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ALTHEIA TAYLOR P . 0 . BOX 3 0 0 8 2 SAN BERNARDINO CA 92413 909 429-2656

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JAMES F. PENMAN
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CASE N0:6:12-bk-28006-mj OPPOSITION OBJECTION DAMAGE SETTLEMENT CHAPTER 9 NOTICE OF COMMENCEMENT OF CHAPTER 9 CASE LAW SUITE /CITY OF SAN BERNARDINO

CITY ATTORNEY
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ATTORNEYS FOR DEBTOR

CITY OF SAN BERNARDINO

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IN RE
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CITY OF SAN BERNARDINO

CALIFORNIA
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DEBTOR
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JAMES F. PENMAN
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CITY ATTORNEY
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ATTORNEYS FOR DEBTOR

CITY OF SAN BERNARDINO

Summary of Pleading - 1

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DAMAGES

SETTLEMENT AMOUNT 5000.00 TO 6000.00

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GENERAL LIABILITY SPECITIC LIABILITY GENERAL INJURY SPECIFIC INJURY TYPE OF AWARD TRAIL COURTS

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TOTAL AWARD COMPENSATORY PAST MEDICAL PAIN AND SUFFERINGS APPELLATE COURTS CITATION COURT DEFENSE

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INVESTIGATION OF CLAIM

APPELEE ATTORNEYS: FEMALE

PLAINTIFF'S SEX:

EMOTIONAL DISTRESS POST TRAUMATC STRESS DISORDER GUN DRAWNDAMAGE EXCESSIVE FORCE PHYSICAL BRUTALITY PRISONERS POLICE MOTORCYCLE

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Summary of Pleading - 2

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STOCKING VEHICLE HARASSMENT ( WHITE GRAY RED YELLOW BURGENCY GREEN ORANGE BLACK ) TRUCK METRO RED LINE METROLINK STOCKING FAMILY DISCRIMINATION FUTURE PAIN AND SUFFERING STOCKING HER FROM A LAW LIBRARARY 301 WEST FIRST STREET LOS ANGLES CA 90028 SLEEP ON CONCRETE IN COLD (HARASSMENT LIGHT BLUE) SLEEP UNION STATION 06/30/2011 /YELLOW SLEEP CONCRETE 06/01/2011-06/30/2011 COMPUTER / CONFIDENTIAL COPY DOCUMENT DAMAGE CAR / WINDOW / COMPUTER ( WINDSHIELD GUN SHOOT ) GUN / WINDSHIELD/ OFFICE CASAREZ S . INTERMITTEMENT SERVE EXCESSIVENSS ADEQUACY OF DAMAGES
A~ED

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FOR INJURIES TO HEAD OR

BRAIN/ HEADACHES INTERMITTENT SEVERE HEADACHES EXCESSIVENESS OR ADEQUACY OF DAMAGES

FOR INJURIES TO NERVES OR NERVOUS

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SYSTEM EVERY DATE STOCKING GAME IN CAR /BUS PLAINTIFF VERY NERVOUS INJURIES BATHROOM

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Summary of Pleading - 3

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DAMAGES CLAIMS DAMAGES PROPERTY / WINDOW VEHICLES DAMAGE TO CAR (MIRROR) COST OF REPLACEMENT OR REPAIR ( WINDSHIELD) LOSS OF EMPLOYMENT 50 TO 100 STATE EMPOYMENT LOS ANGLES POLICE DEPARTMENT PASADENA POLICE DEPARTMENT RIALTO POLICE DEPARTMENT/ 128 N WILLOW AVE RIALTO CA 92376 BODILY INJURY MAIN PHYSICAL INJURY SICKNESS DAMAGES MADE ASSAULT AND BATTERY STOLEN EVIDENCE / AUTO CAR BODILY INJURY / MEAN PHYSICAL INJURY SICKNESS DAMAGES MADE/ PSYCHOLOGICAL DAMAGES ASSAULT AND BATTERY STOLEN EVIDENCE / AUTO CAR LIKELY TO SUFFER INTERMITTENT PAIN FOR REST OF LIFE; OF MENTAL PAIN EMOTIONAL TRAUMA AND DISTRESS SUFFERING WAS INADEQUATE FOR HER PAST AND FUTURE PAIN AND RAISED THE AWARD TO $ 6,000 FOR PAIN AND SUFFERING

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ALTHEIA TAYLOR EXPERIENCED STOCKING EMOTIONAL TRAUMA CONSTANT EMOTIONAL STRESS BOTH SIDE OF HER LEG SLEEP ON CONCRETE

Summary of Pleading - 4

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POINTS

AUTHORITIES

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THE APPELLATE COURT RULED THAT THE JURY'S $7,500 AWARD FOR PHYSICAL AND MENTAL PAIN AND SUFFERING WES INADEQUATE FOR HER PAST AND FURORE PAIN, AND RAISED THE AWARD TO $6,000 FOR PAIN AND SUFFERING.

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(DAMAGES 5, 000) FALSE ARREST AND FALSE IMPRISONMENT FALSE ARREST ARE DEFINED AS THE INTENDED AND UNJUSTIFIED PHYSICAL RES

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RAINT OF THE PERSON. THESE TORTS MAY BE COMMITTED BY A PRIVATE PARTY, SUCH AS MERCHANT OR SECURITY GUARD, BY A PRIVATE PARTY, SUCH AS MERCHANT OR SECURITY GUARD, OR BY A LAW ENFORCEMENT OFFICE. GOOD FAITH DOES NOT NECESSARITY NEGATE THE UNDERLYING TORT. HOWEVER, GOOD FAITH WILL NEGATE MAILICE OR WANTONESS, THUS PRECLUDING RECOVERY OF PUNITIVE DAMAGES SOME COURT EQUATE LACK OF PROBABLE CAUSE TO DETAIN THE PLAINTIFF WITH MALICE IN THE SENSE OF ILL-WILL OR INTENT TO INVADE THE PLAIN-

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TIFF'S RIGHTS CAUSE UNJURY. THE MANNER IN WHICH THE DEFENDANT TREATS THE PLAINTIFF MAY ESTABLISH AGGRAVATED CIRCUMSTANCES, INCLUDING EMPLOYING EXCESSIVE FORCOR INTRASIVE SEARCH TECHNIQUES, OR ACCUSING THE PLATIFF OF CRIMINAL

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Summary of Pleading - 6

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OF THE STATES OF THE UNITED STATES THAT THE FORGOING ISW TRUE AND CORRECT.

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EXECUTED ON OCT 23, 2012 AT LOS ANGLES, CALIFORNIA.

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ALTHEIA TAYLOR

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I DECLARE UNDER PENALTY OF PERJURY UNDER THE LAWS OF THE STATES OF THE UNITED STATES THAT THE FORGOINTG IS TRUE AND CORRECT.

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EXECUTED ON OCT 23, 2012 AT LOS ANGLES CALIFORNIA

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ALTHEIA TAYLOR

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PROOF OF SERVICE I, ALTHEIA TAYLOR, DECLARE AS FOLLOWS. I AM OVER THE AGE YEARS AND NOT A PARTY TO THIS PROCEEDING. MY ADDRESS IS P.O. BOX 30082 SAN BERNARDINO CA 92413

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Summary of Pleading - 8

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FILED

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ALTHEIA TAYLOR P.O. BOX 30082 SAN BERNARDINO CA 92413 909 429-2656

2012 AUG 13 PH 3: 34

UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA

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ALTHEIA TAYLOR
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) CASE NO: EDCV 09-240 MMM

Plaintiff,
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) FINAL PRETRIAL CONFERENCE. ORDER

vs.
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SAN BERNARDINO POLICE

OFFICES
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s.

CASAREZ HIS

INDIVIDUAL CAPACITY
Defendant
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FOLLOWING PRETAIL PROCEEDING, PURSUANT TO RULE 16,

F.RCIV.P. AND L.R. 16, IT IS ORDERED:

1. THE PARTIES ARE: LIST SAN BERNARDINO POLICE

OFFICES S. CASAREZ HIS INDIVIDUAL CAPACITY

EACH

OF THESE PARTIES HAS BEEN SERVED AND HAS APPEARED. THE PLEADING WHICH RAISE THE ISSUES ARE:
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2. FEDERAL JURISDICTION AND VENUE ARE INVOKED. ARE

INVOKED UPON THE GROUNDS:

(GIVE A CONCISE STATEMENT

OF FACTS NECESSARY TO CONFER FEDERAL JUURISDICTION AND VENUE. STATE WHETHER THE FACTS REQUISITE TO
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LETTER REQUEST BY ALTHEIA TAYLOR - 1

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FEDERAL JURISICTION ARE DENIED OR ADMITTED.)

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3. THE TRAIL IS ESTIMATED TO TAKE 5-7 DAYS.

( WHERE

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COUNSEL CANNOT AGREE SET FORTH SIDE'S ESTIMATE.) 4. THE TRAIL IS TO BE A JURY TRAIL. (IF A JURY ADD: AT LEAT FIVE (5) COURT DAYS PRIOR TO THE TRAIL DATE EACH PARTY SHALL FILE AND SERVE BY E-MAIL, FAX, OR PERSONAL DELIVERY: (A) PROPOSED

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JURY INSTRUCTIONS AS REQUIRED BY L.R. 51-1 AND (B) ANY SPECIAL QUESTIONS TO REQUESTED TO BE ASKED ON VOIR DIRE.) (IF A NON-JURY TRAIL ADD: AT LEAST FIVE (5) COURT DAYS PRIOR TO PRIOR TRAIL DATE EACH PARTY SHALL L0DGE AND SERVE BY A E-MAIL, FAX, OR PERSONAL DELIVERY THE FINDING OF FACT AND CONCLUSIONS OF LAW THE PARTY EXPERTS THE COURT TO MAKE UPON PROOF AT THE TIME OF TRIAL AS REQUIRED BY L.R. 52-1)

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5. THE FOLLOWING FACTS ARE ADMITTED AND REQUIRE NO PROOF: 6. THE FOLLOWING FACTS, THOUGH STIPULATED SHALL BE WITHOUT PREJUDICE TO ANY EVIDENTIARY OBJECTION: 7. (THIS SECTION OF THE FINAL PRETRIAL CONFERENCE

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ORDER IS INTENDED IS FINALIZE, IN ADVANCE OF TRAIL, THE CLAIM AND DEFENSES TO BE PRESENTED AT TRAIL. IN

LETTER REQUEST BY ALTHEIA TAYLOR - 2

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ACCORDANCE WITH F.R.CIV.P. 16 (C), PARTIES WILL BE PRECLUDED FROM PRESENTING CLAIMS OR DEFENSES NOT SET FORTH IN THIS ORDER, IN THE MANNER REQUIRED BY THIS ORDER, UNLESS THE ORDER IS MODIFIED TO prevent MAN!FEST INJUSTICE. ONLY CLAIMS OR DEFENSES CONTAINED IN THE COMPLAINT AND ANSWER AND ANY COURT AUTHORIZED AMENDMENT OR SUPPLEMENT MAY BE INCLUDED IN THIS FINAL PRETRIAL CONFERENCE ORDER. IF A PARTY CHOOSES T

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ABANDON A CLAIM OR DEFENSE PREVIOSLY ALLEGED, SO BY NOT INCLUDING IT THIS ORDER, AND THE FAILU TO INCLUDE ANY PLEADED CLAIM OR DEFENSE WILL BE DEEMED TO EFFORT SUCH A WAIVER. BE EMPLOYED: PLAINTIFF(S): (A) PLAINTIFF PLANS TO PURSUE THE FOLLOWING CLAIMS THE FOLLOWING FORMAT MUS

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AGAINST THE FOLLOWING DEFENDANTS: CLAIM 1 :CIVIL RIGHT UNDER THE 4TH AND 14TH AMENDMENT CLAIM 2:EXCESSIVE FORCE VIOLATED

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(B)

THE ELEMENTS REQUIRED TO ESTABLISH PLAINTIFF'S

CLAIMS ARE: THE PARTIES SHOULD STRIVE TO AGREE ON THE ELEMENTS. IF THE PARTIES CANNOT AGREE ON AN ELEMENT, THEN EACH PARTY MAY STATE ITS VERSION OF THE ELEMENTS.

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LETTER REQUEST BY ALTHEIA TAYLOR - 3

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) IN BRIEF, THE KEY EVIDENCE PLAINTIFF RELIES

ON FOR EACH OF THE CLAIMS ITS: DEFENDANT( S) (A) DEFENDANT PLANS TO PURSUE THE FOLLOWIN

COUNTERCLAIMS AND AFFIRMATIVE DEFENSE: INSOFAR AS DEFENSES ARE CONCERNED, DEFENDANT SHOUL IDENTIFY MATTERS ONLY AFFIRMATIVE THE DEFENSES, WHICH THE ARE THOS 0

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ON WHICH

DEFENDANT

BEARS

BURDEN

PROOF. THEY ARE MATTERS WHICH WOULD DEFEAT PLAINTIFF'S CLAIM EVEN IF PLAINTIFF ESTABLISHED THE ELEMENTS OF THE CLAIM. EXAMPLES OF SUCH AFFIRMATIVE DEFENSESWHICH MUST HAVE BEEN PLEADED IN DEFENDANT'S ANSWERAPPEAR IN F.C.R. CIV.P 8 9 As counterclaims are (

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) . INSOFAR Defendean t shoul

concerned.

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follow the SAME FORMAT As plaintiff in listing claims.

(b) the elements required to DEFENDANT'S COUNTERCLAIMS AND AFFIRMATIVE DEFENSE ARE: LIST THE ELEMENTS SEPARATELY FOR EACH COUNTERCLAIM OR AFFIRMATIVE DEFENSE AS FOUND IN SWTANDARD JURY INSTRUCTIONS 0 CASE LAW. ELEMENTS. THE PARTIES SHOULD STRIVE TO AGREE ON TH

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IF THE PARTIES CANNOT AGREE ON AN ELEMENT,

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THEN EACH PARTY MAY STATE ITS VERSION OF THE ELEMENTS.

) IN BRIEF, THE KEY EVIDENCE DEFENDANT RELIES

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ON FOR EACH COUNTERCLAIM AND AFFIRNATIVE DEFENSE IS:

LETTER REQUEST BY ALTHEIA TAYLOR - 4

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CLAIM AMENDMENT

CIVIL

RIGHT

UNDER

THE

4TH

AND

14T

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CLAIM

EXCESSIVE FORCE VIOLATION

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(C

) IN BRIEF, THE KEY EVIDENCE DEFENDANT RELIES

ON FOR EACH COUNTERCLAIM AND AFFIRMATIVE DEFENSE IS: THIRD PARTY PLAINTIFFS AND DEFENDANTS: (CLAIMS AND DEFENSES IN THIRD-PARTY CASES SHOULD BE ANALYZED AND SET FORTH IN THE SAME WAY AS THOSE OF PLAINTIFFS AND DEFENDANTS. SEPARTE PROPOSED PRETRIAL CONFERENCE ORDERS WILL NOT BE ACCEPTED.

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IN VIEW OF THE ADMITTED FACTS AND THE ELEMENTS TO ESTABLISH THE CLAIMS, COUNTERCLAIMS AND

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REQUIRED

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AFFIRMATIVE DEFENSES, THE FOLLOWING ISSUES REMAIN TO BE TRIED:

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9. ALL DISCOVERY IS COMPLETE 10. ALL DISCLOSURES UNDER F.R.CIV.P. 26 ( A ) HAVE BEEN MADE. ( 3 )

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THE JOINT EXHIBIT LIST OF THE PARTIES HAS BEEN FILED UNDER SEPARATE COVER AS REQUIRED BY L. R.
16-15.

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UNLESS ALL PARTIES AGREE THAT AN EXHIBIT SHALL BE WITH

LETTER REQUEST BY ALTHEIA TAYLOR - 5

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DRAWN,

ALL

EXHIBITS

WILL

BE

ADMITTED

WITHOU

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OBJECTION AT TRIAL, EXCEPT THOSE EXHIBITS LISTED BELOW:

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PLAINTIFF OBJECTS TO EXHIBIT NOS. DEFENDANT OBJECTS TO EXHIBIT NOS.

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THE OBJECTIONS AND GROUND THEREFOR ARE: GROUND OBJECTIONS SEPARATLY AS TO EACH EXHIBIT

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11. WITNESS LIST OF THE PARTIES HAVE BEEN FILED WITH THE COURT.

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ONLY THE WITNESSES IDDENTIFIED IN THE LISTS WILL BE PERMITTED TO TESTIY

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EACH PARTY INTENDING TO PRESENT EVIDENCE BY WAY OF DEPOSTION TESTIMONY HAS MARKED SUCH DEPOSITIONS I ACCORDANCE WITH L.R. 16-27., FOR THIS PURPOSE, THE FOLLOWING DEPOSITIONS SHALL LODGED WITH CLARK AS REQUIRED BY L.R. 32-1 PLAINTIFF OBJECTS TO THE PRESENTATION OF TESTIMONY BY DEPOSTION OF FOLLOWING WITNESSES:

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12. THE FOLLOWING LAW AND MOTION MATTERS AND MOTIONS IN ILLMINE, AND NO OTHERS, ARE PENDING OR CONTEMPL-

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LETTER REQUEST BY ALTHEIA TAYLOR - 6

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ATED:

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13. BIFURCASTION OF THE FOLLOWING ISSUES FOR TRAIL IS ORDERD. STATE IDENTIFY THOSE ISSUES TO BE TRIED DURING THE FIRST STAGE OF THE TRAIL AND THOSES TO BE TRIED LATER.

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14. THE FORGEGOING ADMISSIONS HAVING BEEN MADE BY THE PARTIES HAVING SPECIFIED THE FORGEGOING ISSUES REMAINING TO BE LITIGATED, THIS FINAL PRETRAIL CONFERENCE ORDER SHALL SUPERSEDE THE PKEADING AND GOVERN THE COURSE OF THE TRAIL OF THIS CAUSE, UNLESS

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MODIFIED TO PREVENT MANIFEST INJUSTICE.

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LETTER REQUEST BY ALTHEIA TAYLOR - 7

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UNITED STATES DISTRICT JUDGE

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APPROVED AS TO FORM AND CONTEBT

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ATTORNEY FOR PLAINTIFF ALTHEIA TAYLOR

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LETTER REQUEST BY ALTHEIA TAYLOR - 8

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VANDALIZE
GLASS WINDOW

CAR I TRAIL DATE I

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BROKE GLAS BACK

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Summary of Pleading - 6

Case 6:12-bk-28006-MJ Print Report

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This incident has been reported to the Pasadena Police Department and is pending approval

Pasadena Police Department 207 North Garfield Ave Pasadena, CA 91101 626-744-4501

General Information
Incident Type Tracking Number Report Date Harassing Phone Call T12000889 0712412012 10:23 AM

Reporting Person Information

Incident Information
Incident Location Incident Time (start) Incident Time (end) Location Type CCCCCCCC/YYYYYYYY/, Pasadena, CA 90012 07/01/2012 10:15 AM 07/24/2012 10:15 AM Vehicle; Auto, Truck, Bus, Motorcycle STOCKING IN GREEN I PURPLE / LIGHT PURPLE/ YELLOW I RED I BLACKING VAMDALIZE CAR /10 10 10 10 10 10 10 10 10 10 10 VANDALIZE/ WHITE VAN MEXCIO VANDALIZE LYNN IN LOS ANGLES VANDALIZE PURPOSE/ SAN BERNARDINO POLICE Harassment offices s. casarez his cAPACITY VANDALIZE PURPOSE/ TERA WYNN/ GROUP OF POLICE OFFICE VANDALIZE CAR 20 TO 50 OFF STOCKING DAILY/

Incident Description

lPrint This Report I Close Window I

https :/Isecure. cop 1 gi c. corn/dorsi enlfi 1 sh owprin tab 1 port o ing/ ere

7/24/2012

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PROOF OF SERVICE

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I AM OVER THE AGE OF 18 YEARS AND NOT A PARTY TO THIS PROCEEDING MY ADDRESS P.O. BOX 30082 SAN BERNARDINO CA 92413

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ON JULY 06, 2012, I SERVEED THE FOREGOING DESCRIBED AS:

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FINAL PRETAIL CONFERENCE ORDER

JAMES F. PENMAN, CITY ATTORNEY 300 NORTH "D" STREET SAN BERNARDINO CA 92418

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ON ALL INTERESTED PARTIES IN THIS ACTION BY TRUE AND CORRECT COPY THEREOF IN A SEALED ENVELOPE, WITH FIRSTCLASS POSTAGE PREPAID THEREON, AND DEPOSITEF SAID ENVELOPE IN THE UNITED STATES MAIL LOS ANGLES CALIFORNIA ADDRESS TO:

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I DECLARE UNDER PENALTY OF PERJURY UNDER THE LAWS OF THE STATES OF THE UNITED STATES THAT THE FORGOING IS

LETTER REQUEST BY ALTHEIA TAYLOR - 9

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TRUE AND CORRECT .

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EXECUTED ON JULY 06, 2012, AT DATE:

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ALTHEIA TAYLOOR________________________________________

Ol\I?J_\ lt>\l)

~S

;\GLES, CALIFORNIA

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LETTER REQUEST BY ALTHEIA TAYLOR - 10

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DECLARE UNDER PENALTY OF PERJURY UNDER THE LAWS

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OF THE STATES OF THE UNITED STATES THAT THE FORGOING ISW TRUE AND CORRECT.

EXECUTED ON OCT 23 2012 AT

CALIFORNIA.

ALTHEIA TAYLOR

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Summary of Pleading - 9

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ALTHEIA TAYLOR

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PROOF OF SERVICE I, ALTHEIA TAYLOR, DECLARE AS FOLLOWS. I AM OVER THE AGE YEARS AND NOT A PARTY TO THIS PROCEEDING. MY ADDRESS IS P.O. BOX 30082 SAN BERNARDINO CA 92413

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ON OCT

23,2012 I SERVED THE FORGOING DOCUMENT

DESCRIBED AS: PROOF OF SERVICE OF SUMMONS TO: PAUL R. GLASSMAN (STATE BAR NO. 76536 LAURA L. BUCHANAN ( STATE BAR NO. 156261 KATHLEEN D DEVANEY ( STATE BAR NO. 156444) STRADLING YOCCA CARLSON & RAUTH A PROFESSIONAL CORPORATION 100 WILSHIRE BLVD., SUITE 440
SANTA MONICA CA 90401

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EXCESSIVFE FORCE STOCKING VEHICLE HARASSMENT

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I DECLARE UNDER PENALTY OF PERJURY UNDER THE LAWS

Summary of Pleading - 7