilities in
violation of
19
47
20
21
22
23
child placed
constitutes an unusual
or
safety
of
any
child
in
incident
an uncertified
violation of
Section 88061
under
constituting
home in
4 mandating a
24
48
Section 88061 g imposed mandatory statutory duties on defendant Interim to report child
25
abuse under
26
Health
and
Safety
49 Section 88061 h imposed mandatory statutory duties on defendant Interim to provide a log
COMPLAINT
1 of family homes certified and decertified during the month to the Department by the tenth of the following
2
3
month
50
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
5
51
6
compliance with all applicable law and regulations
g
9
10
52
provision of the Community Care Facilities Act commencing with Section 1500 of the Health and Safety
Code and or regulations adopted by the Department pursuant to the Act
11
53
12
13
14
15
16
immediate or substantial threat to the physical health mental health or safety of any child in the home
54
Provision
or provide
required that provision be made for or that there be provided any service personnel or other requirement
the care giver shall do so directly or present evidence to the licensing agency that the requirements have
17
55
20 Community Care Licensing in accordance with the standards set forth in Article 3 ofthis chapter The
21
22
23
defined in Section 1503 5
of
the H
S Code
24
57 Under Section 89201
89201 U
1 O 3
25
58
Section 89205 imposed mandatory statutory duties ori defendant Interim not to operate
28
io
COMPLAINT
establish manage conduct or maintain a foster family home or hold out advertise or represent by any
2 means to do so without first obtaining a current valid license from the licensing agency
3
59
Under
Section
89206
violation of Section 1503 5 and or 1 508 of the Health and Safety Code
5
immediate civil penalty on parents for operating an illegal unauthorized uncertified home pursuant to Title
g 22 section 89255 and Section 1547 of the Health and Safety Code
9
10
61
Section 89206
the appropriate placement or protective service agency of an immediate threat to clients health and safety
11
62 Health and Safety Code Section 1508 imposed mandatory statutory duties on defendant
12
13
14
63 Health and Safety Code Section 1508 imposed mandatory statutory duties on
17
64 Health and Safety Code Section 1508 imposed mandatory statutory duties on defendant
18
CEO SUKHWINDER SINGH not to operate establish manage or maintain uncertified family homes
19
20
65 Health and Safety Code Section 1508 imposed mandatory statutory duties on
21 defendants directors FREDDIE WILSON AJAY MALHOTRA and BHUPINDER CHHUDU not to
22
23
66
24
25
KHUSHANiJD AZARIAH JOEL DOMINGUEZ and SHANZIA RAMNIT to deny an application for
26 certification if it is determined the applicant is not in compliance with applicable laws and regulations
27
28
67
Under Section 89242 a the Department shall have the authority to suspend or
revoke any license on any ofthe grounds specified in Health and Safety Code section 1550
11
COMPLAINT
68
Under Health
and
Safety
Code
section
1550
2 application for or suspend or revoke any license or any administrator certificate issued under this chapter
3
upon
any
the
of
4
grounds
Violation
and
following grounds
in this
chapter
the licensee
by
in
Aiding abetting or permitting the violation ofthis chapter or of the rules and regulations promulgated
under
this chapter
individual in
or
receiving
from the
services
facility
or
State
of
California
Engaging
9 in acts of financial malfeasance concerning the operation of a facility including but not limited to
10
of
facilit Y
moneY s and
P roPertY
11
to provide services
12
69
13
14 licensing approval agency and the child s authorized representative required by the Department including
15
but
not
limited to the
16
emotional
health
or
following 3 Any unusual incident or child absence that threatens the physical or
safety
of
any
child
Any
any
child
17
When there is a change in the location of the home the caregiver shall notify the licensing approval agency
18
70
21
limited to
22
the
furnishings
following
each child shall have personal rights which include but are not
to his her
needs
23
sexual
physical
24
of pain humiliation intimidation ridicule coercion threat mental abuse or other actions of a punitive
25
26 nature including but not limited to interference with the daily living functions of eating sleeping or
27
28
toileting
healthy
or
withholding
food
of shelter
clothing
or aids
to
physical
functioning
1z
COMPLAINT
1
2
89372 O 3
B To
necessary medical
dental
vision
his her
own personal
and mental
health
items
services
including toiletries
8 To receive
3 outside of the foster care system such as teachers church members mentors and friends in accordance
4
with
Section 89372
11
To
contact
family
members
unless prohibited
by
court order
16 To make
and receive confidential phone calls and send and receive unopened mail unless prohibited by court order
6
20 To attend school and participate in extracurricular cultural and personal enrichment activities
developmental level that is
consistent
with
state
accorded dignity in his her personal relationships with other persons in the home
10
s age and
law
23 To be
11
13
14 foster children have their meals with foster family members in a family setting
15
73
16
18
19
opportunity for and encourage participation in group sports leisure time family special school and daily
75
a license to operate a Foster Family Agency FFA to certify foster parents and their homes as meeting all
23
licensing requirements to provide foster care for dependent children entrusted to defendant Interim s
24
25
26
27
28
custody
76
Prior to the issuance of defendant Interim s FFA license to certify family homes defendant
13
COMPLAINT
1 JONES dob 3 26 96 then age 10 and DYSON dob 5 10 97 then age 9 with defendants OATES WILSO
2
in
Facility
78
Defendant Interim knew or should have known defendants OATES WILSON violated
4
plaintiffs
JONES JONES
and
11
16
DYSON
in Sections 89372 1
5
6
10
20
23 in
Facility
Topcast
by
but
not
limited
to
forced to
scrub walls floors vacuum and sweep floors lift rugs move and replace furniture clean toilets kitchen
g and bathrooms nightly in violation of Section 89378 suffering extreme pain fatigue and severe sleep
9
2 not allowed to eat the same food as defendants Oates and Wilson s family in violation of
deprivation
10
Section 89376
3 not allowed to eat at the same table as defendants Oates and Wilson in violation of
Section 89376
11
12
13
14
5 prohibited from opening the refrigerator or entering the food pantry in violation of Section
hunger
g9376
6 barred from court ordered contact with relatives in violation of Section 89379
and 7 forced to
i
moved
to
Facility
18
19
20
issued on 11 16 06 was void by operation of law upon change of location under Title 22 Section 88030 e
and
21
22
by H
S Code
Section 1534 and Title 22 Sections 89234 d by failing to report a change in location to defendant Interim
23
25
26
82
by failing
to
submit an application
for
approval on
Facility
2 Dulce
by
27 Code Section 1534 and Title 22 Sections 89234 d and 89361 d by failing to obtain a Certificate of
28
Approval
on
Facility
2 Dulce
14
COMPLAINT
83
1
to
Facility
2 Dulce
visit
plaintiffs at risk of foreseeable harm knowing or should know plaintiffs suffered ongoing abuse and
4
neglect
84
Defendant Interim s administrator defendant KHUSHANUD AZARIAH did not and could no
6
issue
Certificate
of
Approval
on
Facility
2 Dulce
85
10
g9201
Facility
2
89201
Dulce
89201
family
89206
home
and
pursuant
to Sections 88001
88005
11
86
Defendants OATES WILSON were not certified parents who met licensing requirements
12
13
14
in
C
uncertified
89206
Facility
a
pursuant
to Sections
88001
88005
89201 1
89201
89201
S Code sections 1503 5 and 1508 putting plaintiffs JONES JONES and DYSON at
Defendant Interim breached mandatory statutory duties imposed by Sections 88005 88030
17
b
80001
80005 89201
89205
89206
89227
89231
18
19
by
operating
uncertified
Facility
2 Dulce
20 plaintiffs JONES JONES and DYSON putting plaintiffs at risk of foreseeable harm knowing or should
21
22
23
CHHUDU
by
24
uncertified
25
Facility
2 Dulce with no supervision over and little if any contact with plaintiffs JONES
26 JONES and DYSON putting plaintiffs at risk of foreseeable harm knowing or should know plaintiffs
27 suffered ongoing abuse and neglect
28
89
15
COMPLAINT
o
imposed
by
by
operating
Facility
uncertified
2 over and little if any contact with plaintiffs JONES JONES and DYSON putting plaintiffs at risk of
3 foreseeable harm knowing or should know plaintiffs suffered ongoing abuse and neglect
4
90
5
H
by
operating
uncertified
Facility
2 Dulce
little if any contact with plaintiffs JONES JONES and DYSON putting plaintiffs at risk of foreseeable
g harm knowing or should know plaintiffs suffered ongoing abuse and neglect
9
10
g9255
91
and
S Code Section 1547 by failing to issue an immediate civil penalty against defendants
11
OATES WILSON
on uncertified
Facility
2 Dulce
12
13
14 failing to notify the CPS placement agency that plaintiffs JONES JONES and DYSON were in uncertified
15
16
2 in
Facility
violation of
S Code Sections 1505 and 1508 with no supervision over and little if any
contact with plaintiffs JONES JONES and DYSON putting plaintiffs at risk of foreseeable harm
17
Defendant Interim
breach
of
19
20
21
plaintiffs
22
that
JONES JONES
and
DYSON to
remain
in
moved
to
uncertified
by
an uncertified
Facility
2 in
Section 86206
Facility
by
2 caused
violation of
S Code
Section 1508 as opposed to immediate removal mandated by law with no supervision over and little if
23
any contact putting plaintiffs at foreseeable risk of harm knowing or should know plaintiffs suffered
24
25
26
27 constituted inimical conduct that caused plaintiffs JONES JONES and DYSON to remain in uncertified
28
Facility
2 in
violatiori of
16
COMPLAINT
1 with no supervision over and little if any contact putting plaintiffs at risk of foreseeable harm knowing or
2 should know plaintiffs suffered ongoing abuse and neglect
3
Defendant Interim breached mandatory statutory duties imposed by Section 89205 holding
95
uncertified
and uncertified
Facility
5
plaintiffs
to remain
in
uncertified
2 in
Facility
violation of
as opposed to
immediate removal mandated by law with no supervision over and little if any contact putting plaintiffs
g at foreseeable risk of harm knowing or should know plaintiffs suffered ongoing abuse and neglect
9
96
10
holding
out uncertified
Facility
and uncertified
2 Dulce as certified to
11
CPS constituted a serious deficiency under Section 89201 s 1 causing plaintiffs JONES JONES and
12
13
DYSON to remain in
uncertified
Facility
in
violation of
14 immediate removal mandated by law with no supervision over and little if any contact putting plaintiffs
15 at foreseeable risk of harm knowing or should know plaintiffs suffered ongoing abuse and neglect
16
Defendant Interim
97
breach
of
mandatory
statutory
duties imposed
by
section
89206
for
17
failure to
report
Facility
18
19
20 JONES JONES
21
22
and
DYSON to
remain
in
uncertified
Facility
2 in
1 causing plaintiffs
violation of
S Code Section
1508 as opposed to immediate removal mandatecl by law with no supervision over and little if any
contact putting plaintiffs at foreseeable risk of harm knowing or should know plaintiffs suffered ongoing
23
abuse and neglect
24
98
and
DYSON
s placement
in
uncertified
Facility
Dulce in
25
26
violation of
27
and
28
and
plaintiffs
Welf
S Code Section 1508 was child abuse under Health and Safety Code Section 1531 5 c 3
Inst Code Section 300 b reportable under Penal Code Section 11166 mandating
immediate removal
COMPLAINT
99 Penal Code Section 11166 imposed mandatory statutory duties on defendant Interim to report
1
2
3
plaintiffs
JONES JONES
and
DYSON
s placement
in
uncertified
2 Dulce in violation of H
Facility
100 Defendant Interim s breach of mandatory statutory duties imposed by Penal Code Section
5
11166 for failure
to report plaintiffs
JONES JONES
DYSON
and
placement
in
uncertified
Facility
6
Dulce causing
plaintiffs
to
remain
in
uncertified
Facility
2 in
violation of
g opposed to immediate removal mandated by law with no supervision over and little if any contact put
9 plaintiffs at foreseeable risk of harm knowing or should know plaintiffs suffered ongoing abuse and
1
10
neglect
11
Defendant Interim s breach of mandatory statutory duties imposed by Penal Code Section
101
12
13
14
15
16
89201
report
Facility
caused plaintiffs
violation of
JONES JONES
and
DYSON to
remain
in
uncertified
Facility
2 in
supervision over and little if any contact putting plaintiffs at foreseeable risk of harm knowing or should
17
22
11166
and
contact
Defendant Interim s breach of mandatory statutory duties imposed by Penal Code Section
aided
Dulce in
abetted
violation of
86206
and permitted
88661
s operation of uncertified
Facility
23
immediate removal mandated by law putting plaintiffs at risk of foreseeable harm knowing or should
24
25
26
Defendant Interim engaged in acts of financial malfeasance based on payments from the
27 U S Department of Health and Human Services California Department of Social Services and San
28 Bernadino Department of Social Services for plaintiffs JONES JONES and DYSON s placement in
is
COMPLAINT
uncertified
Facility
2 in
violation of
2 agencies as opposed to immediate removal mandated by law with no supervision little if any contact
3
putting plaintiffs at risk of foreseeable harm knowing or should know plaintiffs suffered ongoing abuse and
4
neglect
5
104
6
CHHUDU breached mandatory statutory duties imposed
by
Section 88063
2 by approving and
g monitoring a budget based on payments from the U S Department of Health and Human Services
9 California Department of Social Services and San Bernadino Department of Social Services for plaintiffs
10
JONES JONES
and
DYSON
s placement
in
uncertified
Facility
2 in
violation of
S Code Section
11
1508 unbeknownst to said government funding agencies with no supervision little if any contact putting
12
13
plaintiffs at risk of foreseeable harm as opposed to immediate removal mandated by law knowing
105
by
Section 88063
3 by approving and
17
monitoring a budget to cover operation costs based on payments from the U S Department ofHealth and
18
19
Human Services California Department of Social Services and San Bernadino Department of Social
20 Services for
21
22
plaintiffs
JONES JONES
and
DYSON
s placement
in
uncertified
Facility
2 in violation of
S Code Section 1508 unbeknownst to said government funding agencies with no supervision little if
any contact putting plaintiffs at risk of foreseeable harm as opposed to immediate removal mandated by
23
law knowing or should know plaintiffs suffered ongoing abuse and neglect
24
106
25
26
by
Section 88063
3 by
27 accessing and maintaining defendant Interim s level of funding to cover operation costs based on payments
28 from the U S Department of Health and Human Services California Department of Social Services and
19
COMPLAINT
1
2
3
4
San Bernadino Department of Social Services for plaintiffs JONES JONES and DYSON s placement in
Facility
uncertified
2 in
violation of
agencies with no supervision little if any contact putting plaintiffs JONES JONES and DYSON at risk
of foreseeable harm as opposed to immediate removal mandated by law knowing or should know plaintiffs
5
suffered ongoing abuse and neglect
6
107
g CHHUDU breached mandatory statutory duties imposed by Sections 80000 1 3 and 88018 by operating
9
10
Facility
uncertified
2 Dulce in
violation of
alleged governmental funding agencies with no supervision little if any contact putting plaintiffs JONES
11
JONES and DYSON at risk of foreseeable harin as opposed to immediate removal mandated by law
12
13
108
14
15 payments from the U S Department of Health and Human Services California Department of Social
16
Services and San Bernadino Department of Social Services for plaintiffs JONES JONES and DYSON s
17
placement
in
uncertified
Facility
2 in
violation of
18
19
government funding agencies with no supervision little if any contact putting plaintiffs JONES JONES
20 and DYSON at risk of foreseeable harm as opposed to immediate removal mandated by law knowing or
21
22
109
23
and
DYSON
health
rnorals
welfare
and
safety
by
operating
uncertified
Facility
Dulce in violation
24
of
25
26
27 for
28
plaintiffs
Defendants Oates and Wilson engaged in acts of financial malfeasance based on payments
JONES JONES
Oates Wilson
and
Facility
and
DYSON
placement in
uncertified
Zo
COMPLAINT
Facility
2 on pretext defendants
Defendant Interim knew or should have known and defendant WILSON observed
111
2 defendant OATES plaintiffs JONES JONES and DYSON to either fight other foster children or
3 beaten tortured by defendant forced to steal food or go hungry forced D JONES to walk 14 miles to and
4
from school when his home school was five minutes away forced DYSON to sit in a small banana crate all
day
forced DYSON
to wear ill
fitting shoes
disability
damage
forced plaintiffs to
ask defendant for a glass of water for toilet paper for tooth paste demeaned and cursed plaintiffs forced
g plaintiffs to clean defendant s house several hours each night to wear used clothes to wear clothes that
9
10
were too small causing shame and embarrassment took plaintiffs personal possessions beat plaintiffs with
belts shoes anything defendant OATES could find refused to allow plaintiffs JONES JONES and
11
DYSON to
wash clothes
in defendant
s machine
in
Facility
12
13 carrying plastic bags of clothes miles to and from the laundromat in the dark at night in all kinds of
14
eather
15
16
112
DYSON
moved
location
to
Facility
Pool
17
113
18
19
S Code Section 1534 and Title 22 Sections 89234 d by failing to report a change in location to
20 defendant Interim
21
22
114
Section 89218
by failing to
submit an application
approval on
Facility
23
Pool
24
115
25
S Code Section 1534 and Title 22 Sections 89234 d and 89361 d by failing to obtain a Certificate of
26
27
2g
116
on
Facility
Pool
21
COMPLAINT
issue
Certificate
of
Approval
on
Facility
2 defendants OATES WILSON S licensing violations defendant Interim made no site visit provided no
3
supervision little if any contact putting plaintiffs JONES JONES and DYSON at risk of foreseeable
harm as opposed to immediate removal mandated by law knowing or should know plaintiffs suffered
5
6
Facility
88005
89201 1
89201
89201
89206
and
S Code Sections
88001
1503 5 and 1508 putting plaintiffs JONES JONES and DYSON at foreseeable risk of harm
10
Defendants OATES WILSON were not certified parents who met licensing requirements in
118
11
uncertified
Facility
pursuant
to Sections 88001
88005
89201 1
89201
89201
12
13
89206
S Code sections 1503 5 and 1508 while defendant Interim provided no supervision
14 little if any contact putting plaintiffs JONES JONES and DYSON at risk of foreseeable harm as opposed
15 to immediate removal mandated by law knowing or should know plaintiffs suffered ongoing abuse and
16
neglect
17
119
Defendant Interim
s operation of uncertified
Facility
Pool
breached
18
19
20
89206
89227
89231
and
by
H
Sections 88005
88030
80001
80005 89201
89205
21 any contact putting plaintiffs JONES JONES and DYSON at risk of foreseeable harm as opposed to
22
immediate removal mandated by law knowing or should know plaintiffs suffered ongoing abuse and
23
neglect
24
120
25
26
27
operation of uncertified
Facility
by
28 JONES JONES and DYSON at risk offoreseeable harm as opposed to immediate removal mandated by
az
COMPLAINT
1 law knowing ar should know plaintiffs suffered ongoing abuse and neglect
121
duties imposed
by
by
operation of uncertified
Facility
Pool
with no
supervision little if any contact putting plaintiffs JONES JONES and DYSON at risk of foreseeable
5
harm as opposed to immediate removal mandated by law knowing or should know plaintiffs suffered
6
ongoing abuse and neglect
9
10
122
imposed
by
by
operation of uncertified
Facility
Pool
with no supervision
little if any contact putting plaintiffs JONES JONES and DYSON at risk of foreseeable harm as opposed
11
to immediate removal mandated by law knowing or should know plaintiffs suffered ongoing abuse and
12
neglect
13
15
16
123
14
g9255
Oates
and
and
S Code Section 1547 by failing to issue an immediate civil penalty against defendants
Wilson
on uncertified
Facility
Pool
17
124
18
19
failing to notify the CPS placement agency that plaintiffs JONES JONES and DYSON were placed in
Facility
Pool
in
violation of
20
uncertified
21
contact putting plaintiffs at risk of foreseeable harm as opposed to immediate removal mandated by law
23
125
Defendant Interim
breach
of
by
Section 86206
for
24
failure
25
26
Pool
to notify
CPS
that
caused plaintiffs
plaintiffs
to remain
in
JONES JONES
uncertified
and
Facility
DYSON
3 in
were placed
violation of
in
uncertified
in
Facility
27 no supervision little if any contact putting plaintiffs at risk of foreseeable harm as opposed to immediate
28
removal mandated by law knowing or should know plaintiffs suffered ongoing abuse and neglect
23
COMPLAINT
Defendant Interim
by
126
no supervision and little if any contact putting plaintiffs JONES JONES and DYSON at risk of
constituted
inimical
causing plaintiffs to
conduct
remain
in
uncertified
3 with
Facility
foreseeable harm as opposed to immediate removal mandated by law knowing or should know plaintiffs
5
suffered ongoing abuse and neglect
6
127
as certified and
uncertified
Facility
3 Pool
as
holding
certified to CPS constituting conduct inimical to plaintiffs JONES JONES and DYSON s health morals
out uncertified
10
elfare
causing
plaintiffs
to
remain
in
uncertified
Facility
3 in
violation of
11
with no supervision and little if any contact putting plaintiffs at risk of foreseeable harm as opposed to
12
13
immediate removal mandated by law knowing or should kriow plaintiffs suffered ongoing abuse and
14 neglect
15
16
128
holding
out uncertified
and uncertified
Facility
17
constituting a serious deficiency under Section 89201 s 1 causing plaintiffs JONES JONES and
18
DYSON to
remain
in
uncertified
19
Facility
in
violation of
20 and little if any contact putting plaintiffs at risk of foreseeable harm as opposed to immediate removal
21 mandated by law knowing or should know plaintiffs suffered ongoing abuse and neglect
22
Defendant Interim
129
breach
of
by
section
23
failing
to
report plaintiffs
JONES JONES
and
DYSON
s placement
in
uncertified
Facility
89206
3 Pool
by
in
24
violation of
25
26
plaintiffs
to
S Code Section 1508 was a serious deficiency under Section 89201 s 1 causing
remain
in
uncertified
Facility
27 at risk of foreseeable harm as opposed to immediate removal mandated by law knowing or should know
28
24
COMPLAINT
2
3
130
1
Pool
and
DYSON
s placement
in
and
uncertified
Facility
Welf
reportable under Penal Code Section 111 66 mandating plaintiffs immediate removal from uncertified
4
defendants OATES WILSON
5
131
Defendant Interim breached mandatory statutory duties imposed by Penal Code Section
6
11166
g
9
10
Pool
in
by failing
in
violation of
uncertified
JONES JONES
to report plaintiffs
DYSON
s placement
in
uncertified
Facility
S Code Section 1508 causing plaintiffs JONES JONES and DYSON to remain
Facility
and
foreseeable harm as opposed to immediate removal mandated by law knowing or should know plaintiffs
11
suffered ongoing abuse and neglect
12
132
13
14
11166
15
pool
Defendant Interim s breach of mandatory statutory duties imposed by Penal Code Section
by failing
in
to
violation of
16
causing
report plaintiffs
plaintiffs
JONES
JONES JONES
and
DYSON
s placement
in
uncertified
Facility
and
DYSON to remain in
uncertified
Facility
3 with no supervision
17
and little if any contact putting plaintiffs at risk of foreseeable harm as opposed to immediate removal
18
19
mandated by law knowing or should know plaintiffs suffered ongoing abuse and neglect
133
20
21
22
Defendant Interim s breach of mandatory statutory duties imposed by Penal Code Section
11166 and Title 22 Sections 89205 86206 fl 88661 c aided abetted and permitted uncertified defendants
OATES WILSON
s operation of uncertified
3 Pool
Facility
in
violation of H
23
causing
plaintiffs
JONES JONES
and
DYSON to
remain
in
uncertified
Facility
3 with no supervision
24
25
and little if any contact with defendant Interim putting plaintiffs at risk of foreseeable harm as opposed to
26 immediate removal mandated by law knowing or should know plaintiffs suffered ongoing abuse and
27 neglect
28
134
Defendant Interim engaged in acts of financial malfeasance based on payments from the
25
COMPLAINT
1 U S Department of Health and Human Services California Department of Social Services and San
2 Bernadino Department of Social Services for plaintiffs JONES JONES and DYSON s placement in
3
4
uncertified
Facility
3 in
violation of
agencies 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 plaintiffs suffered ongoing abuse
6
and neglect
9
10
135
by
Section 88063
2 by approving and
monitoring a budget for defendant Interim based on payments from the U S Department of Health and
il
Human Services California Department of Social Services and San Bernadino Department of Social
12
13
Services for
14 H
plaintiffs
JONES JONES
and
DYSON
s placement
in
uncertified
Facility
3 in violation of
S Code Section 1508 unbeknownst to said government funding agencies with no supervision and
15 little if any contact putting plaintiffs at risk of foreseeable harm as opposed to immediate removal
16
mandated by law knowing or should know plaintiffs suffered ongoing abuse and neglect
17
136
18
19
by
Section 88063
3 by
20 approving and monitoring a budget to cover operating costs based on payments from the U S Department
21
22
of Health and Human Services California Department of Social Services and San Bernadino Department
of
plaintiffs
JONES JONES
and
DYSON
s placement
in
uncertified
Facility
3 in
23
violation of
24
25
supervision and little if any contact putting plaintiffs at risk of foreseeable harm as opposed to immediate
26 removal mandated by law knowing or should know plaintiffs suffered ongoing abuse and neglect
27
28
137
by
26
COMPLAINT
Section 88063
3 by accessing and
1 maintaining defendant Interim s level of funding to cover operation costs based on payments from U S
2 Department of Health and Human Services California Department of Social Services and San Bernadino
3 Department of Social Services for plaintiffs JONES JONES and DYSON s placement in uncertified
4
3 in
Facility
violation of
5
6
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 plaintiffs suffered ongoing abuse and
neglect
9
10
138
BHUPINDER CHHUDU breached mandatory statutory duties imposed by Sections 80000 1 3 and
11
88018 by covering operation costs based on payments from the U S Department of Health and Human
12
Services California Department of Social Services and San Bernadino Department of Social Services for
13
JONES
JONES
and
DYSON
s placement
in
uncertified
Facility
3 in
violation of
S Code
14
plaintiffs
15
Section 1508 unbeknownst to said government funding agencies with no supervision and little if any
16
contact putting plaintiffs at risk of foreseeable harm as opposed to immediate removal mandated by law
17
19
20 based on payments from the U S Department of Health and Human Services California Department of
21
Social Services and San Bernadino Department of Social Services for plaintiffs JONES JONES and
22 DYSON
s placement
in
uncertified
Facility
3 in
violation of
23
said government funding agencies with no supervision and little if any contact putting plaintiffs at risk of
24
25
foreseeable harm as opposed to immediate removal mandated by law knowing or should know plaintiffs
140
JONES
and
by
maintaining
uncertified
Facility
COMPLAINT
Pool
in
violation of
S Code Section
1508 unbeknownst to said government funding agencies with no supervision and little if any contact
2 putting plaintiffs at risk at foreseeable harm as opposed to immediate removal mandated by law knowing or
3
141
5
federal state and county payments for plaintiffs JONES JONES and DYSON placement on pretext
6
defendants
to
Facility
10
Facility
3 were certified
142
g
9
and
143
11
89234 d
and
89361
by failing
of
the relocation to
Facility
12
Woodworth
13
144
14
15
g9218
16
by failing
145
to
submit an application
scenario
for
in
approval on
76
1l l
Facility
with regard
to
uncertified
Facility
Dulce
17
and
112
141
with regard
to
uncertified
3 Pool
Facility
18
4 Woodworth
19
issue a Certificate
of
Approval
on
Facility
20
could not
21
defendants OATES WILSON were not in compliance with licensing regulations defendant Interim made
22
no site visit provided no supervision little if any contact putting plaintiffs JONES JONES and DYSON
23
at risk of foreseeable harm as opposed to immediate removal mandated by law knowirig or should know
24
25
26
27 from the U S Department of Health and Human Services California Department of Social Services and
28 San Bernadino Department of Social Services for plaintiffs JONES JONES and DYSON s placement in
28
COMPLAINT
Facility
uncertified
4 in
violation
of H
2 funding agencies with no supervision and little if any contact putting plaintiffs at risk of foreseeable harm
3
as opposed to immediate removal mandated by law knowing or should know plaintiffs suffered ongoing
4
abuse and neglect
5
147
malfeasance based on payments from U S Department of Health and Human Services California
g Department of Social Services and San Bernadino Department of Social Services for plaintiffs JONES
9
10
JONES
and
DYSON
s placement
in
uncertified
Facility
4 in
violation of
unbeknownst to said government funding agencies with no supervision and little if any contact putting
1T
plaintiffs at risk of foreseeable harm as opposed to immediate removal mandated by law knowing or
12
13
14
15 BHUPINDER CHHUDU continued to breach mandatory statutory duties imposed by Section 88063 c
16
2 by approving and monitoring a budget for defendant Interim based on payments from the U S
17
Department of Health and Human Services California Department ofSocial Services and San Bernadino
18
Department of Social Services for plaintiffs JONES JONES and DYSON s placement in uncertified
19
20
Facility
4 in
violation of
21 with no supervision and little if any contact putting plaintiffs at risk of foreseeable harm as opposed to
22
immediate removal mandated by law knowing or should know plaintiffs suffered ongoing abuse and
23
neglect
24
149
25
26 BHUPINDER CHHUDU continued to breach mandatory statutory duties imposed by Section 88063 c
27
3 by approving and monitoring a budget to cover operation costs based on payments from the U S
g Department of Health and Human Services California Department ofSocial Services and San Bernadino
29
COMPLAINT
1 Department of Social Services for plaintiffs JONES JONES and DYSON s placement in uncertified
4 in
Facility
with no supervision and little if any contact putting plaintiffs at risk of foreseeable harm as opposed to
violation of
immediate removal mandated by law knowing or should know plaintiffs suffered ongoing abuse and
5
neglect
150
g BHUPINDER CHHUDU continued to breach mandatory statutory duties imposed by Section 88063 c
9
10
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 California Department of Social
11
Services and San Bernadino Department of Social Services for plaintiffs JONES JONES and DYSON s
12
placement
13
in
uncertified
Facility
4 in
violation
of H
14 government funding agencies with no supervision and little if any contact putting plaintiffs at risk of
15 foreseeable harm as opposed to immediate removal mandated by law knowing or should know plaintiffs
16
suffered ongoing abuse and neglect
17
151
18
19
BHUPINDER CHHUDU continued to breach mandatory statutory duties imposed by Sections 80000 1 3
88018
by operating
uncertified
Facility
4 Woolworth
in
violation of
20
and
21
unbeknownst to said governmental funding agencies with no supervision and little if any contact putting
22
plaintiffs JONES JONES and DYSON at risk of foreseeable harm as opposed to immediate removal
23
mandated by law knowing or should know plaintiffs suffered ongoing abuse and neglect
24
152
25
26
27
28
JONES
and
Woodworth
DYSON
health
in violation
of
morals
welfare
and
safety
by
operating
uncertified Facility
funding agencies with no supervision and little if any contact putting plaintiffs at risk of foreseeable harm
30
COMPLAINT
as opposed to immediate removal mandated by law knowing or should know plaintiffs suffered ongoing
153
by obtaining federal state and county payments for plaintiffs JONES JONES and DYSON s foster care
5
on pretext
defendants
uncertified
OATES WILSON
Facility
and uncertified
Woodworth were
g
9
10
nonpayment of rent
3 534 96
on
Facility
California 92342
11
155
12
13
OATES WILSON
156
14
resided
in
uncertified
Facility
4 Woodworth
were evicted
from
1 13945 Topmast
Facility
157
s eviction
from
Facility
13945 Topmast
17
Drive
while also
residing in
uncertified
Facility
Woodworth
18
under Section 88061
19
158
20
21
22
88061
by failing
to report
eviction
from
Facility
13945 Topmast
23
159
24
defendants OATES WILSON for
nonpayment of rent
4 870 00
on uncertified
Facility
25
26
27
28
Woodworth
160
DYSON
were evicted
from
uncertified
Facility
31
COMPLAINT
4 870 00 unbeknownst to the above alleged governmental funding agencies due to financial
of rent
5
161
and
DYSON
s eviction
from
uncertified
Facility
6
Woodworth
162
11166
nonpayment of
rent
4 and
Inst Code Section 300 b reportable under Penal Code Section 11166
Wel
9
10
for
Defendant Interim breached mandatory statutory duties imposed by Penal Code Section
by failing
to report plaintiffs
JONES 70NES
and
DYSON
s eviction
from
Facility
11
Woodworth
12
163
13
14
15
11166
Defendant Interim s breach of mandatory statutory duties imposed by Penal Code Section
by failing
to report plaintiffs
JONES JONES
and
DYSON
s eviction
from
uncertified
Facility
Woodworth was a serious deficiency under Section 89201 s 1 that caused plaintiffs to remain in the
16
custody
ofuncertified
of
17
supervision and little if any contact putting plaintiffs at risk of foreseeable harm as opposed to immediate
18
19
20
21
22
removal mandated by law knowing or should know plaintiffs suffered ongoing abuse and neglect
164
Plaintiffs JONES JONES DYSON and defendants OATES WILSON s eviction from
unauthorized uncertified
Facility
defendants directors FREDDIE WILSON AJAY MALHOTRA BHUPINDER CHHUDU defendant CEO
23
WILSON constituted an unusual incident under Section 88061 4 and a serious deficiency under Section
25
26 89201 s 1
27
28
165
failing to report to the Department that plaintiffs JONES JONES and DYSON were evicted from
32
COMPLAINT
1
2
3
166
failing
to
4 Woodworth
Facility
uncertified
report plaintiffs
JONES JONES
and
DYSON
s eviction
from
uncertified
Facility
Woodworth was a serious deficiency under Section 89201 s 1 that caused plaintiffs to remain in the
5
custody
of uncertified
violation of
supervision and little if any contact putting plaintiffs at risk of foreseeable harm as opposed to immediate
g removal mandated by law knowing or should know plaintiffs suffered ongoing abuse and neglect
9
10
Defendant Interim
167
notify CPS
breach
JONES JONES
of plaintiffs
of
and
mandatory statutory
DYSON
s eviction
duty imposed by
from
Facility
Section 89206
to
Woodworth
11
constituted a serious deficiency under Section 89201 s 1 that caused plaintiffs to remain in the custody
12
13
of uncertified
violation of
14 and little if any contact putting plaintiffs at risk of foreseeable harm as opposed to immediate removal
15 mandated by law knowing or should know plaintiffs suffered ongoing abuse and neglect
16
168
17
Facility
18
169
19
20
21
Sections 89234 d
and
89361
by failing
to notify
defendant Interim
of
the move to
Facility
Silversand
22
170
23
Section 89218
by failing to
submit an application
for
approval on
Facility
Silversand
24
171
scenario
in
79
111
with regard
to
uncertified
Facility
25
26
Dulce
112
141
uncertified
Facility
Pool
Silversand
158
uncertified
28
uncertified
Facility
33
COMPLAINT
Facility
4 Woodworth
27
to
142
by
operating
Facility
2 supervision little if any contact putting plaintiffs JONES JONES and DYSON at risk of foreseeable
3 harm as opposed to immediate removal mandated by law knowing or should know plaintiffs suffered
4
ongoing abuse and neglect
5
172
payments from the U S Department of Health and Human Services California Department of Social
g
Services
in
10
and
violation of
children placed
in
uncertified
Facility
supervision or contact putting the children at risk of foreseeable harm as opposed to immediate removal
11
mandated by law knowing or should know plaintiffs suffered ongoing abuse and neglect
12
173
13
14 malfeasance based on payments from the U S Department of Health and Human Services California
15 Department of Social Services and San Bernadino Department of Social Services for children placed in
16
uncertified
Facility
5 in
violation of
17
funding agencies with no supervision or contact putting the children at risk of foreseeable harm as
18
19
20
opposed to immediate removal mandated by law knowing or should know plaintiffs suffered ongoing
abuse and neglect
21
22
CHHUDU
continued to
by
Section 88063
2 by approving
23
and monitoring a budget based on payments from the U S Department of Health and Human Services
24
California Department of Social Services and San Bernadino Department of Social Services for children
25
26
placed
in
uncertified
Facility
5 in
violation of
27 government funding agencies with no supervision or contact putting the children at risk of foreseeable
28 harm as opposed to immediate removal mandated by law knowing or should know plaintiffs suffered
34
COMPLAINT
175
by
Section 88063
3 by approving
and monitoring a budget to cover operation costs based on payments from the U S Department of Health
5
arid Human Services California Department of Social Services and San Bernadino Department of Social
6
Services for foster
care provided
in
uncertified
Facility
5 in
violation of
g unbeknownstto said government funding agencies with no supervision or contact putting the children at
9
risk of foreseeable harm as opposed to immediate removal mandated by law knowing or should know
10
12
13
CHHUDU
continued
by
Section 88063
3 by accessing
14 and maintaining defendant Interim s level of funding to cover operation costs based on payments from the
15
16
U S Department of Health and Human Services California Department of Social Services and San
Bernadino Department
of
care
in
uncertified
Facility
5 in
violation of
17
Code Section 1508 unbeknownst to said government funding agencies with no supervision or contact
18
19 putting the children at risk of foreseeable harm as opposed to immediate removal mandated by law
20 knowing or should know plaintiffs suffered ongoing abuse and neglect
21
22
177
CHHLJDU continued to breach mandatory statutory duties imposed by Sections 80000 1 3 and 88018 by
23
operating
uncertified
Facility
Silversand in
violation of
24
25
the above alleged governmental funding agencies with no supervision or contact putting the children at
26 risk of foreseeable harm as opposed to immediate removal mandated by law knowing or should know
27 plaintiffs suffered ongoing abuse and neglect
28
178
35
COMPLAINT
1 in or about 3 09 by holding out uncertified defendants OATES WILSON and uncertified Facility 5
2
179
4
S ADAMS 2 8 94 in
uncertified
Facility
Silversand
Defendants Interim knew or should have known shortly after placement that plaintiffs
180
6
ADAMS
g
9
10
were violated
assaulted
by
by
uncertified
Sections 89372 1
defendant Oates
adult son
Dwayne
including but
not
10
limited to
11
16
20
23
1 sexually
floors lift rugs move and replace furniture clean toilets kitchen
11
3 not allowed to eat the same food as defendants OATES WILSON family
deprivation
causing sleep
12
13
14 in
15
16
not allowed
to
eat at
constant state of
hunger
suffered
sleep deprivation
abuse
9 witnessed the
17
181 Defendant Interim continued to engage in acts of financial malfeasance based on payments
18
from the U S Department of Health and Human Services California Department of Social Services and
19
Department
20 San Bernadino
21
22
in
violation of
of
plaintiffs
ADAMS
placement
in
uncertified
Facility
supervision and little if any contact putting plaintiffs ADAMS ADAMS JONES JONES and DYSON
23
among others at foreseeable risk of harm as opposed to immediate removal mandated by law knowing or
24
25
26
27 malfeasance based on payments from the U S Department of Health and Human Services California
28 Department of Social Services and San Bernadino Department of Social Services for plaintiffs ADAMS
36
COMPLAINT
placement
in
uncertified
Facility
5 in
violation of
2 government funding agencies with no supervision and little if any contact putting plaintiffs ADAMS
3 ADAMS JONES JONES and D YSON among others at risk of foreseeable harm as opposed to
4
immediate removal mandated by law knowing or should know plaintiffs suffered ongoing abuse and
5
neglect
6
183
g BHUPINDER CHHUDU continued to breach mandatory statutory duties imposed by Section 88063 c
9
10
2 by approving and monitoring a budget based on payments from the U S Department of Health and
Human Services California Department of Social Services and San Bernadino Department of Social
11
Services for
plaintiffs
ADAMS
placement
in
uncertified
Facility
5 in
violation of
S Code Section
12
13
1508 unbeknownst to said government funding agencies with no supervision and little if any contact
14 putting plaintiffs ADAMS ADAMS JONES JONES and DYSON among others at risk of foreseeable
15 harm as opposed to immediate removal mandated by law knowing or should know plaintiffs suffered
16
ongoing abuse and neglect
17
184
18
CHHUDU
continued to
19
3 by approving
20 and monitoring a budget to cover operating costs based on payments from the U S Department of Health
21
22
and Human Services California Department of Social Services and San Bernadino Department of Social
Services for
plaintiffs
ADAMS
placement
in
uncertified
Facility
5 in
violation of
S Code Section
23
1508 unbeknownst to said government funding agencies with no supervision and little if any contact
24
25
putting plaintiffs ADAMS ADAMS JONES JONES and DYSON among others at risk of foreseeable
26 harm as opposed to immediate removal mandated by law knowing or should know plaintiffs suffered
27 ongoing abuse and neglect
28
185
37
COMPLAINT
1
2
BHUPINDER CHHUDU continued to breach mandatory statutory duties imposed by Section 88063 c
3 by accessing and maintaining defendant Interim s level of funding based on payments the U S
3 Department of Health and Human Services California Department of Social Services and San Bernadino
4
Department
of
plaintiffs
ADAMS
placement
in
uncertified
Facility
5 in violation of
5
H
S Code Sectiori 1508 unbeknownst to said governmerit funding agencies with no supervision and
little if any contact putting plaintiffs ADAMS ADAMS JONES JONES and DYSON among others at
g risk of foreseeable harm as opposed to immediate removal mandated by law knowing or should know
9
10
186
11
CHHUDU continued to breach mandatory statutory duties imposed by Sections 80000 1 3 and 88018 by
12
13
operating
uncertified
Facility
Silversand
in
violation of
14 the governmental funding agencies alleged herein with no supervision and little if any contact putting
15 plaintiffs ADAMS ADAMS JONES JONES and DYSON among others at risk of foreseeable harm as
16
opposed to immediate removal mandated by law knowing or should know plaintiffs suffered ongoing
17
abuse and neglect
18
187
19
20
M GALVAN in
uncertified
5 Silv ersand
Facility
in
violation of
188
Deferidant Interim knew or should know that shortly after placement plaintiffs GALVANS
23
personal rights under
Sections 89372 1
10
11
16
20
23 were
24
26
violated
by
plaintiff
S GALVAN S
25
uncertified
sexual
abuse
including
but
not
uncertified
limited to
Facility
5 Silversand in addition to
27 vacuum and sweep floors lift rugs move arid replace furniture clean toilets kitchen and bedrooms
28
nightly
not allowed
to
food
as
38
COMPLAINT
family
not allowed to
1
2
3
eat at
prohibited
defendants Oates
from opening
abuse
the
and
refrigerator
Wilson
or
deprived
of adequate
food
5 sleep deprivation
8 witnessing the abuse and neglect of plaintiffs JONES JONES and DYSON
4
among others
189
from the U S Department of Health and Human Services California Department of Social Services and
g San Bernadino Department of Social Services for plaintiffs GALVANS placement in uncertified Facility
9
10
5 in
violation of
supervision and little if any contact putting plaintiffs GALVAN GALVAN JONES JONES and
11
DYSON among others at risk of foreseeable harm as opposed to immediate removal mandated by law
12
13
14
190
15 malfeasance based on payments from the U S Department of Health and Human Services California
16
Department of Social Services and San Bernadino Department of Social Services for plaintiffs
17
GALVANS
placement
in
uncertified
Facility
5 in
violation of
18
19
to said government funding agencies with no supervision and little if any contact putting plaintiffs
20 GALVAN GALVAN JONES JONES and DYSON among others at risk offoreseeable harm as
21
opposed to immediate removal mandated by law knowing or should know plaintiffs suffered ongoing
22
abuse and neglect
23
191
24
CHHUDU
continued
25
by
Section 88063
2 by approving
26 and monitoring a budget for defendant Interim based on payments from the U S Department of Health and
27 Human Services California Department of Social Services and San Bernadino Department of Social
28
Services for
plaintiffs
GALVANS
placement
in
uncertified
39
COMPLAINT
Facility
5 in
violation of
S Code
Section 1508 unbeknownst to said government funding agencies with no supervision and little if any
2 contact putting plaintiffs GALVAN GALVAN JONES JONES and DYSON among others at risk of
3 foreseeable harm as opposed to immediate removal mandated by law knowing or should know plaintiffs
4
suffered ongoing abuse and neglect
5
192
6
CHHUDU
continued to
by
Section 88063
3 by approving
g and monitoring a budget to cover operation costs based on payments from the U S Department of Health
9
10
and Human Services California Department of Social Services and San Bernadino Department of Social
Services for
plaintiffs
GALVANS
placement
in
uncertified
Facility
5 in
violation of
S Code
11
Section 1508 unbeknownst to said government funding agencies with no supervision and little if any
12
13
contact putting plaintiffs GALVAN GALVAN JONES JONES and DYSON among others
14 at risk of foreseeable harm as opposed to immediate removal mandated by law knowing ar should know
15 plaintiffs suffered ongoing abuse and neglect
16
193
17
CHHUDU
continued
by
Section 88063
3 accessing and
18
19
maintaining defendant Interim s level of funding based on payments from the U S Department of Health
20 and Human Services California Department of Social Services and San Bernadino Department of Social
21
22
Services for
plaintiffs
GALVANS
placement
in
uncertified
Facility
5 in
violation of
S Code
Section 1508 unbeknownst to said government funding agencies with no supervision and little if any
23
contact putting plaintiffs GALVAN GALVAN JONES JONES and DYSON among others at risk of
24
25
foreseeable harm as opposed to immediate removal mandated by law knowing or should know plaintiffs
194
28 CHHUDU continued to breach mandatory statutory duties imposed by Sections 80000 1 3 and 88018 by
40
COMPLAINT
operating
uncertified
Facility
Silversand in
violation of
2 supervision and little if any contact putting plaintiffs GALVAN GALVAN JONES JONES and
3 DYSON among others at risk of foreseeable harm as opposed to immediate removal mandated by law
4
6
GALVAN
were evicted
from
uncertified
Facility
Silversand
196
10
defendants OATES WILSON
out of uncertified
Facility
11
permitting plaintiffs five minutes to retrieve few if any personal belongings carried away in plastic bags
12
197
13
14
15
198
16
eviction
from
uncertified
Facility
17
homelessness was due to financial malfeasance of defendants Interim directors FREDDIE WILSON
18
19
199
and
GALVAN
s eviction
from
uncertified
Facility
for nonpayment of rent and homelessness for five months was child abuse under Health and Safety Code
23
Section 1531 5
and
Welf
Inst Code Section 300 b reportable under Penal Code Section 11166
24
200
25
Defendant Interim breached mandatory statutory duties imposed by Penal Code Section
26
11166 by failing to report plaintiffs JONES JONES DYSON and GALVAN s eviction from uncertified
27
Facility
5 and homelessness causing plaintiffs to remain homeless in the custody of homeless uncertified
28 defendants OATES WILSON with no supervision and little if any contact putting plaintiffs at risk of
41
COMPLAINT
foreseeable harm as opposed to immediate removal mandated by law knowing or should know plaintiffs
201
Defendant Interim s breach of mandatory statutory duties imposed by Penal Code Section
11166 by failing to report plaintiffs JONES JONES DYSON and GALVAN s eviction from uncertified
5
Facility
1 causing plaintiffs to
remain homeless in the custody of homeless uncertified defendants OATES WILSON with no supervision
and little if any contact putting plaintiffs at risk of foreseeable harm as opposed to immediate removal
9
mandated by law knowing or should know plaintiffs suffered ongoirig abuse and neglect
10
202
Plaintiffs
JONES JONES
11
from
uncertified
Facility
12
13
defendants directors FREDDIE WILSON AJAY MALHOTRA and BHUPINDER CHHUDU defendant
14 CEO SUKHWINDER SINGH and defendants Oates Wilson constituted an unusual incident under Section
203
17
failing to report plaintiffs JONES JONES DYSON and GALVAN s eviction from uncertified Facility
18
19
20
21
22
5 homelessness no supervision and little if any contact causing plaintiffs to remain homeless with
uncertified
violation of
unbeknownst to said government funding agencies with no supervision and little or no contact putting
plaintiffs at risk of foreseeable harm as opposed to immediate removal mandated by law knowing or
23
26 failure to report plaintiffs JONES JONES DYSON and GALVAN s eviction and homelessness was a
27
28
serious deficiency under Section 89201 s 1 that caused plaintiffs to remain homeless with uncertified
homeless defendants OATES WILSON in
violation of
q2
COMPLAINT
little if any contact putting plaintiffs at risk of foreseeable harm as opposed to immediate removal
2 mandated by law knowing or should know plaintiffs suffered ongoing abuse and neglect
3
205
failing to notify CPS of plaintiffs JONES JONES DYSON and GALVAN s eviction and homelessness
5
6
the
custody
of uncertified
violation of
S Code Section
1508 with no supervision and little if any contact putting plaintiffs at risk of foreseeable harm as opposed
9 to immediate removal mandated by law knowing or should know plaintiffs suffered ongoing abuse and
10
neglect
11
206
12
13
from the U S Department of Health and Human Services California Department of Social Services and
14 San Bernadino Department of Social Services for plaintiff GALVAN s placement in a purported certified
15 facililty while plaintiffs GALVAN JONES JONES and DYSON were homeless in the custody of
16
homeless
uncertified
violation of
17
to said government funding agencies with no supervision and little if any contact putting plaintiffs at risk
18
19
20
21
22
of foreseeable harm as opposed to immediate removal mandated by law knowing or should know plaintiffs
suffered ongoing abuse and neglect
207
malfeasance based on payments from the U S Department of Health and Human Services California
23
Department of Social Services and San Bernadino Department of Social Services for plaintiff GALVAN s
24
25
26
placement in a purported certified facility while plaintiffs GALVAN JONES JONES and DYSON were
homeless
in the custody
of
homeless
uncertified
violation of
S Code
27 Section 1508 unbeknownst to said government funding agencies with no supervision and little if any
28
contact putting plaintiffs at risk of foreseeable harm as opposed to immediate removal mandated by law
43
COMPLAINT
2
3
208
by Section
88063
2 by approving
and monitoring a budget based on payments from the U S Department of Health and Human Services
5
California Department of Social Services and San Bernadino Department ofSocial Services for plaintiff
6
GALVAN s placement in a purported certified home whereas plaintiff was homeless in violation of H
g S Code Section 1508 unbeknownst to said governrnent funding agencies with no supervision and little if
9
any contact putting plaintiffs M GALVAN JONES JONES and DYSON M GALVAN at risk of
10
foreseeable harm as opposed to immediate removal mandated by law knowing or should know plairitiffs
11
suffered ongoing abuse and neglect
12
209
13
14
WILSON
15
16
moved
210
g9234 d
to
Facility
and
89361
by failing to riotify
Facility
Snowview
17
211
18
19
g9218
212
20
21
22
by failing to
Dulce
112
Facility
submit an application
141 with
regard
Woodworth
168
for
approval on
scenario alleged
to uncertified
186 with
in
Facility
regard
to
Facility
79
111
Pool
uncertifiecl
6 Snowview
with regard
142
Facility
to
uncertified
Facility
23
regard
to
uncertified
Facility
Snowview
24
25
26
failing
to issue
Certificate
of
Approval
on
Facility
6 Silversand
by
27 provided no supervision little if any contact putting plaintiffs JONES JONES and DYSON at risk of
28 foreseeable harm as opposed to immediate removal mandated by law knowing or should know plaintiffs
44
COMPLAINT
213
3 from the U S Department of Health and Human Services California Department of Social Services and
4
San Bernadino Department of Social Services for plaintiff GALVAN s placement in uncertified Facility
5
6 in
violation of
supervision and little if any contact putting plaintiffs GALVAN JONES JONES and DYSON among
g others at risk of foreseeable harm as opposed to immediate removal mandated by law knowing or should
11
malfeasance by payments from the U S Department of Health and Human Services California Department
12
13
f Social Services and San Bernadino Department of Social Services for plaintiff GALVAN s placement
14 in
uncertified
Facility
6 in
violation of
15 funding agencies with no supervision and little if any contact putting plaintiffs GALVAN JONES
16
JONES and DYSON among others at risk of foreseeable harm as opposed to immediate removal
17
mandated by law knowing or should know plaintiffs suffered ongoing abuse and neglect
18
19
215
CHHUDU
21
and monitoring a budget for defendant Interim based on payments from the U S Department of Health and
22
continued to
Section 88063
20
by
2 by approving
Human Services California Department of Social Services and San Bernadino Department of Social
23
Services for
plaintiff
GALVAN
s placement
in
uncertified
Facility
6 in
violation of
S Code Section
24
25
1508 unbeknownst to said government funding agencies with no supervision and little if any contact
26 putting plaintiffs GALVAN JONES JONES and DYSON among others at risk of foreseeable harm as
27 opposed to immediate removal mandated by law knowing or should know plaintiffs suffered ongoing
28
45
COMPLAINT
r ri
1
2
3
216
CHHUDU
continued to
by
Section 88063
3 by approving
and monitoring a budget to cover operation costs based on payments from the U S Department of Health
4
and Human Services California Department of Social Services and San Bernadino Department of Social
5
Services for
plaintiff
GALVAN
s placement
in
uncertified
6 in
Facility
violation of
S Code Section
1508 unbeknownst to said government funding agencies with no supervision and little if any contact
g putting plaintiffs GALVAN JONES JONES and DYSON among others at risk of foreseeable harm as
9
opposed to immediate removal mandated by law knowing or should know plaintiffs suffered ongoing
10
abuse and neglect
11
217
12
13
CHHUDU
continued to
by
Section 88063
3 by accessing
14 and maintaining defendant Interim s level of funding to cover operation costs based on payments from the
15 the U S Department of Health and Human Services California Department of Social Services and Sari
16
Bernadino Department
of
plaintiff
GALVAN
s placement
in
uncertified
Facility
6 in
17
violation of
18
19
supervision and little if any contact putting plaintiffs GALVAN JONES JONES and DYSON among
20 others at risk of foreseeable harm as opposed to immediate removal mandated by law knowing or should
21
22
23
CHHUDU continued to breach mandatory statutory duties imposed by Sections 80000 1 3 and 88018 by
24
25
operating
uncertified
Facility
Snowview
in
violation of
26 governmental funding agencies with no supervision and little if any contact putt ing plaintiffs GALVAN
27 JONES JONES and DYSON among others at risk of foreseeable harm as opposed to immediate removal
28
mandated by law knowing or should know plaintiffs suffered ongoing abuse and neglect
46
COMPLAINT
219
1
2
operating
uncertified
220
Facility
Snowview
in
violation of
by taking
federal
state
and
county
payments
for
plaintiff
GALVAN
foster
care
in
uncertified
Facility
5
Snowview
in
violation of
6
On
221
Snowview
222
1 25 10 defendant Interim
or about
defendants Oates
with uncertified
and
placed plaintiff
Wilson in
SAIS in
violation of
uncertified
Facility
Defendant Interim knew or should have known shortly after placement that plaintiffSAIS
10
personal rights under sections
89372 1
10
11
16
20
23
were
11
violated
in
Facility
Snowview
including but
not
limited to
12
and
13
14
15
rugs
food
allowed
table as
defendants 0ates
16
prohibited
from opening
as
and
the
furniture
defendants Oates
Wilson
refrigerator
or
and
clean
Wilson
toilets
kitchen
family
and
bedrooms nightly
not
suffered
sleep deprivation
17
physical and mental abuse
8 witnessed the abuse and neglect of plaintiffs JONES JONES and DYSON
18
19
20
21
22
among
others
223
from the U S Department of Health and Human Services California Department of Social Services and
San Bernadino Department
of
plaintiff
SAIS
placement
in
uncertified
Facility
6 in
23
violation of
24
25
supervision and little if any contact putting plaintiffs SAIS JONES JONES and DYSON among others
26 at risk of foreseeable harm as opposed to immediate removal mandated by law knowing or should know
27 plaintiffs suffered ongoing abuse and neglect
28
224
47
COMPLAINT
r
1
malfeasance based on payments from the U S Department of Health and Human Services California
2 Department of Social Services and San Bernadino Department of Social Services for plaintiff SAIS
3
placement
in
uncertified
Facility
6 in
violation of
government funding agencies with no supervision and little if any contact putting plaintiffs SAIS
5
6
JONES JONES and DYSON among others at risk of foreseeable harm as opposed to immediate removal
mandated by law knowing or should know plaintiffs suffered ongoing abuse and neglect
225
CHHUDU
continued
to
by
Section 88063
2 by approving
10
and monitoring a budget based on payments obtained from the U S Department of Health and Human
11
Services California Department of Social Services and San Bernadino Department of Social Services for
12
13
SAIS
plaintiff
foster
care provided
in
uncertified
Facility
6 in
violation of
14 unbeknownst to said government funding agencies with no supervision and little if any contact putting
15 plaintiffs SAIS JONES JONES and DYSON among others at risk of foreseeable harm as opposed to
16
immediate removal mandated by law knowing or should know plaintiffs suffered ongoing abuse and
17
neglect
18
19
226
20 CHHUDU
21
22
continued to
by
Section 88063
3 by approving
and monitoring a budget to cover operation costs based on payments from the U S Department of Health
and Human Services California Department of Social Services and San Bernadino Department of Social
23
Services for
plaintiff
SAIS foster
care provided
in
uncertified
Facility
6 in
violation of
S Code
24
25
Section 1508 unbeknownst to said government funding agencies with no supervision and little if any
26 contact putting plaintiffs SAIS JONES JONES and DYSON among others at risk of foreseeable harm as
27 opposed to immediate removal mandated by law knowing or should know plaintiffs suffered ongoing
28
4s
COMPLAINT
2
3
227
CHHUDU
continued to
by
Section 88063
3 by accessing
and maintaining defendant Interim s level of funding to cover operation costs based on payments from the
4
the U S Department of Health and Human Services California Department of Social Services and San
5
Bernadino Department
of
plaintiff
SAIS
placement
in
uncertified
Facility
6 in
6
violation of
supervision and little if any contact putting plaintiffs SAIS JONES JONES and DYSON among others
9
at risk of foreseeable harm as opposed to immediate removal mandated by law knowing or should know
10
plaintiffs suffered ongoing abuse and neglect
ll
Defendants directors FREDDIE WILSON AJAY MALHOTRA and BHUPINDER
228
12
13
CHHUDU continued to breach mandatory statutory duties imposed by Sections 80000 1 3 and 88018 by
14 operating
uncertified
Facility
Snowview
in
violation of
15 governmental funding agencies alleged herein with no supervision and little if any contact putting
16
plaintiffs SAIS JONES JONES and DYSON among others at risk of foreseeable harm as opposed to
17
immediate removal mandated by law knowing or should know plaintiffs suffered ongoing abuse and
18
neglect
19
229
20
21
Administrator
22
230
operate uncertified
Facility
6 Snowview
23
certified
in breach
of
by
24
25
governmental funding agencies alleged herein with no supervision and little if any contact putting
26 plaintiffs SAIS JONES JONES and DYSON among others at risk of foreseeable harm as opposed to
27 immediate removal mandated by law knowing or should know plaintiffs suffered ongoing abuse and
28
neglect
49
COMPLAINT
as
On 12 8 10 unlawful detainer Case No UDVS 1004160 was filed against defendants Oates
231
1
and
Wilson
on uncertified
232
On 2 23 11
Facility
Snowview
4
were evicted
from
uncertified
Facility
Defendants OATES WILSON plaintiffs JONES JONES DYSON and SAIS eviction
g for nonpayment of rent was due to financial malfeasance of defendants Interim directors FREDDIE
12
13 Code Section 11166 by failing to report plaintiffs JONES JONES DYSON SAIS eviction from
14
Facility
uncertified
Snowview
15
235
16
1
18
19
By failing
Defendant Interim s breach of mandatory duties imposed by Penal Code Section 11166
to report plaintiffs
violation of
eviction
from
uncertified
Facility
20
and little if any contact putting plaintiffs SAIS JONES JONES and DYSON among others at risk of
21
22
23
foreseeable harm as opposed to immediate removal mandated by law knowirig or should know plaintiffs
suffered ongoing abuse and neglect
24
236
Plaintiffs
25
26
from
unauthorized
uncertified
Facility
50
COMPLAINT
Wilson constituted an unusual incident under Section 88061 4 and a serious deficiency under Section
89201 s
3
237
failing
to report plaintiffs
and
SAIS
eviction
from
uncertified
Facility
6
7
Snowview
238
9 88061 by failure to report plaintiffs JONES JONES DYSON and SAIS eviction from uncertified
10
Facility
Snowview
was a
serious
deficiency
under
Section 89201
11
remain with uncertified
violation of
12
13
supervision and little if any contact putting plaintiffs SAIS JONES JONES and DYSON among others
14
at risk of foreseeable harm as opposed to immediate removal mandated by law knowing or should know
15
16
239
by
Section 89206
by
failing to
notify CPS
of plaintiffs
and
SAIS
eviction
from
Facility
18
19
uncertified
20
21
violation of
and little if any contact putting plaintiffs SAIS JONES JONES and DYSON among others at risk of
22 foreseeable harm as opposed to immediate removal mandated by law knowing or should know plaintiffs
23
suffered ongoing abuse and neglect
24
240
In 3 11
plaintiffs JONES
25
moved
26
27
28
to
Facility
241
7 on Bluegrass in Victorville
Defendants knew or should have known after placement that plaintiffs JONES JONES
DYSON SAIS
89372 1
51
COMPLAINT
10
11
16
1
2
3
20
23
were violated
including
replace
but
not
furniture
by
defendants Oates
uncertified
limited to
and
Wilson in
uncertified
Facility
7 Bluegrass
1 forced to scrub walls floors vacuum and sweep floors lift rugs move and
kitchen
clean toilets
and
bedrooms nightly
4
defendants OATES WILSON
family
5
4
OATES WILSON
deprived
food
of adequate
suffered
6
the
opening
g
9
abuse
refrigerator or
witnessed
sleep deprivation
6 prohibited from
JONES JONES
and
DYSON among
others
10
242 Defendants OATES WILSON breached mandatory statutory duties imposed by Sections
11
89234 d
and
89361
by failing
of
the
move
to
uncertified
Facility
12
13
Bluegrass
243
14
15
g9218
16
by failing
244
to submit an application
for
approval on
scenario alleged
79
in
Facility
111
Bluegrass
with regard
to uncertified
Facility
17
Dulce
112
141
Facility
Pool
142
158
Facility
4 Woodworth
168
186 Facility
18
5 Silversand
209 231
19
20
21
22
Bluegrass
of
Approval
little if any
Facility
Snowview
to uncertified
Facility
Defendant Interim s administrator defendant JOEL DOMINGUEZ did not issue a Certificate
on
Facility
contact
7 Bluegrass
putting
plaintiffs
SAIS
23
knowing or should know plaintiffs suffered ongoing abuse and neglect as opposed to immediate removal
24
25
26
27
28
mandated by law
245
from the U S Department of Health and Human Services California Department of Social Services and
San Bernadino Department
of
plaintiff
SAIS
52
COMPLAINT
placement
in
uncertified
Facility
7 in
violation of
2 supervision and little if any contact putting plaintiffs SAIS JONES JONES and DYSON among others
3
at risk of foreseeable harm as opposed to immediate removal mandated by law knowing or should know
4
plaintiffs suffered ongoing abuse and neglect
5
246
6
malfeasance based on payments from the U S Department of Health and Human Services California
g
9
Department of Social Services and San Bernadino Department of Social Services for plaintiff SAIS
placement
in
uncertified
Facility
7 Bluegrass
in
violation of
10
said government funding agencies with no supervision and little if any contact putting plaintiffs SAIS
11
JONES JONES and DYSON among others at risk of foreseeable harm as opposed to immediate removal
12
13
mandated by law knowing or should know plaintiffs suffered ongoing abuse and neglect
247
14
15
CHHUDU
continued
by
Section 88063
2 by approving
16
and monitoring a budget for defendant Interim based on payments from the U S Department of Health and
17
Human
ervices California Department of Social Services and San Bernadino Department of Social
18
Services for
plaintiff
SAIS
placement
in
uncertified
19
20 H
21
Facility
7 Bluegrass
in violation of
S Code Section 1508 unbeknownst to said government funding agencies with no supervision and
little if any contact putting plaintiffs SAIS JONES JONES and DYSON among others at risk of
22
foreseeable harm as opposed to immediate removal mandated by law knowing or should know plaintiffs
23
suffered ongoing abuse and neglect
24
248
25
26
CHHUDU
to
duties
imposed
by
Section 88063
3 by approving
27 and monitoring a budget to cover operation costs based on payments from the U S Department of Health
28
and Human Services California Department of Social Services and San Bernadino Department of Social
53
COMPLAINT
1
2
Services for
plaintiff
SAIS
placement
in
uncertified
Facility
Bluegrass
in violation of
S Code Section 1508 unbeknownst to said government funding agencies with no supervision and
3 little if any contact putting plaintiffs SAIS JONES JONES and DYSON among others at risk of
4
foreseeable harm as opposed to immediate removal mandated by law knowing or should know plaintiffs
5
6
9
10
continued to
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 California Department of Social Services and San
11
Bernadino Department
of
plaintiff
SAIS
placement
in
uncertified
Facility
12
13
14
15
16
Bluegrass
in
violation of
ith no supervision and little if any contact putting plaintiffs SAIS JONES JONES and DYSON
ong others at risk of foreseeable harm as opposed to immediate removal mandated by law knowing or
should know plaintiffs suffered ongoing abuse and neglect
17
250
18
CHHUDU
continued to
19
20 operating
21
22
uncertified
Facility
Bluegrass
in
violation of
by
Sections 80000 1
3 and 88018 by
governmental funding agencies alleged herein with no supervision and little if any contact putting
plaintiffs SAIS JONES JONES and DYSON among others at risk of foreseeable harm as opposed to
23
immediate removal mandated by law knowing or should know plaintiffs suffered ongoing abuse and
24
neglect
25
251
26
27 illegal
28
uncerti ced
Facility
7 Bluegrass in
violation of
54
COMPLAINT
1
2
3
taking federal
state
and
county
payments
for
plaintiff
SAIS
foster
care
in
uncertified
Facility
4
253
On 3 4 11 the state licensed defendant OATES to operate a family child care home at the
5
same
location
as uncertified
Facility
6
operated at least six uncertified homes since 6 07 with four evictions and five months homeless due to
254
10
administrator
11
255
Defendant RAMNIT continued to hold out uncertified defendants OATES WILSON to the
12
13
14
placement CPS as certified in breach of mandatory statutory duties imposed by Section 89250 to procure
and maintain placements
for
uncertified
Facility
Bluegrass in
violation of
256
Defendant RAMNIT
continued
to operate uncertified
Facility
17
Safety
foster
child placements
for
uncertified
Facility
18
Bluegrass
19
257
20
21
22
Approval to
operate a certified
family
home located
at a
different location
than uncertified
Facility
Bluegrass
23
258
Defendant RAMNIT and thereby breached mandatory statutory duties imposed by Section
24
89240
25
namely defendant WILSON was in noncompliance with applicable licensing regulations since
26 6 07 operated six uncertified facilities for a period of five years including numerous evictions for
27 nonpayment of rent homelessness due to financial malfeasance
28
259
55
COMPLAINT
Approval
on
1 issued on 11 16 06
Facility
260
3 ACCUSATION CDSS No 6712269202 against defendants OATES WILSON to revoke the Certificate of
4
Approval defendant Interim issued
on
11
16 06
on
Facility
5
261
different locations between 11 16 06 to 10 3 12 evicted from four with foster children and homeless for
Unbeknownst
to the
Department
Facility
was not
located
on
Bluegrass
Facility
1 was
11
located on 13945 Topmast Drive Helendale California 92342 defendants Oates Wilson were evicted
12
13
from
Facility
14 Bluegrass unti12011
15
16
263
Exemption
of defendant Wilson
17
264
18
19
Safety Code
section
1558
Estes
arms
pushed her against a wall and pinned her arms above her head and
20
will
21
committed a battery upon her with sexual intent Additionally defendant Wilson made a statement to the
22
grabbed plaintiff
effect that he was going to commit a forcible sex act upon her person making Estes fearful that she was
23
going to be raped
24
265
25
26 RIGHTS VIOLATIONS
27
28
section
89372
as
follows
defendant Wilson
struck
18
Safety
Code
sections
1534 b
1558
1596 885
Regulation
three foster
children
JONES JONES
56
COMPLAINT
and
DYSON
during
the
period
from
about
2 cast hit plaintiffD JONES about the body resulting in welts on the buttocks thighs and back
3
Wilson
Additionally
made
threatening
statements to
plaintiff
D JONES
such as
4
Y u
5
ACCUSATION CDSS No
266
6712269202
20
alleged
Oates made threatening statements to plaintiff D JONES to the effect that she would put him in the
g
hospital
21
267
to
plaintiff
R JONES
10
slapped
choked
attempted
to
11
prevented the child from going up the stairs by dragging her down Choked plaintiff R JONESJ
12
ACCUSATION CDSS No
268
13
through
16
plaintiffJ
with a spoon
January
2012
bleeding
handle
6712269202
alleged
with respect
to
plaintiff
D JONES
defendant Oates
hit
stabbed
made plaintiff squat while holding heavy objects for long periods of time
17
as a
form
of
discipline
would pinch plaintif s arms the objects were dropped during that time
18
ACCUSATION CDSS No
269
6712269202
alleged
19
20
21
22
with respect
plaintiffJ
to plaintiff
on
the head
hit plaintiffJ
and about
the
body
on
the
head
with
her fist
hit
as form of discipline
23
270
alleged
REPORTING REQUIREMENTS
24
Health
25
and
Safety
and
1558
Regulation
section
89361
On several
26 occasions during the period from in or about 2011 through in or about March 2012 defendant Wilson
27
28
failed to report incidents of physical abuse or corporal punishment that he witnessed or had been informed
of To wit seeing defendant Oates strike foster children being told defendant Oates had struck a foster
57
COMPLAINT
1
2
child
271
3 battered and terrorized plaintiffs JONES JONES and DYSON for nearly six years forced plaintiffs to
4
fight other foster children or be beat by defendant Oates not allowed to eat the same food as defendants
5
not allowed to eat at the same table as defendants Oates and Wilson
deprived
of adequate food prohibited from opening the refrigerator or entering the food pantry forced to steal food
or go hungry
9
272
In addition defendants OATES WILSON forced D JONES to walk 7 miles to school when
10
his home school was five minutes away forced DYSON to sit in a small banana crate all day and wear
11
shoes so small as to cause permanent damage forced plaintiffs to ask defendant for a glass of water for
12
13
14
15
16
toilet paper for sanitary napkins for tooth paste demeaned and cursed plaintiffs
alls floors vacuum and sweep floors lift rugs move and replace furniture clean toilets
bathrooms nightly
several
hours in
the
school
kitchen and
plaintiffs to wear used clothes took plaintiffs personal possessions beat plaintiffs with belts shoes
17
anything defendant OATES could find refused to allow plaintiffs JONES JONES and DYSON to wash
18
19
clothes in defendant s washing machine forced plaintiffs to walk or ride one bike four miles to wash their
20 clothes hit in the face causing bleeding slammed in the ground dragged downstairs beat with belts
21
22
forced to run around the block for hours carrying heavy milk gallons filled with water plaintiff SAIS was
23
273
24
ADAMS GALVANS and SAIS and forced plaintiffs to witness the abuse and terror of each other and all
25
274
alleged
28 EXEMPTION and LACK OF GOOD CHARACTER Health and Safety Code Sections 1522 and
58
COMPLAINT
1558
Regulation Section 89319 defendant Wilson violated the conditions ofthe previous criminal
2 record exemption in that he failed to comply with Licensing laws or regulations failed to continue to
5
275
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 Health and
Safety Code Sections 1522 1534 b and 1558 a and California Code of Regulations Title 22 Sections
9 89319 89361 and 89372 and grounds under Health and Safety Code section 1522 to rescind defendant
10
The Department s duly served Default Decision informed defendant WILSON of the right to
277
In or about January 2014 the Department issued a default decision against defendant
OATES finding the factual allegations in the ACCUSATION to be true and correct and constitute
17
violations of Health and Safety Code Sections 1522 1534 b and 1558 a and California Code of
18
Regulations Title 22 Sections 89319 89361 and 89372
19
20
21
22
278
The Department s duly served Default Decision informed defendant OATES of the right to
request the decision be vacated within seven 7 days after the Department mailed the default decision and
order to defendant Oates and the procedure to make said request
23
279
Defendant OATES WILSON did not request the default decision be vacated
280
Defendant Interim maintained little if any contact with plaintiffs providing no supervision
24
25
26 over plaintiffs care in multiple uncertified community care facilities over a period of six years
27
28
281
As a direct result of above alleged acts and omissions plaintiffs suffered severe physical
59
COMPLAINT
embarrassment
and
shame
deprivation of
liberty and freedom and substantial hurt and injury to plaintiffs health strength activity and substantial
2 enduring shock and injury to plaintiffs nervous system mental anguish depression anxiety inability to
3
sleep loss of focus and concentration confusion anger indignity nervousness hopelessness shame fear
4
panic and desperation all of which injuries caused and continue to cause plaintiffs severe mental pain and
5
6
282
permanent disability and general damages in an amount which will be stated according to proof pursuant to
9 California Code of Civil Procedure Section 425 10 which amount is in excess of Twenty five Thousand
10
25 000 00
Dollars
11
WHEREFORE PLAINTIFFS PRAY for judgment against defendants and each of them as
12
13
follows
For General Damages in a sum which will be stated according to proof pursuant to the
14 California Code of Civil Procedure which sum is in excess of Twenty Five Thousand Dollars
15
16
25 000 00
2 For
medical and
and
For loss
of earnings incurred and future loss of earning capacity according to proof 4 For pre judgment interest
17
according to
proof
For
costs of suit
incurred herein
and
18
19
20
21
22
23
25
26
27
28
60
COMPLAINT
283
284
by
Plaintiffs
reallege
Plaintiffs were dependent children under court supervision within the class to be protected
S Code Section 1508 the statutes and regulations alleged herein who suffered the injuries the
statute and regulations were enacted promulgated to prevent unsafe placements in six uncertified
5
unsupervised community care facilities with uncertified caregivers abuse corporal punishment extreme
6
neglect
g
9
evictions
142
208 Eviction
158
and
homelessness
Facility
Facility
alleged with
159
197
specificity in
167 Eviction
79 111
Facility
208 Homelessness
168
231
209
Facility
186
Facility
232
Facility
195
240
10
Eviction
Facility
240
258
Facility
11
285
12
13
14
91 92 93 97 100
103
206 213
119 123
124
129
131
134
146
158
162
163
165
167 172
178
181
15 class to suffer the injuries the statutes and regulations were enacted promulgated to prevent unsafe
16
placements in six uncertified unsupervised community care facilities with uncertified caregivers abuse
17
corporal punishment extreme neglect evictions and homelessness
18
2g6
19
20 specificity in
21
22
64 H
S Code Section
1508
90 108
122
182 190
198 207
214 224 246 causing plaintiffs members of the protected class to suffer the injuries the statute and
regulations were enacted to prevent unsafe placements in six uncertified unsupervised community care
23
facilities with uncertified caregivers abuse corporal punishment extreme neglect evictions and
24
homelessness
25
287 Defendants directors FREDDIE WILSON AJAY MALHOTRA and
26
27
28
137
138
148
149 150
151
164
174
175
176 177
61
COMPLAINT
alleged
183
in
184 185
104 105
186
191
106
107 120
192 193
135
194 208
1 215 216 217 218 225 226 227 248 249 150 causing plaintiffs members ofthe protected class to
2 suffer the injuries said statutes regulations were enacted promulgated to prevent unsafe placements in six
3
uncertified unsupervised community care facilities with uncertified caregivers abuse corporal
4
punishment extreme neglect evictions and homelessness
5
288
6
SHAHZIA RAMNIT breached mandatory statutory duties
alleged
in
84 89 116
121
145 164
178
198 212 229 230 233 236 255 256 257 258 causing plaintiffs members of the protected class to
suffer the injuries said statutes regulations were enacted promulgated to prevent unsafe placements in six
10
uncertified unsupervised community care facilities with uncertified caregivers abuse corporal
11
13
As a result of defendants breach of mandatory statutory duties plaintiffs were placed with
14 uncertified defendants OATES WILSON in multiple uncertified homes suffering terror trauma PTSD
15 humiliation intimidation threats embarrassment and shame substantial hurt and injury to plaintiffs
16
health strength activity and substantial enduring shock and injury to plaintiffs nervous system mental
17
anguish depression anxiety inability to sleep loss of focus and concentration confusion anger indignity
18
19
fear panic and desperation all of which injuries caused and continue to
20 cause plaintiffs severe mental pain and suffering for which defendants are liable
21
22
290
Plaintiffs are informed believe and thereupon allege that said injuries will result in some
permanent disability and general damages in an amount which will be stated according to proof pursuant to
23
California Code of Civil Procedure Section 425 10 which amount is in excess of Twenty five Thousand
24
Dollars
25 000 00
25
WHEREFORE
26
27 follows
2g
For General Damages in a sum which will be stated according to proof pursuant to
the California Code of Civil Procedure which sum is in excess of Twenty Five Thousand Dollars
62
COMPLAINT
25 000 00
2 For medical
and
incident
expenses
incurred
and to
For loss
2 of earnings incurred and future loss of earning capacity according to proof 4 For prejudgment interest
3
according to
proof
For
costs of suit
incurred herein
and
4
Court deems just and proper
5
10
SUAVE
11
12
13
14
15
16
291
17
292
18
19
tender years dependent plaintiffs herein to cheat hundreds of thousands of foster care dollars from the U S
20 Department of Health and Human Services California Department of Social Services and San Bernadino
21
22
County Department of Social Services for plaintiffs placement in seven illegaUuncertified unlicensed
homes
with uncertified
defendants OATES
and
WILSON in
violation of
23
four 4 evictions for none payment of rent and half vear of homelessness with no supervision by and
24
25
diminimus contact knowing or should know plaintiffs suffered ongoing unrestrained relentless torture
26 trauma severe mental and emotional abuse by uncertified caregivers defendants OATES WILSON in
27
79 111
Facility
112 141
Facility
142
158
28
63
COMPLAINT
Facility
159
167 Eviction
Facility
209
168
186
231
Facility
293
Facility
232
195
208 Eviction
240 Eviction
Defendants despicable
outrageous
Facility
Facility
240
5
258
197
Facility
208 Homelessness
with reckless disregard for plaintiffs safety shocks the conscience and exceeds all bounds of decency
5
6
usually tolerate d by a decent society of a nature especially calculated to cause and did cause severe
sustained mental and emotional distress
294
9
Defendant Interim held out uncertified defendants OATES WILSON as certified and
operated uncertified
Facility
as certified
in
violation of
10
plaintiffs JONES JONES and DYSON providing no supervision and little if any contact putting
11
12
13
plaintiffs at risk of foreseeable harm knowing or should know plaintiffs suffered ongoing abuse and
neglect
295
14
15
uncertified
16
violation of
Facility
2 as certified in
S Code Section 1508 knowing or should know defendant Interim provided no supervision
17
and little if any contact putting plaintiffs JONES JONES and DYSON at risk of foreseeable harm
18
19
296
20
21
22
Defendant SINGH held out uncertified defendants OATES WILSON as certified and
operated uncertified
Facility
as certified
in
violation of
knowing or should
know defendant Interim provided no supervision and little if any contact putting plaintiffs JONES
23
JONES and DYSON at risk of foreseeable harm knowing or should know plaintiffs suffered ongoing
24
abuse and neglect
25
297 Defendants uncertified OATES and WILSON held themselves and uncertified Facility
26
27
out
as certified
in
violation of
28
plaintiffs suffered severe ongoing pain neglect mental and emotional abuse
64
COMPLAINT
ir
298
1
2
3
Facility
as certified
in
violation of
should know defendant Interim provideii no supervision and little if any contact putting plaintiffs JONES
JONES and DYSON at risk of foreseeable harm knowing or should know plaintiffs suffered ongoing
S
abuse and neglect
6
299
g
9
out uncertified
in
violation of
Facility
3 as certified
10
supervision and little if any contact putting plaintiffs JONES JONES and DYSON at risk of foreseeable
11
harm knowing or should know plaintiffs suffered ongoing abuse and neglect
12
13
14
15
16
300
Defendant SINGH held out uncertified defendants OATES WILSON as certified and
operated uncertified
Facility
as certified
in
violation of
ow defendant Interim provided no supervision and little if any contact putting plaintiffs JONES
JONES and DYSON at risk of foreseeable harm knowing or should know plaintiffs suffered ongoing
17
abuse and neglect
18
301
19
Facility
violation of
21
knowing or should know defendant Interim provided no supervision and little if any contact putting
22
as certified
in
20
plaintiffs JONES JONES and DYSON at risk of foreseeable harm knowing or should know plaintiffs
23
suffered ongoing abuse and neglect
24
25
26
302
certified
in
Defendants OATES
violation of
and
Facility
27 putting plaintiffs JONES JONES and DYSON at risk of foreseeable harm knowing or should know
28
plaintiffs suffered ongoing abuse and neglect
65
COMPLAINT
3 as
1
2
Defendant Interim held out uncertified defendants OATES WILSON as certified and
303
operated uncertified
Facility
as certified
in
violation of
3 know defendant Interim provided no supervision and little if any contact putting plaintiffs JONES
4
JONES and DYSON at risk of foreseeable harm knowing or should know plaintiffs suffered ongoing
5
abuse and neglect
6
Defendants directors WILSON MALHOTRA and BHUPINDER CHHUDU held out
304
g
9
uncertified
violation of
Facility
4 as certified in
10
supervision and little if any contact putting plaintiffs JONES JONES and DYSON at risk of foreseeable
11
12
13
14
15
harm knowing or should know plaintiffs suffered ongoing abuse and neglect
305
Defendant SINGH held out uncertified defendants OATES WILSON as certified and
operated uncertified
Facility
as certified
in
violation of
ow defendant Interim provided no supervision and little if any contact putting plaintiffs JONES
16
JONES and DYSON at risk of foreseeable harm knowing or should know plaintiffs suffered ongoing
17
abuse and neglect
18
19
306
20 OATES WILSON
21
22
Facility
as certified
in
violation of
S Code
Section 1508 knowing or should know defendant Interim provided no supervision and little if any
contact putting plaintiffs JONES JONES and DYSON at risk of foreseeable harm knowing or should
23
Defendants OATES and WILSON held themselves out as certified and operated uncertified
25
26
Facility
as certified
in
violation of
27 Interim provided no supervision and little if any contact while defendants abused and neglected plaintiffs
28
308
Defendant Interim held out uncertified defendants OATES WILSON as certified and
66
COMPLAINT
ay
operated uncertified
Facility
as certified
in
violation
of H
2 know defendant Interim provided no supervision and little if any contact putting plaintiffs ADAMS
3 ADAMS JONES JONES and DYSON at risk of foreseeable harm knowing or should know plaintiffs
4
suffered ongoing abuse and neglect
5
309
6
uncertified
g
9
10
violation of
uncertified
Facility
5 as certified in
supervision and little if any contact putting plaintiffs ADAMS ADAMS JONES JONES and DYSON
at risk of foreseeable harm knowing or should know plaintiffs suffered ongoing abuse and neglect
11
310
Defendant SINGH held out uncertified defendants OATES WILSON as certified and
12
operated uncertified
13
14
Facility
as certified
in
violation of
ow defendant Interim provided no supervision and little if any contact putting plaintiffs ADAMS
15 ADAMS JONES JONES and DYSON at risk of foreseeable harm knowing or should know plaintiffs
16
suffered ongoing abuse and neglect
17
311 Defendant administrator AZARIAH held out uncertified defendants OATES WILSON as
18
certified and operated uncertified
19
Facility
as certified
in
violation
of H
20 knowing or should know defendant Interim provided no supervision and little if any contact putting
21
22
plaintiffs ADAMS ADAMS JONES JONES and DYSON at risk of foreseeable harm knowing ar should
know plaintiffs suffered ongoing abuse and neglect
23
312
24
DYSON
homelessness
with
homeless
uncertified
violation of
25
26 Code Section 1508 knowing or should know defendant Interim provided no supervision and little if any
27 contact putting plaintiffs GALVAN JONES JONES and DYSON at risk of foreseeable harm knowing o
28
67
COMPLAINT
2
3
313
1
up
concealed plaintiffs
defendants
uncertified
WILSON
OATES
in
violation of
know defendant Interim provided no supervision and little if any contact putting plaintiffs GALVAN
5
6
JONES JONES and DYSON at risk of foreseeable harm kriowing or should know plaintiffs suffered
314
9
10
DYSON
s and
defendant OATES
WILSON
homelessness in
violation of
owing or should know defendant Interiin provided no supervision and little if any contact putting
11
plaintiffs GALVAN JONES JONES and DYSON at risk of foreseeable harm knowing or should know
12
13
14
15
16
315
JONES JONES
and
DYSON
s and
homelessness in
violation
of
Code Section 1508 knowing or should know defendant Interim provided no supervision and little if any
17
contact putting plaintiffs GALVAN JONES JONES and DYSON at risk of foreseeable harm knowing o
18
19
20
21
22
Defendant Interim held out uncertified defendants OATES WILSON as certified and
operated uncertified
Facility
as cerEified
in
violation of
knowing or should
know defendant Interim provided no supervision and little if any contact putting plaintiffs SAIS JONES
23
JONES and DYSON at risk of foreseeable harm knowing or should know plaintiffs suffered ongoing
24
25
26
27
28
317
uncertified
violation
defendants
of
OATES
WILSON
Facility
6 as certified in
68
COMPLAINT
supervision and little if any contact putting plaintiffs SAIS JONES JONES and DYSON at risk of
2 foreseeable harm knowing or should know plaintiffs suffered ongoing abuse and neglect
3
318
Defendant SINGH held out uncertified defendants OATES WILSON as certified and
4
operated uncertified
Facility
as certified
in
violation of
know defendant Interim provided no supervision and little if any contact putting plaintiffs SAIS JONES
6
JONES and DYSON at risk of foreseeable harm knowing or should know plaintiffs suffered ongoing
g
319
10
OATES WILSON
Facility
as certified
in violation
of
S Code
11
Section 1508
knowing or should know defendant Interim provided no supervision and little if any
12
13
contact putting plaintiffs SAIS JONES JONES and DYSON at risk of foreseeable harm knowing or
320
16
as certified and operated uncertified
Facility
as certified
in
violation of
17
knowing or should know defendant Interim provided no supervision and little if any contact putting
18
19
plaintiffs SAIS JONES JONES and DYSON at risk of foreseeable harm knowing or should know
321
Defendant Interim held out uncertified defendants OATES WILSON as certified and
22
operated uncertified
Facility
as certified
in
violation of
23
know defendant Interim provided no supervision and little if any contact putting plaintiffs SAIS JONES
24
25
JONES and DYSON at risk of foreseeable harm knowing or should know plaintiffs suffered ongoing
322
uncertified
69
COMPLAINT
Facility
7 as certified in
violation of
2 supervision and little if any contact putting plaintiffs SAIS JONES JONES and DYSON at risk of
3 foreseeable harm knowing or should know plaintiffs suffered ongoing abuse and neglect
4
323
Defendant SINGH held out uncertified defendants OATES WILSON as certified and
5
operated uncertified
Facility
in
as certified
violation of
know defendant Interim provided no supervision and little if any contact putting plaintiffs SAIS JONES
g JONES and DYSON at risk of foreseeable harm knowing or should know plaintiffs suffered ongoing
9
10
324
11
as certified and operated uncertified
Facility
in
as certified
violation of
12
13
owing or should know defendant Interim provided no supervision and little if any contact putting
14 plaintiffs SAIS JONES JONES and DYSON at risk of foreseeable harm knowing or should know
325
17
certified and operated uncertified
Facility
as certified
in
violation of
18
19
owing or should know defendant Interim provided no supervision and little if any contact putting
20 plaintiffs SAIS JONES JONES and DYSON at risk of foreseeable harm knowing or should know
326 Defendants abandoned failed to supervise and had little or no contact with plaintiffs in a series
23
of unlicensed facilities with unlicensed caregivers defendants OATES WILSON putting plaintiffs at risk of
24
25
26
foreseeable harm knowing or should know plaintiffs suffered ongoing abuse and neglect
327
27 cheat the government out of lucrative foster care funds for plaintiffs illegal placements knowing or should
28 know plaintiffs were suffering ongoing abuse and neglect that would and did increase alleged herein
o
COMPLAINT
1 with particularity causing plaintiffs to suffer severe mental trauma PTSD humiliation intimidation
2 threats embarrassment and shame deprivation of liberty and freedom and substantial hurt and injury to
3
plaintiffs health strength activity and substantial enduring shock and injury to plaintiffs nervous system
mental anguish depression anxiety inability to sleep loss of focus and concentration confusion anger
5
6
indignity nervousness hopelessness shame fear panic and desperation all of which injuries caused and
continue to cause plaintiffs severe mental pain and suffering for which defendants are liable
328
g
9
Plaintiffs are informed believe and thereupon allege that said injuries will result in some
permanent disability and general damages in an amount which will be stated according to proof pursuant to
10
California Code of Civil Procedure Section 425 10 which amount is in excess of Twenty five Thousand
11
25 000 00
Dollars
12
WHEREFORE PLAINTIFRS PRAY for judgmerit against defendants and each of them as
13
14 follows
For General Damages in a sum which will be stated according to proof pursuant to
15 the California Code of Civil Procedure which sum is in excess of Twenty Five Thousand Dollars
16
25 000 00
2 For
medical and
and
to
be incurred in
the
future
For loss
17
of earnings incurred and future loss of earning capacity according to proof 4 For pre judgment interest
18
19
according
to proof
For
costs of suit
incurred herein
and
FOR CONSPIRACY
23
PLAINTIFFS DEANDRE JONES
24
SUAVE
25
26
27
28
COMPLAINT
1
2
329
330
4
defendants Administrators and defendants OATES WILSON held uncertified OATES WILSON and
5
seven uncertified facilities out as certified by INTERIM in violation of Health and Safetv Code Section
6
1508 to bilk hundreds of thousands of foster care dollars from the U S Dept of Health and Human
Services Title N E
State Foster
9 Funds and San Bernadino County Child Proteetive Services Foster Care Funds knowing or should know
10
plaintiffs suffered unconscionable ongoing unrestrained unmitigated terror torture corporal punishment
11
physical and mental
by
unchecked
12
331
13
14 defendants Administrators and OATES WILSON placed accepted plaintiffs foster children in seven
15
facilities
16
uncertified
332
by
INTERIM
in
violation of
17
Administrators
18
owing or should know plaintiffs suffered unconscionable ongoing unrestrained terror torture
19
20 corporal punishment physical and mental abuse and neglect at the hands of defendants OATES WILSON
21
unchecked
22
333
At all times herein defendant INTERIM defendants board members defendant CEO
23
and defendants Administrators knew plaintiffs foster children were evicted from four 4 of the seven
24
25
uncerti ed facilities with uncertified dangerous defendants OATES WILSON while holding said evicted
26 defendants out as certified by INTERIM in cahoots with defendants OATES WILSON in violation of
27 H
S Code Section 1508 placed more dependent children collected lucrative federal state and county
28 foster care funds perpetrating the kids for cash scam knowing or should know evicted plaintiffs foster
72
COMPLAINT
1 children suffered unconscionable ongoing unrestrained terror torture corporal punishment physical and
2
334
the
hands
of
unchecked
At all times herein defendant INTERIM defendants board members defendant CEO
4
and defendants Administrators knew defendants OATES WILSON and plaintiffs foster children were
5
homeless for
six months
homeless foster
children
defendants out as certified by INTERIM in cahoots with defendants OATES WILSON in violation of
g
S Code Section 1508 placed more dependent children collected lucrative federal state and county
9 foster care funds perpetrating the kids for cash scam knowing or should know homeless plaintiffs
10
suffered unconscionable ongoing unrestrained terror torture corporal punishment physical and mental
11
abuse and neglect at the hands of defendants OATES WILSON unchecked
12
335
13
14 humiliation intimidation threats embarrassment and shame substantial hurt and injury to plaintiffs
15 health strength activity and substantial enduring shock and injury to plaintiffs nervous system mental
16
anguish depression anxiety inability to sleep loss of focus and concentration confusion anger indignity
17
nervousness
hopelessness
shame
fear panic and desperation all ofwhich injuries caused and continue to
18
19
cause plaintiffs severe mental pain and suffering for which defendants are liable
336
20
Plaintiffs are informed believe and thereupon allege that said injuries will result in some
21 permanent disability and general damages in an amount which will be stated according to proof pursuant to
22
California Code of Civil Procedure Section 425 10 which amount is in excess of Twenty five Thousand
23
Dollars
25 000 00
24
25
26 follows
WHEREFORE
For General Damages in a sum which will be stated according to proof pursuant to
27 the California Code of Civil Procedure which sum is in excess of Twenty Five Thousand Dollars
28
73
COMPLAINT
25 000 00
2 For
medical and
incident
expenses
incurred
and
3 For loss
2 of earnings incurred and future loss of earning capacity according to proof 4 For pre judgment interest
3
according to
proof
For
costs of suit
incurred herein
and
4
Court deems just and proper
5
6
DATED October 2
L014
8
9
By
10
74
COMPLAINT
1
2
3
4
5
DATED October 2
014
6
7
8
9
By
10
75
COMPLAINT
N BERNARDINO
CI11G 141
CASE NO
Vs
17
CERTIFICATE OF ASSIGNMENT
c
L1
Aresidence
civil actionof aorparty
proceeding
presented for filing must be accompanied by this Certificate If the ground is the
name and residence shall be stated
The
un
rsigned declares that the above entitled matter is filed for proceedings in the
District of the Superior Court under Rule 404 of this court for the
checked reason
General
Collection
Nature of Action
Adoption
2 Conservator
3 Contract
1
Equity
Eminent Domain
Family
Guardianship
Harassment
Mandate
Name Change
Personal Injury
Personal Property
Probate
9
0
11
12
13
Law
Ground
Petitioner or ward resides within the district or has property within the district
Plaintiff defendant petitioner or respondent resides within the district
Decedent resided or resides within the district or had property within the
district
14
Prohibition
15
Review
O16
Title to Real
17
Property
Transferred Action
Unlawful Detainer
18
19
20
Domestic Violence
Other
21
IN
above
c
J
RESS
CITY
STATE
I declare
on
under
at
is tr
ZIP CODE
13
16503 360
Rev 06 2014
CERTIFICATE OF ASSIGNMENT
California