BETWEEN THE BARS
P.O. BOX 425103
CAMBRIDGE MA 02142

# 554..

WRITING A FEW WORDS FOR "BLOG READERS" AS WANTING SOME "FEED BACK" AS TO THE "PRESENTED DOCUMENTS" AS TO THE "STRUGGLES OF PRISON LIFE" FOR THE "BASIC NECESSITIES" AS MOST "CITIZENS" THINK WE ARE LIVING THE "LIFE OF" "LUXURY" BUT THEY WOULD NOT TRADE PLACES WITH ANY OF US HERE INSIDE THESE "WALLS EVERYDAY" AS WE ARE "NOT LINDSEY LOHAN" AS THEY USE HER AS A "MODEL" TO "SUPPORT" THE "PROPAGANDA" AS TO "HUMANLY TREATMENT" WHEN YOU HAVE THE "RIGHT RESOURCES" THEN YOU CAN GET "FAIR, EQUAL JUSTICE" FROM THE "JUDICIAL" SYSTEM..
BUT THE FIGHT GOES ON AS IVE GOTTEN "BAD NEWS" ON MY CIVIL SUIT FOR BEING "DENIED SUITABILITY FOR PAROLE" EVEN THOUGH I HAVE A "WRIT OF HABEAS" CORPUS PENDING AND IT LOOK GOOD, BASED ON RECENT LAW THAT JUST CAME DOWN A FEW DAYS AGO..AS I "NEED AN ATTORNEY FOR MY "PAROLE LAWSUIT" OR IN THE "ALTERNATIVE MONIES KEEP HOPE ALIVE" AS THE "GUARDS HATES ME FOR WHAT I DO IN THE COURTS..BUT THE "BOARD OF PRISON" FEELS I SHOULD BE HERE BUT IVE "SUCCEEDED" IN MY "GOAL" AS BEING A "LEGAL ASSISTANT" AS GETTING A "JOB" IS THE "HARD PART"..
PLEASE WRITE ME DIRECT..
JIMMIE STEPHEN C56483
22-H3-L
P.O. BOX 4000
VACAVILLE CALIFORNIA..95696
DATE 5-9-11

JIMMIE STEPHEN C56483
CSP-SOLANO 22 H3 L
PO BOX 4000
VACAVILLE CA 95696-4000
Pimp My 'Fro
[image]

JIMMIE STEPHEN C56483
P.O. BOX 4000
VACAVILLE CALIFORNIA.,

CV-09-1516--MCE-KJM
CV–10–1678-KJN-PC

DEAR ATTORNEYS
I AM REQUESTİNG REPRESENTATING IN "PRO BONO" AS TO ONGOING "CIVIL RIGHT" CASES PENDING IN USDC EASTERN DISTRICT UNDER "42 USC 1983"EVEN THOUGH I AM "SKILLED IN LAW" AND "LITIGATION" I NEED THE OUTSIDE INTERVENTION BASED IN PART TO "RETALIATION".. AS THESE 2 CASES MAY BE "DOWNLOADED"..
1..THE FIRST CASE 1516 DEALS WITH "DENTAL DENIAL" SINCE 2005. .AS ACCEPTED UNDER "IMMINENT DANGER EXCEPTION" UNDER 28 USC 1915-G..WITH WARDENS BEING ALSO RESPONSIBLE FOR "OVERCROWDING CAUSING DISEASES" INCLUDING "VENTILLATION SYSTEM" AS I WAS "NO HAPPY" SO I WENT, TO 9TH CIRCUIT ON "REST OF ISSUES" THEY WERE DENIED AS LACK OF "JURISDICTION"...
2..THE "SEGOND CASE" INVOLVES THE "FIRST CASE''GRANTING" COMPLAINT AS TO WARDENS HERE AT SOLANO AS TO "OVERCROWDING" AND "VENTILATION" WHEN "TESTED "POSITIVE" AFTER "PROLONGED" "REQUESTED""COLONOSOPY EXAMINATION" SINCE ARRIVAL OF 11-18-08. . AS "DENIED" "PROLONGED WILLFULLY".. WITH "RISK OF HARM"..
AS AFTER FIRST SUMMONED FOR "COLONOSOPY" ON 1-8-10 OVER ONE YEAR SINCE ARRIVAL AS ON "5" DIFFERENT APPOINTMENTS FOR "COLONOSOPY" DID IT OCCUR ON 6-7-10 AS DOCTOR ORDERED REFERRED FOR "URGENT"''EMERGENCY""SURGERY" AS THE "SURGERY" DID "NOT" HAPPEN UNTIL 7-21-10..OVER "45" DAYS. .AS I DID AN "URGENT" "EMERGENCY" APPEAL AND DID THE ORIGINAL LAWSUIT BY HAND AS I KNOW THEY SCAN YOUR MAIL HERE..SO I MANAGED TO. "FILE" BEFORE THE SURGERY TOOK PLACE AS SOON AS THEY FOUND OUT THEY "ORDERED" THE "SURGERY"..
AS IM WAITING FOR THE COURT TO ISSUE "RUILING" ON 1678..
PLEASE RESPOND:

JIMMIE STEPHEN C56483
22-H-3-L
P.O. BOX 4000
VACAVILLE CALIFORNIA, .95696..

Case 2:09-CV-01516-MCEM Docurren 31 Filed 04/27/10 Page 1 of 10
APR 2 7 2010
CLERK, U.9. DISTRICT COURT EASTERN DISTRICT OF CALFORNIA
DEPUTY CLERK

"ORIGINAL PAGES # 10..

"PRATT V ROWLAND" 65 F3D 802
(9TH 1995)..
"JURISDICTION''.. WHEN ONGING "RETALIATION" ECT. AS TO "DEFENDANTS" WHEN "TRANSF-. ERRED" FROM "PRISON TO PRISON". "WILLFULLY".

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF CALIFORNIA

CV-09-1516-MCE..
(Case Number)

JIMMIE STEPHEN C456483
(Name of Plaintiff)
P.O. 'BOX 4000-20-A-2-UP
(Address of Plaintiff)
VACAVILLE CALIFORNIA..95696..

VS.
"DR F. ZHANG"
ET AL DEFENDANTS
(Names of Defendants)

COMPLAINT
"CORRECTED''AMENDED # 2.6.
"FRCP" # 15..
WITH "SUPPLEMENT"...

I. Previous Lawsuits:
A. Have you brought any other lawsuits while a prisoner: Yes

B. If your answer to A is yes, how many?: ____ Describe the lawsuit in the space below. (If there is more than one lawsuit, describe the additional lawsuits on another piece of paper using the same outline.)
(SEE.ORDER" DATED 4-15-10)
1. Parties to this previous lawsuit:
Plaintiff JIMMIE STEPHEN C456483
Defendants "DR HOXIE" ET AL DEFENDANTS
FORM TO BE USED BY A PRISONER IN FILING A COMPLAINT UNDER THE CIVIL RIGHTS ACT. 42 U.S.C. $ 1983

Case 2:09-CV-01516-MCE-KJM Document 31 Filed 04/27/10 Page 2 of 10

2. Court (if Federal Court, give name of District; if State Court, give name of County)
"USDC" CENTRAL LOS ANGELES CALIFORNIA"..

3. Docket Number - 08-56533..

4. Name of judge to whom case was assigned A.H. "STOTLER..

5. Disposition (For example: Was the case dismissed? Was it appealed? Is it still pending?) "DENIED" WITH REQUEST TO "AMEND"..FRCP # 15..

6. Approximate date of filing lawsuit_5-16-08..

7. Approximate date of disposition 2-26-10..

II. Exhaustion of Administrative Remedies

A. Is there a grievance procedure available at your institution?
X Yes
No
B. Have you filed a grievance concerning the facts relating to this complaint?
X Yes
No
If your answer is no, explain why not
C. Is the grievance process completed?
X Yes
No

III. Defendants

(In Item A below, place the full name of the defendant in the first blank, his/her official position in the second blank, and his/her place of employment in the third blank. Use item B for the names, positions and places of employment of any additional defendants.)
A. Defendant "F. ZHANG".. is employed as "DENTIST": "SOLANO STATE PRISON , at 2100 PEABODY RD. .VACAVILLE CALIFORNIA.. 95969..

B. Additional defendants' 1"'C/O GUERREROW.2.. "DR CHEN"..3.. "COUNSELOR GREEN".. 4..'C/O MOSBY"'..5.. "C/O PINES"..6.. "LTA KOSHER". .7.."C/O RICHARDSON".. 8. "WARDEN HAVILAND"..9.."WARDEN SISTO"..10.."WARDEN SWARTHOUT"..11. .WARDEN "BROWN"..12.. "DIRECTOR TILTON"., 13.."SGT CLARK"..14.. "SGT ECKT. .15.. "DIRECTOR TILTON". . 16. . "CCPOA PRESIDENT JIMENEZ"..17.."GOVERNOR SCHARZENEGGER" L "BPT" "ALL DEFENDANTS" RESIDE AT "SOLANO" STATE PRISON EXCEPT "TILTON".. "JIMENEZ""SCHARZENEGGER".. "ALL DEFENDANTS" "SUED" IN "INDIVIDUAL AND OFFICIAL CAPACITY.. UNDER "COLOR OF LAW AS A "CDGR EMPLOYEE". ECT.. (18).. "BOARD OF PRISON TERMS". 632). DEFENDANTS TOTAL"..

2.. (SEE NEXT PAGE)

"DEFENDANTS": EMPLOYED AT "BPT" P.O. BOX 4036 SACRAMENTO CALIF 95812-4036..(1).R. "OYEYEMI""PSYCH"..

"DEFENDANTS: EMPLOYED AT "CMC":(10.."DR HOXIE".. (2).. COUNSELOR "OSHIRO"..(3).M. "CORNELIOUS"..(4)..WARDEN "MARSHAL". (5)D.C. "CASTILLO".. P.O. BOX 8101. .SAN LUIS OBISPO.

"DEFENDANTS": EMPLOYED AT "DONOVAN'AT 480 ALTA RD SAN DIEGO CALIF.
71)"DR LEE" (2) "DR ANTIQUE" (3) "SGT J.N. CLARKE" (4) "SGT "ARMENTA" (5)M."ESPINUZA" (6) "WARDEN HERNANDEZ".. (8)W."SORIANO" (7). IM, BELTON" UNDER "FRCP # 19"..
Do not give any legal arguments or cite any cases or facts. Attach extra sheets if necessary.)
#1..
UPON "ARRIVAL" OF 11-14-08 FROM "CMC"! PRISON PLAINTIFF WAS SUPPOSE TO BE PLACED ON "PRIORITY DENTAL LIST" FOR "PARTIALS DENTURES" BUT IS "PRESENTLY" BEING "DENIED" "RIGHT TO EAT PROPERLY" WHEN "GUMS BLEED" WITH "NERVES EXPOSED" ECT BY "DR ZHANG" WHEN "PAIN EXIST AS "PARTIALS WILLFULLY DENIED DEPRIVED" SINCE 2005. .AS "BASIC HUMAN NEED..BASED ON "WILLFUL OVERCROWDING"AS "TACTICS" BY "CDCR" IN PAST IS TRANSFER FROM PRISON TO PRISON".FROM 3-27-07 VILLFULLY TOLD BY DR HOXIE OF CMCT AS 10 NOT HAVING ANY SUPPORT FOR "PARTIALS" ON "RIGHT SIDE OF MOUTH" AS ALL "TEETH" WERE "WILLFULLY EXTRACTED" WHEN COULD'VE BEEN "SAVED AS "TEETH" TIL 11-14-08.. ONGOING" "DENTURES" PARTIALS DENIED". OR "ALTERNATIVE" TO "PARTIALS" WHEN "NO TEETH' TO "SUPPORT DENTURES" ECT.. FARROW V WEST" 320 F3D 1235..(11TH 2005) STATE "IMMINENT" V. Relief. DANGER EXCEPTION" APPLICABLE WHEN DENIED "DENTURES" FOR "15" (CONTINUED NEXT PAGE).. "MONTHS"..

(State briefly exactly what you want the court to do for you. Make no legal arguments. Cite no cases or statutes.)
IST 5TH 8TH 14TH
A.. JURY TRIAL DEMANDED"
B.. 'DAMAGES" IN SUM OF $10,000 EACH DEFENDANT PLUS $100,000 PUNITIVE EACH.
C. ."'INJUNCTIVE" RELIEF AGAINST "RETALIATION'' "MEDICAL'DENTAL" DENIALS" OR
ANY TYPE OF "LIMITATIONS" TO MAKE "TOOTH FUNCTIONS WHOLE.
D. . "ORDER STRIKING" "3-STRIKE ORDER" OF 2006.. UNDER "FRCP # 12-B..
E. ."APPOINTMENT OF ATTORNEY" FORTHWITH.. F."SINGLE BED"""CELL STATUS". .FORTHWITH..
Signed this 24TH day of APRIL 2010
(Signature of Plaintiff)
I declare under penalty of perjury that the foregoing is true and correct.
• 4-24-10
(Date)
(Signature of Plaintiff)

"CONTINUED"..
"TRANSFER" "FROM PRISON TO PRISON" .
"DELIBERATE INDIFFERENCE"
"RECKLESS DISREGARD" WHEN
"SERIOUS DENTAL" NEEDS
WILLFULLY:

"'DEFENDANTS:
1..''DR ZHANG"..
2. DR HOXIE"..
3. DR LEE..
4.. "DR ANTIQUE"..

PLAINTIFF "DENTAL NEEDS' RISE TO RISKS" OF "FUTURE HARM" WHEN BASED IN "2 PARTS" THE RIGHT TO DENTURES, PARTIALS' ARE "WILLFULLY" "DENIED ""''DELAYED" BASED ON "WILLFUL OVERCROWDING" SINCE 5-1-05 AS ARE "ONGOING" AS OF 9-26-09.. AS ALL "RIGHTS CHILLED".. IST, 5TH 8TH & 14TH.. WHEN PLAINTIFF HAS "ONLY ONE TOOTH' TO "CHEW ON IN "BACK OF MOUTH'..
B.. THE "2ND" PART WHEN "GUMS DECLINE" AWAY FROM "TEETH "''EXPOSING SENSITIVE NERVES" THAT PRODUCE "PAIN WHEN BRUSHING' TOUCHING" ECT.. WITH "RISKS OF INFECTIONS" INTURN WITH "RISKS OF MORE SERIOUS' "AILMENTS" INCLUDING "POISONING OF THE BLOOD STREAM" AND "RISK OF HEART'' "ATTACKS" ECT.. "ONGOING AS OF 9-26-09".. "PAIN AND SUFFERING"..ECT.,
C..AS_"'DENTIST ZHANG" WILLFULLY DENIED TEETH" TREATMENT SINCE 11-14-08. ARE "WILLFULLY" PLACING PLAINTIFF "LIFE"*WELL BEING AT RİSKS".. WHEN PRACTICE AT "SOLANO" IS "EXTRACTIONS".. EVEN THOUGH PLAINTIFF "SERIOUS DENTAL NEEDS" IS "2 PART". .AS OF 9-26-09. .AS THE EXCUSE OF "FUNDS" BY "ZHANG" AND "CDCR" VIOLATE THE "8TH AMENDMENT...
D. TO "THWARF' PLAINTIFF "ACCESS TO DENTAL" THE POLICY CUSTOM PRACTICE IS TO "WILLFULLY TRANSFER FROM PRISON TO PRISON". .AS PLAIN TIFF HAS BEEN TO "3" "PRISONS" SINCE "2005"..WHEN RIGHTS TO "IST AMENDMENT PROTECTED RIGHTS OF ACCESS" "PRACTICED BY FILING GRIEVANCE" FOR "SERIOUS DENTAL NEEDS".. "FROM 5-1-05" TO 3-27-07 "DENIED"..RIGHT"
TO HTEETH" OR "DENTAL TREATMENT BY "LEE! ANTIQUE" AND "HOXLE. ONGOING ..
E.. "INJURIES ARE ONGOING AS TO "SERIOUS DENTAL NEEDS AS OF 9-26-09 INCLUDING "PAIN "PAIN AND IRRITATING WHEN BRUSHING TEETH" INCLUDING "BLEEDING" "SORENESS" WHEN "NERVES EXPOSED" AS IN PART DOES PLACE PLAINTIFF "HEALTH AND SAFETY" IN "JEOPARDY" WHEN 'WIRES" FROM "PARTIALS DENTURES" "IRRITATE" THE "NERVES" OF "DECLINE GUMS" WHEN "NERVES EXPOSED"..FROM 3- 27-07 TIL 11-14-08""DR HOXIE" "WILLFULLY DENIED" "TEETH TREATMENT" ECT.. MONGOING AS OF 4-20-10" "FARROW V WEST' 320 F3D
14_08"' DR HORFARROW V LWS 2005)...

#-2. "BELIBERATE INDIFFERENCE"
"RECKLESS DISREGARD" WHEN "SERIOUS' "MEDICAL" NEEDS
"WILLFULLY DELAYED"..

"DEFENDANTS":
1.. DR CHEN": :
2.."C/O RICHARDSON"..

UPON "ARRIVAL" OF 11-16-08 PLAINTIFF "MEDICAL" CONDITION CHANGED WHEN "OVERCROWDED DORMS" AND "GERMS" CAUSED PLAINTIFF "SERIOUS FLU" "'INFECTIONS" OF THE "THROAT AND MOUTH'"'NOSE" AREAS. AS WAS "WILLFULLY DENIED" RIGHT TO SEE "DR CHEN" UNTIL 1-5-09..WHEN "OVERCROWDED"..AREA AS "RISKS OF CONTACTING HIPATITUS" AND OTHER DISEASES WHEN PLAINTIFF "CONTRACTED TUBERCULOSIS" IN 2005..WHEN "SCREENING PRACTICES OF THE HOUSING AT SOLANO IS "INADEQUATE" WHEN "DORMS BREED DISEASES WHEN "VENTILLATION SYSTEM IS "INADEQUATE" AND KNOWLEDGE OF "WARDEN SISTO" -"SWARTHOUT'..AS OF 9-26-09. .AS "IMMINENT DANGER!, "SERIOUS PHYSICAL". "INJURIES".. WHEN "HEART BYPASS" AND "PUNCTURED LUNG" CONTRIBUTE TO A "CHRONIC NEEDS" WITH PRIORITY CARE..AS OF 4-20-10"ONGOING"..

"ANDREWS V CERVANTES" 493 F3D 1047(9TH 2007). "IMMINENT DANGER"
EXCEPTION" WHEN PLACED WITH EXCESS TO "DISEASES"..

PRISON LAW OFFICE
General Delivery, San Quentin. CA -9-964-000 i Telephone (415) 457-9144 • Fax:(415) 457-9151 www.prisonlaw.com

Director:
Donald Specter

Staff Attorneys:
Susan Christian
Steven Fama
Rachel Farbiarz
Penny Gocibold
Megan Hagler
Alison Hardy MEMORANDUM
Vibeke Marcin
Millard Murphy
Sara Norman
TO: Charles Antonen. Deputy Attorney General
Judith Rosenberg From: Alison Hardy/SW
Zoe Schonfeld
E. Ivan Truiillo Date: 1/25/2008 Re: Perez. 3 - Individual Inmate Exhausted Dental Concern - Request for Review
To:
Jimmie Stephen, C-56483
CMC
Mr. Stephen has exhausted his administrative remedies on the issue of receiving repair of his teeth (IAB # 0708017, Log # CMC-07-01748).
According to the Second Level's Decision, Mr. Stephen was classified as Priority 2 on 5/8/07. The response goes on to state that Mr. Stephen was triaged for a "new and separate dental issue" on 6/13/07, which was resolved on 6/19/07. The response, which was written on 8/29/07, states that Mr. Stephen "would continue to receive treatment as a DPC 2 patient."
1
S
t
Mr. Stephen writes that he still has not received partials or treatment to repair his teeth.
Please respond to the following:
1
1. When did Mr. Stephen last see a dentist regarding the possible need for partials or repair of his teeth? What were the results of this appointment?
2. Please describe Mr. Stephen's current treatment plan.
Board of Directors Penelope Cooper. Presidenr. Michele Walkin Huwk. Vice Presidenr. Marshall Krause. Treasurer
Honorable lohn Burron. Felecia Gaston Christiane Hipps . Margarer Johns Cesar Lagleva · Laura Magnani. Michael Matcun. Ruch Morgan Dennis Roberts
Case 2:09-cy-01516-MCE-KJM Document 31 Filed 04/27/10 Page 5 of 10
"RIGHT, PRIVILEGE" TO OWN "TELEVISIONS''
"WHEN OVERCROWDED"..ECT
# 2-A..THE "DORMS OF SOLANO YARD # 4" HAVE "ONE TOILET" PER "30" PRISONERS AS "INADEQUATE" AND "HEALTH AND SAFETY" "RISK"..ON 8-30-09 PLAINTIFF REQUESTED "DISINFECTANT" FROM "C/O RICHARDSON' AND WAS IN TURN "WILLFULLY DENIED" WHEN I WAS "NOT TALKING TO HIM BUT A "FEMALE "GUARD". .AS MORE LENIENT. .AS "TOILETS" SINKS" "MUST" BE "STERILIZED" "AFTER EACH USE" THIS IS DENIED UPON "APPEAL" WAS "DENIED BY "WARDEN BROWN" .. UNDER "HAVILAND"."AIDS." "HIPATITUS"" VALLEY FEVER" "PLUS" "TB" ARE "CONTRACTED EASILY" IN "DORM SETTING" ESPECIALLY WITH "3-TIER" "BEDS" ECT.. "WARDEN SISTO" IS AWARE OF THIS PROBLEM. AIDED BY "JIMINEZ..
B.. "BASIC HUMAN NEEDS" INCLUDE PROTECTION FROM "RISKS OF DISEASE OR CONTAGIOUS DISEASES".. WHEN 'VENTILLATION SYSTEM IS "INADEQUATE AS "WARDEN SISTO""'HAVILAND'"BROWN'SWARTHOUT" ARE AWARE OF THE STATE OF "'VENTILLATION" IN "DORMS # 20,21,22,23" WHEN "DORMS # 19, AND 24" "ONLY HOUSE MEDICAL WITH AIR CONDITIONING" NEEDS SUCH AS "HOT MEDS".. AND "PSYCH MEDS"..AS "DORMS # 20-23" "VENTILLATION" WHEN REACHES 90 DEGREES "MUST HAVE A FAN" BUT "PROVIDES INADEQUATE" "AIR" BASED ON *NO CIRCULATION OF COOL AIR" WHEN "FANS" BLOW OUT "HOT AIR".. CAUSING "'EXTREME HARDSHIP" AND "PAIN UNECESSARILY". .AS OF 9-26-09 "ONGOING".. WHEN "OVERCROWDED" AS "RISKS OF VIOLENCE''DISEASES" AS A "BASIC HUMAN NEED".. IN ADDITION THE "WILLFUL CONFISCATION OF TELEVISIONS" OF 6-30 09 ADDS FURTHER "RISKS OF VIOLENCE" ECT.. "SAFETY AND SECURITY"..ECT.. (DISINFECTANT DISPENSERS DENIED) 5TH, 8TH AND 14TH VIOLATED & IST..
BY WARDEN BROWN" OF 8-30-09). "ONGOING AS OF 4-20-10"..
2.. 'MOSBY".
# 3.. "SELECTIVE RETALIATION' WHEN
"WILLFULLY FILED FALSE" AND
DEFENDANTS": "MISLEADING CHARGES" FOR "IST' AMENDMENT ACCESS TO COURT"..
1.. "PINES"..
3. ECK.. ON 3-28-09 PLAINTIFF WAS "WILLFULLY" SUBJECTED TO "SELECTIVE": 4.. SGT CLARK'.. AND "DISCRIMATORY" "RETALIATIONS" BY "C/O PINES" AND "C/O MOSBY'' IN CONCERT..WHEN PLAINTIFF REQUESTED***PASS TO LAW LIBRARY" AS "PATTERN" OF PLAINTIFF SINCE 11-14-08..ON 3-28-09 PLAINTIFF FIRST REQUESTED A "PASS AT 7:00 AM" TO "MOSBY" AND TOLD TO COME BACK AT 8:30 AM..AT 8:15 AM "MOSBY" TOLD PLAINTIFF TO ASK "PINES" WHOM STATED SHE WOULD NEVER "WRITE PLAINTIFF A PASS EVER" AND "YELLED" FOR PLAINTIFF TO GET AWAY FROM "DESK" AS POLICY, CUSTOM, PRACTICE, OF "PINES" IS TO "PRO VOKE'" 'INCITE" TO "PUSH ALARM TO "SEGREGATE" OR "RISK OF VIOLENCE".
B..PLAINTIFF SAT AT "TABLES ABOUT 12 FEET AWAY"' AND WATCHED C/O "MOSBY" "WRITE 3 PASSES" TO LIBRARY..AS THE PRACTICE OF SOLANO 4 YARD WHEN YOUR "BUILDING HAS LAW LIBRARY'' EVEN THOUGH YOUR "BUILDING DONT" YOU MAY GO TO "LIBRARY WITH PASS"..OF 3-28-09..PLAINTIFF "HAD LIBRARY FROM 7:30 AM TO 2;00 AM..AS WAS "WILLFULLY DENIED" WHEN OTHERS WERE ALLOWED AS HAD "'NÓ CONFRONTATION PERSONALLY WITH "MOSBY" OR "PINES" BEFORE THE ACTS OF 3-28-09.. "ONGOING RETALIATION AS OF 4-20-10"..
C..ON 3-28-09 "PINES" DID "FABRICATE WRITE UP" TO "CAUSE HARM" "DENY PAROLE" OR "RISKS" ECT.. THE 'WRITE UP" CONSISTED OF PLAINTIFF ALLEGED "LOOKING AT HER" ..AS PLAINTIFF WAS IN FACT LOOKING AT "MOSBY AND PINES" AND SAW "RIGHTS WILLFULLY VIOLATED" "WHEN MOSBY WROTE" "3" "PASSES TO LIBRARY THIS DAY 3-28-09.. "ONGOING RETALIATION" AS OF 4-20-10..
D.."PINES WRITE UP' FOR "LOOKING" WHEN ''HER DESK SITS IN FRONT" OF "OPEN SHOWERS" AND "OPEN TOILETS" ALL "MALES". WHEN OPEN BUILDINGS".
PRACTICE, OF DRA PLAINTIFF TO CERT
USH ALARM" TO
Case 2:09-CV-01516-MCE-KJM Document 31 Filed 04/27/10 Page 6 of 10
E..PLAINTIFF OF 3-28-09 REQUESTED TO SEE "SARGEANT'' AND WAS DENIED BY "MOSBY" AND "PINES" AS A "RIGHT" WHEN DENIED "LIBRARY" WHEN "BUILDING # 20" HAD "LIBRARY ACCESS" OF 3-28-09..FROM 7:30 TO 2;00 AM AND WAS DENIED'ACCESS". . "YARD OF 3-28-09"OPENED AT 12:30 AM..
F.. AT 12:30 AM PLAINTIFF WENT TO AND SAW "SGT ECK" WHOM WILL FULLY "STATED PLAINTIFF HAD TO GO TO LIBRARY WHEN HAD YARD AS THIS IS "NEW POLICY" BY "ECK" AS ON "APPEAL" SAME STATED BY HEARING "SGT CLARK" OF 4-30-09..AS ''NO NOTICE OR CHANCE TO APPEAL" "NEW RULE'T AS BEEN GOING TO LIBRARY SINCE 11-14-08" ON "ARRIVAL"..BY "PASS" WHEN "PLAINTIFF BUILDING HAS LIBRARY'' BUT "NO YARD"..
G.. "RISKS OF SAFETY AND SECURITY" BY ACT OF A "CAMPAIGN OF HARASSMENT'' FOR "IST AMENDMENT PROTECTED RIGHTS".. WHEN "PATTERN EXIST OF RETALIATION AS ON 8-9-05 11-27-05 AND 9-19-06 PLAINTIFF WILLFULLY "SEGREGATED" AS "ALL "3"" DISMISSED" ON "APPEAL" ECT!228 DAYS SEGREGATED".
H.. "PINES" ECT AS "HOUSING OFFICER" IS RESPONSIBLE FOR "COMPATI-. BLE CELLMATES" FOR PLAINTIFF SINCE 1-18-09 AS "DENIED"15 TIMES I.. "RISKS OF DENIAL OF PAROLE" FOR TWRITE UP "CHRONO" OF 3-28-09.. BY "PINES' AIDED AND ABETTED BY ''MOSBY"'.. AS "BPT HEARING OF 7-14-10".
IST 5TH & 14TH..
# 4.. "DUE PROCESS''EQUAL
PROTECTION OF LAW AS "BASIC HUMAN NEED"..
"DEFENDANTS": 1.."KOSHER".. 2.."B.P.T."..
ON 4-10-09 PLAINTIFF OVERHOOD "LTA KOSHER" STATE WHEN LAST "2" "TYPEWRITERS ARE BROKEN THEY WOULD NOT BE REPLACED'' AS PRACTICE OF "LTA KOSHER" IS TO 'WILLFULLY DESTROY TYPEWRITERS WHEN REPAIRABLE" SINCE "ARRIVAL" OF 11-14-08..AS "NEW POLICY OF "NOT REPLACING TYPE WRITERS" OR "ELIMINATING OF TYPEWRITERS' VIOLATED "RIGHTS TO DUE PRO CESS"..ECT..OB "CHANCE TO APPEAL".. "NO NOTICE" BY "KOSHER"..
B..PLAINTIFF "RISKS" OF "PAROLE DENIALS" WHEN "LIBRARY" OFFERS "BOARD OF PRISON TERMS" "TYPING SKILLS''PARALEGAL''''LEGAL ASSISTANT" **LEGAL RESEARCH" ECT..AS WELL AS 'ELIGIBILITY OF EMPLOYMENT..AND THE "HIGH STANDARDS OF BPT" AS WELL AS "BPT MANDATORY INSIGHT'' IS FORF ILLED BY LIBRARY AS OF 9-26-09..AND "GRANTING OF PAROLE"..AS UNDER "SHAPIKUS" "INSIGHT" IS "MANDATORY" AS "LAW LIBRARY" FORFILLS THESE STANDARDS OF "BPT"..BY "SCHARZENEGGAR" AND "M. JIMINEZ" "DENIED ..
C..AS AN "ADA" PLAINTIFF "DISABILITIES INCLUDE "UN LEGIBLE" "DOCUMENTS" TO THE COURTS AS REQUIRE 'LEGIBLE DOCUMENTS" WHEN FACTS STATE "TYPED DOCUMENTS" ARE "MORE LIKELY TO BE "HEARD" THAT "NON" "TYPED DOCUMENTS" FOR "ACCESS TO COURT"..."AS OF 4-20-10 ONGOING"..
D.. THE "EDUCATION DEPT AT SOLANO" CONSISTS OF OVER "50" OR MORE "TYPEWRITERS" THAT DO NO MORE THAN MENIAL TYPING OF DAILY "ROSTERS" WHEN LIBRARY "TYPEWRITERS MUST BE LEGAL TYPING"..
E.."CERTIFICATION OF LAW LIBRARY!! IS "MANDATORY" AS "SAME "STA TUS" AS A "CHURCH".. WHEN MANDATORY TO HAVE "PULLPIT'' AS "LAW LIBRARY" "MUST HAVE TYPEWRITERS".... EQUAL PROTECTION OF LAW"..AS "WARDEN BROWN 'HAVILAND'SISTO "ISWARTHOUT ARE AWARE OF THE "LIBRARY'' PROBLEMS ECT.
F.."INMATE WELFARE FUNDS" MEAN "MONIES" "WILLFULLY CONFISCATED" WHEN PLAINTIFF PURCHASE FROM "CDCR VENDORS' ECT..AS THESE "MONIES" ARE 'SUPPOSE TO BE USED FOR "TYPEWRITERS' SPORTS EQUIPMENT'"'MOVIES".. AS THE "RISKS OF FREEDOM BY DENIAL OF PAROLE' WHEN "PROPOSITION # 9" ''MANDATE UP TO 15 YEAR DENIALS' BY "BPT''..AS OF 9-16-09''ONGOING".. WHEN "PROPOSITION #9 IS BEING 'ILLEGALLY USED OF 7-14-10 AS PLAINTIFF "ARRESTED" OF 6-6-89 BY "BPT' AND 'SCHARZENEGGAR"..AS "EX POST FACTO"..
IST, 5TH & 14TH..
. 6..
Case 2:09-CV-01516-MCE-KJM Document 31 Filed 04/27/10 Page 7 of 10
"DEFENDANTS": # 5., "CAMPAIGN OF HARASSMENT"
1.."GREEN". "ABUSE OF AUTHORITY" BY
2.. "CORNELIOUS".. "RETALITORY TACTICS"..
3.. "OYEYEMI".. "WILLFULLY"..
UPON "ARRIVAL OF 11-14-08" PLAINTIFF WAS "ASSIGNED" "COUNS ELOR GREEN". WHOM DUTIES IS TO "RECORD FROM C-FILES" "CORRECT" AND "LEGAL AUTHENTIC" "CERTIFIED DOCUMENTS" INFORMATION TO "ENHANCE" "CHANCES OF PAROLE BY BPT" BY "JOBS, "EDUCATION" BY GPL" "CHRONOS" AS BUT ON 12-2-08 THE DATE OF "INITIAL 3 PANEL CLASSIFICATION PLAINTIFF WAS "REFERRED AS A MENTAL DISORDER OFFENDER" OR "MDO" "WITHOUT NOTICE" OR "CHANCE TO APPEAL"..AS ACTS OF 12-2-08 WERE "WILLFULY" WHEN PLAINTIFF "PRESENT" AT "HEARING OF 12-2-08"..WHEN UPON "Z" OR MORE "REQUESTS" "COUNSELOR GREEN" REFUSED TO SEND A "COPY"' OF SAID "CLASSIFICATION HEARING" OF 12-2-08..
B. PLAINTIFF THROUGH "APPEALS OFFICE" FINALLY FORCED "GREEN" TO "PRODUCE A COPY" OF SAID HEARING AS "RECEIVED 3-5-09". AS THE STATED "INFORMATION IS CONTAMINATED" AND "RISKS OF PAROLE OF 8-9 10 BY BPT" IS "HINDERED" OR "CHANCES ARE "NON EXISTANT"..WHEN "NO DIPLOMA" WITH AN "EALSE" GPL OF 4.0"..AS "PATTERN" OF "RISKS" OF "PAROLE" BY "CORNELIOUS" FOR ACTS DID OF 6-6-07 AT "CMC" WHEN "WILLFULLY PLACED IN SCHOOL" WHEN HAVE "HIGH SCHOOL DIPLOMA" OF "1971"..AND UPON "APPEAL" WAS WRITTEN UP" BY SAME LADY WHOM TOOK "APPEAL" OF 6-6-07..WHEREBY "CONTAMINATING ENTIRE C FILES". AS A "RIGHT TO WORK PIA""''DENIED" AS OF 12-2-08"ONGOING" WHEN "WORKED" "PIA"""PRIOR TO WRITE UP OF 6-6-07" FOR ALLEGED "NOT PARTICIPATING AS "INJURY" INCLUDES "DENIAL JOBS''TRADES" "A-1-A" STATUS"..ECT.. - AS "ONGOING" AS OF 4-24-10.. "RISKS OF DENIAL OF PAROLE''INCREASED.
C.. THE "REFERRAL AS A MDO" CONSISTS OF "RISKS OF POSSIBLE TASCADERO" HOUSING WITH "MANDATORY MEDICAL"MEDICINES" TO THWARF THINKING CAPACITY" ECT..AS ACTS BY "GREEN" OF 12-2-08" "NEGATE" ""PAROLE ELIGIBILITY" BY "CONTAMINATED C FILES" WHEN "GREEN" IS "SCHEDULED" TO DO PLAINTIFFS "BOARD OF PRISON TERMS" REPORT OF 7-14-10.... "WITH RISKS OF HARM" BY "DENIAL OF PAROLE" WILLFULLY..
TWHEN WILLFULLY WITHELD. BY COUNSELOR GREEN NO NOTICE"..AS OF 2-11-10 "PSYCH OYEYEMI" USED THESE "FALSE REPORTS FOR "BPT"'ASSESS MENT" FOR 7-14-10..TO "MISLEAD" TO DENY "ELIGIBILITY FOR RELEASE" ECT,
IST, 5TH & 4TH #"6.. "WILLFUL CAMPAIGN OF HARASS
MENT" FOR "IST AMENDMENT"
"DEFENDANTS": "PROTECTED RIGHTS"..
1.. "GUERRERO"..
PLAINTIFF UPON "ARRIVAL AT SOLANO ON 11-16-08 WAS "WILLFULLY" "RELOCATED TO A 3-TIER" BUNK AS A "LIFER" PRISONER WHEN "3-TIER BUNKS ARE ILLEGAL". .AS "HIGH RISK OF DISEASES" AS PLAINTIFF DID CONTACT AN "INFECTION" IN THROAT" "NOSE' MOUTH" ECT..WHEN BUNKS ARE "SIMILIAR TO A DEAD PERSONS COFFINT WHEREAS "CANNOT" "SIT UP OR EXERCISE ON BUNK". . WHEN OTHERS WITH "2-TIER" BUNKS CAN..
B., ON 11-25-08,12-1-08, AND 1-7-09 PLAINTIFF WAS WILLFULLY "HARASSED''''THREATENED" BY "C/O GUERRERO" TO SIT ON "STOOL" FOR "COUNT" AS THERE ARE "SPECIAL STOOLS" FOR "3-TIER" "BUNKS" WHERE AS SHOWING KNOWLEDGE" OF VIOLATIONS OF 8TH..BY WARDEN SISTO" "JIMINEZ" "HAVILAND""""BROWN" "SWARTHOUT'"''TILTON". . ECT..WHEN "RISKS OF DISEASE "VIOLENCE""''WHEN "DISINFECTANT DISALLOWED" TO "POPULATION" WHEN OTHER PRISONS HAVE 'DISINFECTANT DISPENSERS". AS "BASIC HUMAN NEEDS". AS "RELOCATED OF 1-17-09 AFTER WROTE GUERRERO" UP.. "AS" PLAINTIFF "PRIOR CONTRACTED" THE TTB VIRUS" OF 5-1-05 IN"OVERCROW DED""PRISONS" UNDER HERNANDEZ,MARSHAL, SISTO"..ECT.. IST,5TH 8TH, 14TH..
"ONGOING AS OF 4-20-10"..
Case 2:09-CV-01516-MCE-KJM Document 31 Filed 04/27/10 Pages Enfantsh.
1. TOSHIRO".. "OVERALL IMMINENT DANGER EXCEPTIONS" #7.. 2.."BRAVO"..
UNDER "28 USC 1915"..
3.. "SGT ARMENTA".. "WHEN WILLFULLY""TRANSFERRED" FROM
4. "ESPINOZA".. "PRISON TO PRISON"
** 5.."SGT CLARKE".. TO THWARF LITIGATIONS"ECT..
6..''BELTON".. AS "PATTERN"..
7.. SORIANO".. ***8.. "CASTILLO"..
E
EN
PLAINTIFF "COMMITTMENT OFFENSE"''NEGATES" INTEGRATION" UNDER THE "JOHNSON" AND "CDRC RULES" BUT PLAINTIFF "WILLFULLY RETALIATED" BY "COUNSELOR OSHIRO" OF 6-1-08 WHEN HE "WILLFULLY APPROVED" PLAINTIFF FOR "INTEGRATED CELLMATE WHEN INTEVIEWED" PERSONALLY WITH "CONTAMIN ATED" "C FILE" UNDER "3269" IS "WILLFUL ERROR" AS DONE TO "CAUSE HARM" TO "RETALIATE" TO INJURE" ECT..FOR "IST AMENDMENT PROTECTED RIGHTS OF" "ACCESS TO COURT" FOR "FILING GRIEVANCES" ECT..AS ARRIVED AT "CMC ON 3-27-07 FROM DONOVAN ..AS "APPEALS COORDINATORS" VELA" AND "ENGLER" "WILLFULLY" REFUSED TO ENTERTAIN APPEALS FOR 3269 VIOLATIONS AS WAS "TRANSFERRED ON 11-14-08 TO "SOLANO"..AS "TRANSFER FROM PRISON" TO PRISON" TO "THWARF"IMMINENT DANGER EXCEPTION"..WHEN "UNREASONABLE RISKS" TO "CAUSE HARM" BY "OSHIRO" UNDER "MARSHAL"..
(A)..THE "C FILE" IS "SAME REPORTS" USED BY "PSYCH OYEYEMI" OF 2-11-10 TO DO "BPT REPORT" FOR SCHEDULED HEARING OF 7-14-10.. AS WELL AS THE "WILLFUL MDO" REFERRAL OF 11-14-08 BY "COUNSELOR GREEN"."'CONTAMINATION"..
(B)..PRIOR TO "TRANSFER" TO "CMC" OF 3-27-07 ON 9-29-06 PLAINTIFF WAS "WILLFULLY ASSAULTED" BY "GUARDS BRAVO" "ARMENTA" ECT WHILE SITTING "TYPING" IN "LAW LIBRARY" AS OVER 200 PAGES OF LEGAL DOCUMENTS WILLFULLY "STOLEN"DESTROYED" BY "ARMENTA" AS WELL AS "PRESCRIPTION EYEGLASSES" AS TOOK "7 MONTHS TO "REPLACE".. "WILLFULLY SEGREGATED" FOR "108""DAYS.."FALSELY".
(C)..ON 11-27-05 PLAINTIFF WAS "WILLFULLY SEGREGATED FOR "45" DAYS".. BY "GỦARD. ESPINOZA" ON "FALSE CHARGES"..
(D)..ON 8-9-05 PLAINTIFF "WILLFULLY SEGREGATED" AGAIN ON "FALSE" AND MISLEADING CHARGES BY "SGT CLARKEN AS USED "FALSE EVIDENCE" TO "SEGREGATE" FOR "75 DAYS" AS "VICTIM BELION_""'FIRED FROM JOB ILLEGALLY WRONGFUL BY CLARKE.
-- (E)..ON 10-4-06 DEFENDANT "SORIANO" WILLFULLY "WROTE FALSE'"'WRITE UP" ON PLAINTIFE-FOR "REFUSING TO CELIV WITH ANOTHER "RACE" UNDER "OPERATIONAL PROCC UDER" # 85..WHEN "EFFECTIVE DATÉ-OF-0.P. # 85" WAS, IS-12-1-06..AS "GUILT" FI NDINGS" MEANT RELEIVING OF ALL PERSONAL PROPERTY"! UNDER 3190"..AS "ASSESSED" 160 DAYS".. OF 10-25-06. UNDER "HERNANDEZ'"'TILTON..AS "3 WRITE-UPS! --OF 8-9-05 11-27-05 AND 9-29-06 "ALL DISMISSED"..AS ON-LAST-- WRITEUP OF 9-29-06 THE "ENT IRE YARD" WAS CLOSED BY "HERNANDEZ AND "TRANSFERRED"-OVER 1,000 PRISONERS..
(F)..ON 6-30-07 PLAINTIFF "BLACK CIVIL RIGHTS" SCRAPBOOK" WAS. WILLFULLY
"DESTROYED" BY "CASTILLO""'WITHOUT NOTICE" OR "CHANCE TO APPEAL"..OR "RELIEF.. (DEFENDANTS)
IST 5TH 8TH & 14TH #8.. RIGHT PRIVILĒGET TO "POSSESSIV'S".. 1.."SWARTHOUT". 2.. "SISTO".. PLAINTIFF STATE THE "RIGHT TO POSSESS TELEVISIONS" BY "LIFERS" "ADA'S"
"RIGHT""''PRIVILEGE" IS BEING DENIED BY WARDEN' SWARTHOUT" BASED ON "UNCOD ED" BUILDINGS # 19 AND #24 OF "SOLANO" WHEN THE MAIN "LIFER BUILDINGS" # 20-23 ARE NOT FIRE HAZARD" OR "SECURITY" VIOLATIONS ARE ADMITTED BY "SWARTHOUT" DATED 3-23-10..AS OF 4-20-10 THE STATE OF "OVERCROWDING" AS "POPULATION WISE" FORCES "100" PRISONERS PER TELEVISION WITH A "SERIOUS" AND "EXTREME RISK OF VIOLENCE".. WHEN "PROPOSITION # 9" BY "BPT'I AND.GOV. ERNOR SCHARZENEGGAR" MANDATES UP TO "15 YEAR DENIAL TO "LIFERS" OR NEW "SENTENCE" WHEN "EX POST FACTO" WHEN PLAINTIFF ARRESTED 6-6-89..WHEN "NO" 'JOBS'"TRADES" ECT TO OCCUPY "IDLE TIME OF PLAINTIFF PRISONERS" ECT. .AS OF 4-24-10 "TELEVISIONS" "ALLOWED" "BUT" UNDER "ATTRITION" WHEN "BROKEN ECT.. WHEN REASONS STATED BY "SISTO"""SWARTHOUT ARE "INACCURATE" "WRONG!" DECEPTIVE". WITH "RISK OF HARM'"VIOLENCE.. TO "CAUSE HARM ECT. BY DISABILITIES AND "EXTENDED TERMS IN PRISONS" UNDER "PROP # 9"..ECT.. IST 5TH 8TH & 14TH..
8.