CIV 141027 CIV DS 1416170 CASEEN 130002

0

I

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System Code

CIV

Case Number

DS1416170

CaseType

CIV

Action Code

CASEEN

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Action Date

10 27 14

A PART OF THE OFFICIAL RECORD
YOU WILL NOT BE CHARGED FOR

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THIS COVERSHEET IS FOR COURT

TH I S PAG E

Complaint and Party information entered

7

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

h

1

1

L Wallace Pate

SBN 79523

Esq

LAW OFFICES OF L WALLACE PATE

2 9903 Santa Monica Boulevard Suite 3100
3

Beverly

Hills CA 90212

Telephone

I L

SUPERIOR COUR7
Cp

310 203 2210

NTY

pF

FQ

RNARp I p

RNAF DINO ISTf ICT
Q T
1

4
5

OF SAN

Attorneys for Plaintiffs
1

6

d K

csi

cL

p

LEANDRA HENDRIX DEPUTY

7
S
9
10

SUPERIOR COURT FOR THE STATE OF CALIFORNIA

11
COUNTY OF SAN BERNADINO

12
13

CASE NO

DEANDRE JONES REANDRENE JONES

I

70

ISAIAH SAIS SALEENA GALVAN

14 MARK GALVAN

SURPRISE ADAMS

SHAWNA ADAMS individuals

15

SUAVE

DYSON minor by and through his Guardian
Ad Litem Robert Miller

16
1

1g
19
20
21

COMPLAINT FOR DAMACES
DEMAND FOR JURY TRIAL

Plaintiffs
DEMAND IN CONTROVERSY EXCEEDS

vs

25 000
INTERIM CARE FOSTER FAMILY

AGENCY a California Corporation
SUKHWINDER SINGH FREDDIE
WILSON AJAY MALHOTRA
BHUPINDER CHHUDU KHUSHANUD
AZARIAH JOEL DOMINGUEZ

SHAHZIA RAMNIT LISA OATES

22 NAWAB WILSON Individuals and DOES
1 50 inclusive

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

1

Plaintiffs DEANDRE JONES REANDRENE JONES ISAIAH SAIS SALEEN

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

6

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

At all times herein

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

14 Trademark Street A Rancho Cucamonga California 91730
15
16

3

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

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

certified by INTERIM in violation of Health and Safety Code Section 1508
4

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

Federal Foster Care Funds

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

26 OATES WILSON and defendants seven facilities
27
28

5

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

2

COMPLAINT

4

GENERAL ALLEGATIONS

1
2

1

Plaintiffs DEANDRE JONES REANDRENE JONES ISAIAH SAIS SALEEN

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

and defendants uncertified LISA OATES and NAWAB WILSON

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

14 Trademark Street A Rancho Cucamonga California 91730
15
16

3

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

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

certified by INTERIM in violation of Health and Safety Code Section 1508
4

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

Federal Foster Care Funds

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

26 OATES WILSON and defendants seven facilities
27
28

5

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

2

COMPLAINT

i

1
2
3

uncertified facilities while holding said defendants and said facilities out as certified by INTERIM in
violation of

H

S Code Section 1508 placed more dependent children collected lucrative federal state

and county foster care funds perpetrating the kids for cash scam

4

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

H

took no action held out said homeless defendants as

children

S Code Section 1508 placed more dependent children

g

certified

9

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

g

Defendant SUKHWINDER SINGH defendant Interim s Chief Financial Officer and

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

H

S Cocle Section 1508

9 Defendant FREDDY WILSON defendant Interim s director 10251 Trademark Street A

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

H

S Code Section 1508

28

3

COMPLAINT

r

At all times herein defendant AJAY MALHOTRA defendant Interim s director 10251

10

1

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

H

S Code Section 1508

6

At all times herein defendant BHUPINDER CHHUDU defendant Interim s director

11

g

10251 Trademark Street A Rancho Cucamonga California 91730 bilked hundreds of thousands of foster

9

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

H

S Code Section 1508

12

12 At all times herein between 11 29 06 and 12 03 10 defendant KHUSHANUD AZARIAH

13

14 employed as defendant Interim s Administrator 10251 Trademark Street A Rancho Cucamonga
15 California 91730 bilked hundreds of thousands of foster care dollars from the U S Dept of Health and
16

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

H

S Code Section 1508

19
20

13 At all times herein between 12 03 10 and 7 22 11 defendant JOEL DOMINGUE employed as

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

facilities were certified

by

INTERIM in

violation of

H

S Code

25

26 Section 1508
27
28

RESERVED 14

17

16

At all times herein between 10 18 11 and 8 30 14 defendant SHAHZIA RAMNIT

4

COMPLAINT

i

1 employed as defendant Interim s Administrator 10251 Trademark Street A Rancho Cucamonga
2 California 91730 bilked hundreds of thousands of foster care dollars from the U S Dept of Health and

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

H

S Code Section 1508

6
7

FIRST CAUSE OF ACTION FOR NEGLIGENCE

g
9

pLAINTIFFS DEANDRE JONES REANDRANE JONES ISAIAH SAIS SALEENA

10
11

GALVAN MARK GALVAN SU1tPRISE ADAMS SHAWNA A AMS SUAVE

12

DYSON AGAINST DEFENDANTS INTERIM SUKHWINDER SINGH FREDDIE

13

WILSON AJAY MALHOTRA BHUPINDER CHHUDU

14

KHUSHANUD AZARIAH JOEL DOMINGUEZ SHAHZIA RAMNIT LISA OATES
15

NAWAB WILSON and DOES 1 20
16
1

18

Plaintiffs reallege pars 1 17 as though fully set forth herein

18

19

On 8 18 06 the Department sent written notification to defendants FREDDIE WILSON

19

AJAY MALHOTRA and BHUPINDER CHHUDU that defendant Interim applied for a license to operate

20

a foster farnily agency and named defendants as its board members
21
20

The Department

s notification

further

stated

It is important for you to understand that if

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

Regular board of directors meetings is

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

Y

22

1

2
3

California Code of Regulations Title 22 Section 88063 imposed mandatory statutory

duties on defendant Interim s directors defendants FREDDIE WILSON AJAY MALHOTRA and
BHUPINDER CHHUDU

c to actively ensure accountability and perform at a minimum the following

4

1 establish and approve policies and procedures governing the operation of defendant

responsibilities

5
Interim

2

approve and monitor a

budget for defendant Interim

3

access and maintain the level of

funding necessary to cover the costs of operating defendant Interim
23

g

Title 22 Sections 80001 O 3 and 88018 d imposed mandatory statutory duties on

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

licensing statutes and regulations
12
24

13

Title 22 Section 88035 imposed responsibility on defendants directors FREDDIE

14 WILSON AJAY MALHOTRA and BHUPINDER CHHUDU for dependent children placed in defendant

15 Interim s custody
16

25 Title 22 Section 88063 a imposed mandatory statutory duties on defendant Interim to

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

California Code of Regulations Title 22 section 88001 a 2

Title 22 Sections 88001

c

2

88030 b imposed mandatory statutory duties on

28 defendants administrators KHUSHANLJD AZARIAH JOEL DOMINGUEZ and SHAHZIA RAMNIT to

6
COMPLAINT

i

1

sign Certificates of Approval on defendant Interim s family homes
29

2
3

Title 22 Section 88001 c imposed mandatory statutory duties on defendants

administrators KHUSHANUD AZARIAH JOEL DOMINGUEZ and SHAHZIA RAMNIT to issue

4

Certificates of Approval on defendant Interim s family homes
5
30

Under Section 88001

3

c

c

4

a certified family home means a residence certified by a

6

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

Title 22 Section 88030 b imposed mandatory statutory duties on defendants

11

administrators KHUSHANUD AZARIAH JOEL DOMINGUEZ and SHAHZIA RAMNIT to provide
12
13

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

upon a change of location or certified parents

16

32

Under Section 89201

Completed Application

11

means

A the applicant has

17

submitted and the licensing agency has received all required material and B the licensing agency has
18
19

completed a site visit to the facility
33

20
21

Name

Under Section 89218

and address of

22
renting

3

the

applicant

c

T he application and supporting documents shall include 1

2 Name and address of owner of premises if applicant is leasing or

A copy of the document s that establish that the applicant has control of the property to be

23
licensed
24
34

Under Section 80001

a

b

an application for a Certificate of Approval includes a Plan of

25

26 Operation completed by the applicant
27
28

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

1

2 For licensing agency approval and shall be reported to the Department
3

37

Under Section 89218

The application shall be filed with the licensing agency which

e

4

services the geographical area in which the home is located
5

38 Title 22 Section 89227 a imposed mandatory statutory duties on defendants
6

administrators KHUSHANUD AZARIAH JOEL DOMINGUEZ and SHAHZIA RAMNIT to ensure a
site visit to the proposed foster family home is completed as part of the application review process and a
9

determination that all of the requirements of Article 3 of this chapter have been satisfied

10

39 Title 22 Section 89231 a imposed mandatory statutory duties on defendants

11

Administrators KHUSHANUD AZARIAH JOEL DOMINGUEZ and SHAHZIA RAMNIT to issue a
12
13

license to the applicant after an application has been completed an in home visit has been made pursuant

14

to Section 89227

15

Article 3 of this chapter have been met

16

40

subsection

a

1

upon determination that all licensing requirements set forth in

and

Section 89234 imposed mandatory statutory duties on defendants OATES WILSON to

17

provide defendant Interim with reasonable notice prior to any change in the location of the home as
18
specified

in Section 89361

subsection

d

19
41

20

Under H

S Code section 1503 5 a facility shall be deemed an unlicensed

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

a

a

home

that

89201 C

Under Title 22 Sections 80001

2

is

providing

held

out as or represented as

and

H

S Code section 1503 5

care and supervision

includes

3

A licensed

home that moves to a new location

43

H

S Code Section 1531 5

c

child abuse

states

s

COMPLAINT

means a situation in which a

1
2
3

child suffers

other

from any

one or more of

than accidental means

going without necessary

and

2 Harm

basic

the

following

by

reason of

1 Serious physical injury inflicted upon the child by
intentional

neglect or malnutrition or sexual abuse

3

4 Willful mental injury negligent treatment or

physical care

4

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

in accordance with regulations prescribed by the Director of Social Services

9

S Code Sections 1531 5

44 Under H

g

3

c

and

4

necessary and basic physical

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

S Code Section 1531 5 c 3 and 4 based on

the abuse of a dependent child pursuant to H

14
placement

in

uncertified

community

care

facilities in

violation of

H

S Code Section 1508

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

S Code Section 1531 5 c

to H

3 and 4 based on

18
placement

in

uncertified

community

care

facilities in

violation of

H

S Code Section 1508

19
47

20
21
22
23

A

child placed

constitutes an unusual

or

safety

of

any

child

in

incident

an uncertified

c

child abuse under

H

violation of

Section 88061

under

constituting

home in

H

S Code Section 1508

4 that threatens the physical or emotional health
S Code Section 1531 5

c

3

4 mandating a

report under Penal Code Section 11166

24
48

Section 88061 g imposed mandatory statutory duties on defendant Interim to report child

25
abuse under

26

Health

and

Safety

Code Section 1531 5

c

3

4 based on placement in uncertified homes in

27 violation of Health and Safety Codes Section 1508
28

49 Section 88061 h imposed mandatory statutory duties on defendant Interim to provide a log

9

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

4

maintain current admission agreements with each certified parent with whom the children were placed
5
51

Section 89200 a imposed mandatory statutory duties on defendant Interim to ensure

6
compliance with all applicable law and regulations
g
9
10

52

Under Section 89201

d

Deficiency means any failure to comply with any

1

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

Under Section 89201

s

Serious Deficiency means any deficiency that presents an

1

12
13
14

15
16

immediate or substantial threat to the physical health mental health or safety of any child in the home
54

Under Section 89201

p

4

Provision

or provide

means whenever any regulation

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

been met by some other means
18
19

55

Under Section 89201

1

Licensed Home means a home that is licensed by

2

20 Community Care Licensing in accordance with the standards set forth in Article 3 ofthis chapter The
21
22

license cannot be transferred to another person or location
56

Under Section 89201

Unlicensed Community Care Facility means a facility as

1

u

23
defined in Section 1503 5

of

the H

S Code

24
57 Under Section 89201

u

1

C

3

89201 U

1 O 3

Unlicensed Community Care

25

26 Facility means a licensed home that moves to a new location
27

58

Section 89205 imposed mandatory statutory duties ori defendant Interim not to operate

28

io

COMPLAINT

r

1

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

a

An unlicensed facility as defined in Section 89201 u 1 is in

4

violation of Section 1503 5 and or 1 508 of the Health and Safety Code
5

60 Section 89206 d imposed mandatory statutory duties on defendant Interim to issue an
6

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

imposed mandatory statutory duties on defendant Interim to notify

the appropriate placement or protective service agency of an immediate threat to clients health and safety

11

62 Health and Safety Code Section 1508 imposed mandatory statutory duties on defendant
12
13
14

Interim not to operate establish manage or maintain uncertified homes

63 Health and Safety Code Section 1508 imposed mandatory statutory duties on

15 defendants administrators KHUSHANUD AZARIAH JOEL DOMINGUEZ and SHANZIA RAMNIT
16

not to operate establish manage or maintain uncertified family homes

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

operate establish manage or maintain uncertified family homes

23
66

Section 89240 a imposed mandatory statutory duties on defendants administrators

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

t

68

1

Under Health

and

Safety

Code

section

1550

T he department may deny an

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

a

and

following grounds

the manner provided

in this

for any of the following

chapter

of the rules and regulations promulgated under this chapter b

the licensee

by

in

5

6

Aiding abetting or permitting the violation ofthis chapter or of the rules and regulations promulgated
under

g

this chapter

individual in

or

c

Conduct which is inimical to the health morals welfare or safety of either an

receiving

from the

services

facility

or

the people of the

State

of

California

Engaging

9 in acts of financial malfeasance concerning the operation of a facility including but not limited to
10

fraudulent app rop riation for personal gain

of

facilit Y

moneY s and

P roPertY

or willful or ne g li gent failure

11
to provide services

12
69

Under Section 89361

a

each caregiver shall furnish such reports to the

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

4

Any

suspected physical or psychological abuse of

any

child

d

17

When there is a change in the location of the home the caregiver shall notify the licensing approval agency
18

30 days prior to the move or as soon as the information is available
19
20

70

21

limited to

22

Under Section 89372

the

furnishings

following

each child shall have personal rights which include but are not

1 To be accorded safe healtliful and comfortable home accommodations

and equipment appropriate

to his her

needs

2 To be treated with respect and to be free from

23
sexual

physical

emotional or other abuse

4 To be free from corporal or unusual punishment infliction

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

5

To receive adequate and

6 To be provided adequate clothing and personal items in accordance with Section

1z
COMPLAINT

1
2

89372 O 3

B To

necessary medical

possess and use

dental

vision

his her

own personal

and mental

health

items

services

including toiletries

8 To receive

10 To have social contacts with people

3 outside of the foster care system such as teachers church members mentors and friends in accordance
4
with

Section 89372

c

3

11

To

contact

family

members

unless prohibited

by

court order

16 To make

5

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

g

consistent with the child

9

accorded dignity in his her personal relationships with other persons in the home

10

1

s age and

law

23 To be

Section 89376 a imposed mandatory statutory duties on certified parents to provide

11

or ensure at least three nutritious meals per day
12
72

13

Section 89376 a imposed mandatory statutory duties on certified parents to ensure

14 foster children have their meals with foster family members in a family setting
15

73

Section 89378 a imposed mandatory statutory duties on certified parents to provide

16

care and supervision as necessary to meet each child s needs
17
74

Section 89379 a imposed mandatory statutory duties on certified parents to provide

18
19

opportunity for and encourage participation in group sports leisure time family special school and daily

20 living skills activities
21
22

75

On 12 1 06 the Department of Social Services Department issued defendant Interim

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

issued defendants OATES WILSON a Certificate of Approval on 11 16 06

77 On or about 12 11 06 defendant Interim placed plaintiffs JONES dob 5 3 95 then age 11

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

1 on 13945 Topmast Drive Helendale California 92342

Facility

3

78

Defendant Interim knew or should have known defendants OATES WILSON violated

4
plaintiffs

JONES JONES

and

11

16

DYSON

s personal rights enumerated

2

in Sections 89372 1

4

5

5
6

B

8

10

9

20

23 in

Facility

1

Topcast

by

but

not

limited

to

1

forced to

6

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

4

11

deprived of adequate food in violation of Section 89376 causing a constant state of

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

15 Wear ill fitting shoes causing permanent injuries
16

9 In or about 6 07 defendants OATES WILSON plaintiffs JONES JONES and DYSON

i
moved

to

Facility

2 on 12547 Dulce Street Victorville The Certificate of Approval defendant Interim

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

80 Defendants OATES WILSON breached mandatory statutory duties imposed

21
22

S Code Sections 1524 1503 5

H

by H

S Code

Section 1534 and Title 22 Sections 89234 d by failing to report a change in location to defendant Interim

23

81 Defendants OATES WILSON breached mandatory statutory duties imposed by Section
24
89218

c

25
26

82

by failing

to

submit an application

for

approval on

Facility

2 Dulce

Defendants OATES WILSON breached mandatory statutory duties imposed

by

H

S

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

Defendant Interim provided no supervision over defendants OATES WILSON no site

83

1
to

Facility

2 Dulce

little or no contact with plaintiffs JONES JONES and DYSON putting

2

visit

3

plaintiffs at risk of foreseeable harm knowing or should know plaintiffs suffered ongoing abuse and

4
neglect

5

84

Defendant Interim s administrator defendant KHUSHANUD AZARIAH did not and could no

6
issue

a

Certificate

of

Approval

on

Facility

2 Dulce

given defendants OATES WILSON s violations of

g mandatory statutory duties alleged in pars 80 81 83
9

85

10
g9201

1

2

Facility
2

89201

u

Dulce

was not a certified

89201

1

u

1

C

3

family

89206

a

home

and

pursuant

to Sections 88001

c

3

88005

S Code sections 1503 5 and 1508

H

11

86

Defendants OATES WILSON were not certified parents who met licensing requirements

12
13
14

in
C

uncertified

3

89206

Facility
a

H

2

pursuant

to Sections

88001

4

c

88005

89201 1

2

89201

u

1

89201

u

1

S Code sections 1503 5 and 1508 putting plaintiffs JONES JONES and DYSON at

15 risk of foreseeable harm
16

g

Defendant Interim breached mandatory statutory duties imposed by Sections 88005 88030

17
b

80001

80005 89201

c

89205

89206

a

89227

a

89231

a

H

S Code Sections 1503 5 and 1508

18
19

by

operating

uncertified

Facility

2 Dulce

with no supervision over and little if any contact with

20 plaintiffs JONES JONES and DYSON putting plaintiffs at risk of foreseeable harm knowing or should
21
22

know plaintiffs suffered ongoing abuse and neglect
88

Defendants directors FREDDIE WILSON AJAY MALHOTRA and BHUPINDER

23
CHHUDU

breached mandatory statutory duties imposed

by

H

S Code Section 1508 by operating

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

Defendant administrator KHUSHANUD AZARIAH breached mandatory statutory duties

15

COMPLAINT
o

1

imposed

by

S Code Section 1508

H

by

operating

Facility

uncertified

2 Dulce with no supervision

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

Defendant CEO SUKHWINDER SINGH breached mandatory statutory duties imposed by

90
5
H

S Code Section 1508

6

by

operating

uncertified

Facility

2 Dulce

with no supervision over and

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

Defendant Interim breached mandatory statutory duties imposed by Sections 89206 d

and

H

S Code Section 1547 by failing to issue an immediate civil penalty against defendants

11
OATES WILSON

on uncertified

Facility

2 Dulce

12

92 Defendant Interim breached mandatory statutory duties imposed by Section 86206 fl by

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

H

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

knowing or should know plaintiffs suffered ongoing abuse and neglect
18
93

Defendant Interim

s

breach

of

19
20

failure to notify CPS

21

plaintiffs

22

that

mandatory statutory duties imposed

defendants OATES WILSON

JONES JONES

and

DYSON to

remain

in

moved

to

uncertified

by

an uncertified

Facility

2 in

Section 86206

Facility

by

2 caused

violation of

H

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

ongoing abuse and neglect
94

Defendant Interim s breach of mandatory statutory duties imposed by Section 86206

27 constituted inimical conduct that caused plaintiffs JONES JONES and DYSON to remain in uncertified
28

Facility

2 in

violatiori of

H

S Code Section 1508 as opposed to immediate removal mandated by law

16

COMPLAINT

f

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

4

Defendant Interim breached mandatory statutory duties imposed by Section 89205 holding

95

uncertified

defendants OATES WILSON

and uncertified

2 out as certified to CPS causing

Facility

5
plaintiffs

to remain

in

uncertified

2 in

Facility

violation of

H

S Gode Section 1508

as opposed to

6

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

Defendarit Interim s breach of mandatory statutory duties imposed by Section 88061 CO

96

10

holding

out uncertified

defendants OATES WILSON

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

2

Facility

in

violation of

H

S Code Section 1508 as opposed to

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

s

breach

of

mandatory

statutory

duties imposed

by

section

89206

for

17
failure to

report

defendants OATES WILSON and

Facility

2 Dulce were uncertified in violation of H

18
19

S Code Section 1508 constituted a serious deficiency under Section 89201 s

20 JONES JONES
21
22

and

DYSON to

remain

in

uncertified

Facility

2 in

1 causing plaintiffs

violation of

H

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

Plaintiffs JONES JONES

and

DYSON

s placement

in

uncertified

Facility

2

Dulce in

25
26

violation of

27

and

28

4

and

plaintiffs

H

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

i

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

S Code Section 1508 maridating plaintiffs immediate removal

4

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

2

6
Dulce causing

plaintiffs

to

remain

in

uncertified

Facility

2 in

violation of

H

S Code Section 1508 as

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

11166 for failure to

89201

s

1

report

Facility

caused plaintiffs

violation of

H

2 Dulce was uncertified was a serious deficiency under section

JONES JONES

and

DYSON to

remain

in

uncertified

Facility

2 in

S Code Section 1508 as opposed to immediate removal mandated by law with no

supervision over and little if any contact putting plaintiffs at foreseeable risk of harm knowing or should

17

know plaintiffs suffered ongoing abuse and neglect
18
102
19
20
21

22

11166

Title 22 Sections 89205

and

contact

Defendant Interim s breach of mandatory statutory duties imposed by Penal Code Section

aided

Dulce in

abetted

violation of

86206

and permitted

H

88661

c

among others with no supervision little if any

defendants OATES WILSON

s operation of uncertified

Facility

S Code Section 1508 as opposed to plaintiffs JONES JONES and DYSON s

23

immediate removal mandated by law putting plaintiffs at risk of foreseeable harm knowing or should
24
25
26

know plaintiffs suffered ongoing abuse and neglect
103

2

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

1

uncertified

Facility

2 in

violation of

S Code Section 1508 unbeknownst to said government funding

H

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

Defendants directors FREDDIE WILSON AJAY MALHOTRA and BHUPINDER

6
CHHUDU breached mandatory statutory duties imposed

by

Section 88063

c

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

H

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

14 plaintiffs suffered ongoing abuse and neglect
15
16

105

Defendants directors FREDDIE WILSON AJAY MALHOTRA and BHUPINDER

CHHUDU breached mandatory statutory duties imposed

by

Section 88063

c

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

H

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

Defendants directors FREDDIE WILSON AJAY MALHOTRA and

25
26

BHUPINDER CHHUDU breached mandatory statiztory duties imposed

by

Section 88063

c

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

J

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

H

S Code Section 1508 unbeknownst to said government funding

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

Defendants directors FREDDIE WILSON AJAY MALHOTRA and BHUPINDER

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

H

S Code Section 1508 unbeknownst to the above

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

owing or should know plaintiffs suffered ongoing abuse and neglect

13

108

14

Defendant CEO SUKHWINDER SINGH engaged in acts of financial malfeasance based on

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

H

S Code Section 1508 unbeknownst to said

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

shoulcl know plaintiffs suffered ongoing abuse and neglect

22

Defendants OATES WILSON engaged in conduct inimical to plaintiffs JONES JONES

109

23
and

DYSON

s

health

rnorals

welfare

and

safety

by

operating

uncertified

Facility

2

Dulce in violation

24
of

25

S Code Section 1508 unbeknownst to above alleged governmental funding agencies
110

26
27 for
28

H

plaintiffs

Defendants Oates and Wilson engaged in acts of financial malfeasance based on payments
JONES JONES

Oates Wilson

and

Facility

and

DYSON

s

placement in

uncertified

2 Dulce were certified

Zo

COMPLAINT

Facility

2 on pretext defendants

f

Defendant Interim knew or should have known and defendant WILSON observed

111

1

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

5

day

forced DYSON

to wear ill

fitting shoes

that caused permanent

disability

damage

forced plaintiffs to

6

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

2 forced plaintiffs to walk or ride a bike

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

In or about 9 07 defendants OATES WILSON plaintiffs JONES JONES and

moved

location

to

Facility

3

Pool

17
113

Defendants OATES WILSON breached mandatory statutory duties imposed by

18
19

H

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

Defendants OATES WILSON breached mandatory statutory duties imposed by
c

by failing to

submit an application

to defendant Interim for

approval on

Facility

3

23
Pool
24
115
25

Defendants OATES WILSON breached mandatory statutory duties imposed by

S Code Section 1534 and Title 22 Sections 89234 d and 89361 d by failing to obtain a Certificate of

26

H

27

Approval from defendant KHUSHANUD AZARIAH

2g

116

on

Facility

3

Pool

Defendant Interim s administrator defendant KHUSHANUD AZARIAH did not

21
COMPLAINT

J

1

and could not

issue

a

Certificate

of

Approval

on

3 Pool under Section 89240 a given

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

4

harm as opposed to immediate removal mandated by law knowing or should know plaintiffs suffered
5
6

ongoing abuse and neglect
117

3 Pool was not a certified family home pursuant to Title 22 Sections

Facility
88005

89201 1

2

89201

1

89201

1

C

3

89206

a

and

H

S Code Sections

g

88001

9

1503 5 and 1508 putting plaintiffs JONES JONES and DYSON at foreseeable risk of harm

c

10

3

u

u

Defendants OATES WILSON were not certified parents who met licensing requirements in

118

11
uncertified

Facility

3

pursuant

to Sections 88001

c

4

88005

89201 1

2

89201

u

1

89201

u

1

12
13

C

3

89206

H

a

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

3

Pool

breached

18
19
20

mandatory statutory duties imposed

89206

a

89227

a

89231

a

and

by
H

Sections 88005

88030

b

80001

80005 89201

c

89205

S Code Sections 1503 5 and 1508 with no supervision little if

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

Defendants directors FREDDIE WILSON AJAY MALHOTRA and

25
26

BHUPINDER CHHUDU breached mandatory statutory duties imposed

27

operation of uncertified

Facility

by

H

S Code Section 1508 by

3 Pool with no supervision little if any contact putting plaintiffs

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

3

Defendant administrator KHUSHANUD AZARIAH breached mandatory statutory

121

2

duties imposed

H

by

S Code Section 1508

by

operation of uncertified

3

Facility

Pool

with no

4

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

Defendant CEO SUKHWINDER SINGH breached mandatory statutory duties

122

g

imposed

by

S Code Section 1508

H

by

operation of uncertified

Facility

3

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

Defendant Interim breached mandatory statutory duties imposed by Sections 89206 d

123

14
g9255
Oates

and

and

S Code Section 1547 by failing to issue an immediate civil penalty against defendants

H

Wilson

on uncertified

Facility

3

Pool

17
124

Defendant Interim breached mandatory statutory duties imposed by Section 86206 fl by

18
19

failing to notify the CPS placement agency that plaintiffs JONES JONES and DYSON were placed in
Facility

3

Pool

in

violation of

H

S Code Section 1 508 with no supervision little if any

20

uncertified

21

contact putting plaintiffs at risk of foreseeable harm as opposed to immediate removal mandated by law

2

knowing or should know plaintiffs suffered ongoing abuse and neglect

23
125

Defendant Interim

s

breach

of

mandatory statutory duties imposed

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

H

in

uncertified

in

Facility

S Code Section 1508 with

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

3

Defendant Interim

breach ofmandatory statutory duties imposed

by

H

S

1

126

2

Code Section 1508

3

no supervision and little if any contact putting plaintiffs JONES JONES and DYSON at risk of

constituted

s

inimical

causing plaintiffs to

conduct

remain

in

uncertified

3 with

Facility

4

foreseeable harm as opposed to immediate removal mandated by law knowing or should know plaintiffs
5
suffered ongoing abuse and neglect
6

Defendant Interim breached mandatory statutory duties imposed by Section 89205 by

127

defendants OATES WILSON

as certified and

uncertified

Facility

3 Pool

as

g

holding

9

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

H

S Code Section 1508

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

Defendant Interim breached mandatory statutory duties imposed by Section 88061 O by

128

holding

out uncertified

defendants OATES WILSON

and uncertified

Facility

3 Pool as certified to CPS

17

constituting a serious deficiency under Section 89201 s 1 causing plaintiffs JONES JONES and
18
DYSON to

remain

in

uncertified

19

Facility

3

in

violation of

H

S Code Section 1508 with no supervision

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

s

breach

of

mandatory statutory duties imposed

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

H

S Code Section 1508 was a serious deficiency under Section 89201 s 1 causing

remain

in

uncertified

Facility

3 with no supervision and little if any contact putting plaintiffs

27 at risk of foreseeable harm as opposed to immediate removal mandated by law knowing or should know
28

plaintiffs suffered ongoing abuse and neglect

24
COMPLAINT

2
3

Plaintiffs JONES JONES

130

1
Pool

was child abuse under

H

and

DYSON

S Code Section 1531 5

s placement

c

3

4

in

and

uncertified

Facility

3

Inst Code Section 300 b

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

3

S Code Section 1508 causing plaintiffs JONES JONES and DYSON to remain

H

Facility

and

3 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

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

H

JONES

JONES JONES

and

DYSON

s placement

in

uncertified

Facility

3

S Code Section 1508 was a serious deficiency under section 89201 s 1
JONES

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

S Code section 1508

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

i

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

H

S Code section 1508 unbeknownst to said government funding

agencies with no supervision and little if any contact putting plaintiffs at risk of foreseeable harm as

5

opposed to immediate removal mandated by law knowing or should know plaintiffs suffered ongoing abuse
6
and neglect

9
10

Defendants directors FREDDIE WILSON AJAY MALHOTRA and BHUPINDER

135

g

CHUDU breached mandatory statutory duties imposed

by

Section 88063

2 by approving and

c

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

Defendants directors FREDDIE WILSON AJAY MALHOTRA and

136
18
19

BHUPINDER CHHUDU breached mandatory statutory duties imposed

by

Section 88063

c

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

Social Services for

plaintiffs

JONES JONES

and

DYSON

s placement

in

uncertified

Facility

3 in

23
violation of

H

S Code Section 1508 unbeknownst to said government funding agencies with no

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

Defendants directors FREDDIE WILSON AJAY MALHOTRA and BHUPINDER

CHHUDU breached mandatory statutory duties imposed

by

26
COMPLAINT

Section 88063

c

3 by accessing and

f

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

H

S Code Section 1508 unbeknownst to said government funding agencies

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

g

neglect

9
10

138

Defendants directors FREDDIE WILSON AJAY MALHOTRA and

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

H

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

knowing or should know plaintiffs suffered ongoing abuse and neglect
18
139

19

Defendant CEO SUKHWINDER SINGH engaged in acts of financial malfeasance

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

H

S Code Section 1508 unbeknownst to

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

26 suffered ongoing abuse and neglect
27
28

140

JONES

and

Defendants OATES WILSON engaged in inimical conduct fo plaintiffs JONES
DYSON

by

maintaining

uncertified

Facility

3

2

COMPLAINT

Pool

in

violation of

H

S Code Section

1

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

should know plaintiffs suffered ongoing abuse and neglect

4

Defendants OATES and WILSON engaged in acts of financial malfeasance by taking

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

On 11 20 07 defendants OATES WILSON plaintiffs JONES JONES and DYSON moved

142

g
9

and

4 on 14594 Woodworth Way Victorville California

143

Defendants OATES WILSON breached mandatory statutory duties imposed by Sections

11
89234 d

and

89361

d

by failing

to notify defendant Interim

of

the relocation to

Facility

4

12
Woodworth

13
144

14
15

g9218

16

c

Defendants OATES WILSON breached mandatory statutory duties imposed by Section

by failing

145

to

submit an application

The identical factual

scenario

for
in

approval on

76

1l l

Facility

4

with regard

to

uncertified

Facility

2

Dulce

17
and

112

141

with regard

to

uncertified

3 Pool

Facility

repeated with regard to uncertified Facility

18
4 Woodworth

Defendant Interim s administrator defendant KHUSHANUD AZARIAH did not and

19
issue a Certificate

of

Approval

on

Facility

4 Woodworth under Section 89240 a given

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

plaintiffs suffered ongoing abuse and neglect
146

Defendant Interim continued to engage in acts of financial malfeasance based on payments

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

1

Facility

uncertified

4 in

violation

of H

S Code Section 1508 unbeknownst to said government

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

Defendant CEO SUKHWINDER SINGH continued to engage in acts of financial

6

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

H

S Code Section 1508

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

should know plaintiffs suffered ongoing abuse and neglect
148

14

Defendants directors FREDDIE WILSON AJAY MALHOTRA and

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

H

S Code Section 1508 unbeknownst to said government funding agencies

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

Defendants directors FREDDIE WILSON AJAY MALHOTRA and

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

1 Department of Social Services for plaintiffs JONES JONES and DYSON s placement in uncertified
4 in

S Code Section 1508 unbeknownst to said government funding agencies

H

2

Facility

3

with no supervision and little if any contact putting plaintiffs at risk of foreseeable harm as opposed to

violation of

4

immediate removal mandated by law knowing or should know plaintiffs suffered ongoing abuse and
5
neglect

6

Defendants directors FREDDIE WILSON AJAY MALHOTRA and

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

S Code Section 1508 unbeknownst to said

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

Defendants directors FREDDIE WILSON AJAY MALHOTRA and

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

H

S Code Section 1508

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

Defendants OATES WILSON continued to engage in conduct inimical to plaintiffs JONES

25
26
27
28

JONES

and

Woodworth

DYSON

s

health

in violation

of

morals

H

welfare

and

safety

by

operating

uncertified Facility

4

S Code Section 1508 unbeknownst to the above alleged governmental

funding agencies with no supervision and little if any contact putting plaintiffs at risk of foreseeable harm
30

COMPLAINT

1

as opposed to immediate removal mandated by law knowing or should know plaintiffs suffered ongoing

2

abuse and neglect

3

153

4

Defendants OATES WILSON continued to engage in acts of financial malfeasance

by obtaining federal state and county payments for plaintiffs JONES JONES and DYSON s foster care

5
on pretext

defendants

uncertified

OATES WILSON

4

Facility

and uncertified

Woodworth were

6

certified while plaintiffs suffered foreseeable ongoing abuse and neglect
154

g
9
10

On 11 11 07 unlawful detainer Case No UDVS 701833 was filed against defendants

OATES WILSON for

nonpayment of rent

3 534 96

on

1

Facility

13945 Topmast Drive Helendale

California 92342

11
155

On 11 11 07 plaintiffs JONES JONES DYSON and defendants

12
13

OATES WILSON

156

14

resided

in

uncertified

Facility

4 Woodworth

On 12 4 07 defendants OATES WILSON

were evicted

from

1 13945 Topmast

Facility

15 Drive Helendale California 92342 by court order Case No UDVS 701833
16

157

Defendants OATES WILSON

s eviction

from

Facility

1

13945 Topmast

17
Drive

while also

residing in

uncertified

Facility

4

Woodworth

was an unusual incident reportable

18
under Section 88061
19
158

20
21
22

88061

Defendant Interim breached mandatory statutory duties imposed by Section

by failing

to report

defendants OATES WILSON S

eviction

from

Facility

1

13945 Topmast

Drive Helendale California 92342 on 12 4 07

23
159

On 2 1 08 unlawful detainer Case No UDVS 800320 was filed against

24
defendants OATES WILSON for

nonpayment of rent

4 870 00

on uncertified

Facility

4

25
26
27
28

Woodworth

160

DYSON

On 2 20 08 defendants OATES WILSON plaintiffs JONES JONES and

were evicted

from

uncertified

Facility

4 Woodworth Case No UDVS 800320 for nonpayment

31

COMPLAINT

1

4 870 00 unbeknownst to the above alleged governmental funding agencies due to financial

of rent

2 malfeasance of defendants Interim defendants directors FREDDIE WILSON AJAY MALHOTRA

3 BHUPINDER CHHUDU defendant CEO SUKHWINDER SINGH defendant administrator
4

KHUSHANUD AZARIAH and defendants OATES WILSON

5
161

Plaintiffs JONES JONES

and

DYSON

s eviction

from

uncertified

Facility

4

6
Woodworth

g

162

11166

nonpayment of

rent

was child abuse under

H

S Code Section 1531 5

c

3

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

4

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

4

Woodworth was a serious deficiency under Section 89201 s 1 that caused plaintiffs to remain in the

16
custody

ofuncertified

defendants OATES WILSON in violation

of

H

S Code section 1508 with no

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

4

Woodworth due to financial malfeasance of defendants Interim

defendants directors FREDDIE WILSON AJAY MALHOTRA BHUPINDER CHHUDU defendant CEO

23

SUKHWINDER SINGH defendant administrator KHUSHANUD AZARIAH and defendants OATES
24

WILSON constituted an unusual incident under Section 88061 4 and a serious deficiency under Section
25

26 89201 s 1
27
28

165

Defendant Interim breached mandatory statutory duties imposed by Section 88061 4 by

failing to report to the Department that plaintiffs JONES JONES and DYSON were evicted from
32

COMPLAINT

1
2
3

Defendant Interim s breach of mandatory statutory duties imposed by Section 88061 by

166

failing

to

4 Woodworth

Facility

uncertified

report plaintiffs

JONES JONES

and

DYSON

s eviction

from

uncertified

Facility

4

4

Woodworth was a serious deficiency under Section 89201 s 1 that caused plaintiffs to remain in the
5
custody

of uncertified

defendants OATES WILSON in

violation of

H

S Code section 1508 with no

6

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

s

breach

JONES JONES

of plaintiffs

of

and

mandatory statutory

DYSON

s eviction

duty imposed by

from

4

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

defendants OATES WILSON in

violation of

H

S Code section 1508 with no supervision

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

On 3 1 08 plaintiffs JONES JONES DYSON defendants OATES WILSON moved to

168

17

Facility

5 on 13547 Silversand Street Victorville

18

Defendants OATES WILSON breached mandatory statutory duties imposed by

169

19
20
21

Sections 89234 d

and

89361

d

by failing

to notify

defendant Interim

of

the move to

Facility

5

Silversand

22

Defendants OATES WILSON breached mandatory statutory duties imposed by

170

23
Section 89218

c

by failing to

submit an application

for

approval on

Facility

5

Silversand

24
171

The identical factual

scenario

in

79

111

with regard

to

uncertified

Facility

2

25
26

Dulce

112

141

uncertified

Facility

3

Pool

Silversand

158

uncertified

repeated with regard

28

KHUSHANUD AZARIAH breached mandatory statutory duties imposed

uncertified

Facility

33

COMPLAINT

Facility

4 Woodworth

Defendant Interim s administrator defendant

27

to

5

142

by

H

S Code Section 1508 by

1

operating

Facility

5 without a Certificate of Approval defendant Interim made no site visit provided no

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

Defendant Interim continued to engage in acts of financial malfeasance based on

172

6

payments from the U S Department of Health and Human Services California Department of Social
g

Services

9

in

10

and

San Bernadino Department of Social Services for

violation of

H

children placed

in

uncertified

Facility

5

S Code Section 1508 unbeknownst to said government funding agencies with no

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

Defendant CEO SUKHWINDER SINGH continued to engage in acts of financial

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

H

S Code Section 1508 unbeknownst to said government

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

174 Defendants directors FREDDIE WILSON AJAY MALHOTRA and BHUPINDER

21
22

CHHUDU

continued to

breach mandatory statutory duties imposed

by

Section 88063

c

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

H

S Code Section 1508 unbeknownst to said

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

1 ongoing abuse and neglect
2
3

175

Defendants directors FREDDIE WILSON AJAY MALHOTRA and BHUPINDER

CHHUDU continued to breach mandatory statutory duties imposed

by

Section 88063

c

3 by approving

4

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

H

S Code Section 1508

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

plaintiffs suffered ongoing abuse and neglect
11
176

Defendants directors FREDDIE WILSON AJAY MALHOTRA and BHUPINDER

12
13

CHHUDU

continued

to breach mandatory statutory duties imposed

by

Section 88063

c

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

Social Services for foster

care

in

uncertified

Facility

5 in

violation of

H

S

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

Defendants directors FREDDIE WILSON AJAY MALHOTRA and BHUPINDER

CHHLJDU continued to breach mandatory statutory duties imposed by Sections 80000 1 3 and 88018 by

23
operating

uncertified

Facility

5

Silversand in

violation of

H

S Code Section 1508 unbeknownst to

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

Defendant Interim breached mandatory statutory duties imposed by Section 89205

35

COMPLAINT

1 in or about 3 09 by holding out uncertified defendants OATES WILSON and uncertified Facility 5
2

Silversand as certified to the placing CPS agency

3

In or about 3 09 defendant Interim placed plaintiffs siblings S ADAMS dob 10 31 92 and

179

4
S ADAMS 2 8 94 in

uncertified

Facility

5

Silversand

5

Defendants Interim knew or should have known shortly after placement that plaintiffs

180
6
ADAMS

g
9
10

personal rights under

were violated

assaulted

by

by

uncertified

Sections 89372 1

2

4

defendants OATES WILSON

defendant Oates

adult son

Dwayne

5

6

B

including but

8

9

not

10

limited to

11

16

20

23

1 sexually

2 forced to scrub walls floors vacuum and sweep

floors lift rugs move and replace furniture clean toilets kitchen

and bedrooms nightly several hours

11

3 not allowed to eat the same food as defendants OATES WILSON family

deprivation
causing sleep

12
13

4

14 in
15
16

not allowed

to

eat at

constant state of

the same table as

hunger

entering the food pantry

8

6

suffered

defendants OATES WILSON

sleep deprivation

suffered corporal punishment

abuse and neglect of plaintiffs JONES

5

deprived of adequate food

7 prohibited from opening the refrigerator or
physical and mental

abuse

9 witnessed the

JONES and DYSON among others

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

H

of

Social Services for

plaintiffs

ADAMS

placement

in

uncertified

Facility

5

S Code Section 1508 unbeknownst to said government funding agencies with no

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

should know plaintiffs suffered ongoing abuse and neglect
182

Defendant CEO SUKHWINDER SINGH continued to engage in acts of financial

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

1

placement

in

uncertified

Facility

5 in

violation of

H

S Code Section 1508 unbeknownst to said

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

Defendants directors FREDDIE WILSON AJAY MALHOTRA and

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

H

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

Defendants directors FREDDIE WILSON AJAY MALHOTRA and BHUPINDER

18
CHHUDU

continued to

19

breach mandatory statutory duties imposed by Section 88063

c

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

H

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

Defendants directors FREDDIE WILSON AJAY MALHOTRA and

37

COMPLAINT

y

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

Social Services for

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

6

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

plaintiffs suffered ongoing abuse and neglect

10
186

Defendants directors FREDDIE WILSON AJAY MALHOTRA and BHUPINDER

11

CHHUDU continued to breach mandatory statutory duties imposed by Sections 80000 1 3 and 88018 by
12
13

operating

uncertified

5

Facility

Silversand

in

violation of

H

S Code Section 1508 unbeknownst to

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

In or about 3 09 defendant Interim placed plaintiffs siblings S GALVAN dob 7 8 93 and

M GALVAN in

uncertified

5 Silv ersand

Facility

in

H

violation of

S Code Section 1508 in the

21 custody of uncertified defendants OATES WILSON
22

188

Deferidant Interim knew or should know that shortly after placement plaintiffs GALVANS

23
personal rights under

Sections 89372 1

2

4

5

6

B

8

9

10

11

16

20

23 were

24

26

defendants OATES WILSON in

violated

by

plaintiff

S GALVAN S

25

uncertified

sexual

abuse

including

but

not

uncertified

limited to

Facility

5 Silversand in addition to

1 forced to scrub walls floors

27 vacuum and sweep floors lift rugs move arid replace furniture clean toilets kitchen and bedrooms
28
nightly

2

not allowed

to

eat the same

food

as

defendants OATES WILSON

38

COMPLAINT

s

family

3

not allowed to

1
2
3

eat at

6

the same table as

prohibited

defendants Oates

from opening

physical and mental

abuse

the

and

refrigerator

Wilson

or

4

deprived

of adequate

entering the food pantry

7

food

5 sleep deprivation

suffered corporal punishment

8 witnessing the abuse and neglect of plaintiffs JONES JONES and DYSON

4
among others

5

Defendant Interim continued to engage in acts of financial malfeasance based on payments

189

6

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

H

S Code Section 1508 unbeknownst to said government funding agencies with no

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

owing or should know plaintiffs suffered ongoing abuse and neglect
Defendant CEO SUKHWINDER SINGH continued to engage in acts of financial

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

H

S Code Section 1508 unbeknownst

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

Defendants directors FREDDIE WILSON AJAY MALHOTRA and BHUPINDER

191
24
CHHUDU

continued

25

to breach mandatory statutory duties imposed

by

Section 88063

c

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

H

S Code

1

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

Defendants directors FREDDIE WILSON AJAY MALHOTRA and BHUPINDER

6
CHHUDU

continued to

breach mandatory statutory duties imposed

by

Section 88063

c

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

H

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

Defendants directors FREDDIE WILSON AJAY MALHOTRA and BHUPINDER

17
CHHUDU

continued

to breach mandatory statutory duties imposed

by

Section 88063

c

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

H

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

26 suffered ongoing abuse and neglect
27

194

Defendants directors FREDDIE WILSON AJAY MALHOTR A and BHUPINDER

28 CHHUDU continued to breach mandatory statutory duties imposed by Sections 80000 1 3 and 88018 by
40
COMPLAINT

1

operating

uncertified

5

Facility

Silversand in

violation of

S Code Section 1508 with no

H

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

knowing or should know plaintiffs suffered ongoing abuse and neglect
5
195

On 8 25 09 defendants OATES WILSON plaintiffs JONES JONES DYSON and M

6
GALVAN

g

were evicted

from

uncertified

5

Facility

Silversand

for nonpayment of rent for six months

8 400 00 Case No UDVS 902368

9

San Bernadino Sheriffs locked plaintiffs JONES JONES DYSON M GALVAN

196

10
defendants OATES WILSON

out of uncertified

Facility

5 Silversand exercising a Writ of Possession

11

permitting plaintiffs five minutes to retrieve few if any personal belongings carried away in plastic bags
12

Defendants OATES WILSON plaintiffs JONES JONES DYSON and M GALVAN

197

13
14

ere homeless for five months from on or about 8 25 09 to 1 1 10

15

198

16
eviction

from

Defendants OATES WILSON plaintiffs JONES JONES DYSON and M GALVAN s

uncertified

Facility

5 for nonpayment of 8 400 00 rent followed by five months

17
homelessness was due to financial malfeasance of defendants Interim directors FREDDIE WILSON
18
19

AJAY MALHOTRA BHUPINDER CHHUDU

CEO SUKHWINDER SINGH administrator

20 KHUSHANLJD AZARIAH and OATES WILSON alleged hereinabove with particularity
21
22

199

Plaintiffs JONES JONES DYSON

and

GALVAN

s eviction

from

uncertified

Facility

5

for nonpayment of rent and homelessness for five months was child abuse under Health and Safety Code

23
Section 1531 5

c

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

1

1

foreseeable harm as opposed to immediate removal mandated by law knowing or should know plaintiffs

2 suffered ongoing abuse and neglect
3

201

Defendant Interim s breach of mandatory statutory duties imposed by Penal Code Section

4

11166 by failing to report plaintiffs JONES JONES DYSON and GALVAN s eviction from uncertified
5

Facility

5 and homelessness were serious deficiencies under Section 89201 s

1 causing plaintiffs to

6

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

DYSON GALVAN defendants OATES WILSON s eviction

11
from

uncertified

Facility

5 and homelessness due to financial malfeasance ofdefendants Interim

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

15 gg061 4 and a serious deficiency under Section 89201 s 1
16

203

Defendant Interim breached mandatory statutory duties imposed by Section 88061 4 by

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

homeless defendants OATES WILSON in

violation of

H

S Code Section 1508

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

should know plaintiffs suffered ongoing abuse and neglect
24
204
25

Defendant Interim s breach of mandatory statutory duties imposed by Section 88061 by

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

H

q2

COMPLAINT

S Code Section 1508 with no supervision and

1

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

Defendant Interim s breach of mandatory statutory duties imposed by Section 89206 fl by

4

failing to notify CPS of plaintiffs JONES JONES DYSON and GALVAN s eviction and homelessness
5

constituted a serious deficiency under Section 89201 s

1 that caused plaintiffs to remain homeless in

6
the

g

custody

of uncertified

homeless defendants OATES WILSON in

violation of

H

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

Defendant Interim continued to engage in acts of financial malfeasance based on payments

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

defendants OATES WILSON in

violation of

H

S Code Section 1508 unbeknownst

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

Defendant CEO SUKHWINDER SINGH continued to engage in acts of financial

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

defendants OATES WILSON in

violation of

H

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

1

a

i

knowing or should know plaintiffs suffered ongoing abuse and neglect

2
3

208

Defendants directors FREDDIE WILSON AJAY MALHOTRA and BHUPINDER

CHHUDU continued to breach mandatory statutory duties imposed

by Section

88063

c

2 by approving

4

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

On 1 1 10 plaintiffs JONES JONES DYSON M GALVAN defendants OATES

moved

210

g9234 d

to

6 on 13141 Snowview Road Victorville

Facility

Defendants OATES WILSON breached mandatory statutory duties imposed by Sections

and

89361

d

by failing to riotify

defendant Interim of the move to

Facility

6

Snowview

17
211

Defendants OATES WILSON breached mandatory statutory duties imposed by Section

18
19

g9218

c

212

20
21
22

by failing to

Dulce

The identical factual

112

Facility

4

submit an application

141 with

regard

Woodworth

168

for

approval on

scenario alleged

to uncertified

186 with

in

Facility

regard

to

Facility

79

3

111

Pool

uncertifiecl

6 Snowview

with regard

142

Facility

5

to

uncertified

Facility

2

158 with regard to uncertifie
Silversand repeated with

23
regard

to

uncertified

Facility

6

Snowview

Defendant Interim s administrator defendant

24

25
26

KHUSHANLJD AZARIAH breached mandatory statutory duties imposed

failing

to issue

a

Certificate

of

Approval

on

Facility

6 Silversand

by

H

S Code Section 1508 by

defendant Interim made no site visit

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

4

1

suffered ongoing abuse and neglect

213

2

Defendant Interim continued to engage in acts of financial malfeasance based on payments

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

H

S Code Section 1508 unbeknownst to said government funding agencies with no

6

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

9 know plaintiffs suffered ongoing abuse and neglect
10
214

Defendant CEO SUKHWINDER SINGH continued to engage in acts of financial

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

H

S Code Section 1508 unbeknownst to said government

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

Defendants directors FREDDIE WILSON AJAY MALHOTRA and BHUPINDER

CHHUDU

21

and monitoring a budget for defendant Interim based on payments from the U S Department of Health and

22

continued to

breach mandatory statutory duties imposed

Section 88063

20

by

c

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

H

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

abuse and neglect

45

COMPLAINT

r ri

1
2
3

216

CHHUDU

Defendants directors FREDDIE WILSON AJAY MALHOTRA and BHUPINDER

continued to

breach mandatory statutory duties imposed

by

Section 88063

c

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

H

S Code Section

6

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

Defendants directors FREDDIE WILSON AJAY MALHOTRA and BHUPINDER

12
13

CHHUDU

continued to

breach mandatory statutory duties imposed

by

Section 88063

c

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

Social Services for

plaintiff

GALVAN

s placement

in

uncertified

Facility

6 in

17
violation of

H

S Code Section 1508 unbeknownst to said government funding agencies with no

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

know plaintiffs suffered ongoing abuse and neglect
218

Defendants directors FREDDIE WILSON AJAY MALHOTRA and BHUPINDER

23

CHHUDU continued to breach mandatory statutory duties imposed by Sections 80000 1 3 and 88018 by
24

25

operating

uncertified

Facility

6

Snowview

in

violation of

H

S Code Section 1508 unbeknownst to

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

U

219

1
2

operating

3

Defendants uncertified OATES WILSON continued to engage in inimical conduct by

uncertified

220

6

Facility

Snowview

in

violation of

H

S Code Section 1508

Defendants OATES WILSON continued to engage in acts of financial malfeasance

4

by taking

federal

state

and

county

payments

for

plaintiff

GALVAN

s

foster

care

in

uncertified

6

Facility

5
Snowview

in

H

violation of

S Code Section 1508 unbeknownst to governmental funding agencies

6
On

221

g

Snowview

9

222

1 25 10 defendant Interim

or about

defendants Oates

with uncertified

and

placed plaintiff

Wilson in

SAIS in

violation of

uncertified

H

Facility

6

S Code Section 1508

Defendant Interim knew or should have known shortly after placement that plaintiffSAIS

10
personal rights under sections

89372 1

2

4

5

6

B

8

9

10

11

16

20

23

were

11
violated

in

6

Facility

Snowview

including but

not

limited to

1

forced to scrub walls floors vacuum

12
and

13
14
15

sweep floors lift

rugs

food

allowed

to eat the same

table as

defendants 0ates

16
prohibited

move and replace

from opening

as

and

the

furniture

defendants Oates

Wilson

refrigerator

4

or

and

clean

Wilson

toilets

s

kitchen

family

deprived of adequate food
entering the food pantry

3

5

and

bedrooms nightly

2

not

not allowed to eat at the same

suffered

sleep deprivation

6

7 suffered corporal punishment

17
physical and mental abuse

8 witnessed the abuse and neglect of plaintiffs JONES JONES and DYSON

18
19
20

21
22

among

9

others

223

coerced and threatened to lie to social workers

Defendant Interim continued to engage in acts of financial malfeasance based on payments

from the U S Department of Health and Human Services California Department of Social Services and
San Bernadino Department

of

Social Services for

plaintiff

SAIS

placement

in

uncertified

Facility

6 in

23
violation of

H

S Code Section 1508 unbeknownst to said government funding agencies with no

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

Defendant CEO SUKHWINDER SINGH continued to engage in acts of financial

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

H

S Code Section 1508 unbeknownst to said

4

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

9

Defendants directors FREDDIE WILSON AJAY MALHOTRA and BHUPINDER

225

g

CHHUDU

continued

to

breach mandatory statutory duties imposed

by

Section 88063

c

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

H

S Code Section 1508

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

Defendants directors FREDDIE WILSON AJAY MALHOTRA and BHUPINDER

continued to

breach mandatory statutory duties imposed

by

Section 88063

c

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

H

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

abuse and neglect

4s
COMPLAINT

2
3

Defendants directars FREDDIE WILSON AJAY MALHOTRA and BHUPINDER

227

1

CHHUDU

continued to

breach mandatory statutory duties imposed

by

Section 88063

c

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

Social Services for

plaintiff

SAIS

placement

in

uncertified

Facility

6 in

6
violation of

H

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
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

6

Snowview

in

violation of

H

S Code Section 1508 unbeknownst to

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

In or about 12 10 defendant JOEL DOMINQUEZ came on board as defendant Interim s

Administrator

22

230

Defendant JOEL DOMINQUEZ continued to

operate uncertified

Facility

6 Snowview

23
certified

in breach

of

mandatory duties imposed

by

H

S Code Section 1508 unbeknownst to said

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

I

2

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

3

Facility

6

Snowview

defendants OATES WILSON plaintiffs JONES JONES DYSON and SAIS

4
were evicted

from

uncertified

Facility

6 Snowview by court order No UDVS 1004160 unbeknownst to

5

governmental funding agencies alleged herein
6
233

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

9 WILSON AJAY MALHOTRA BHUPINDER CHHUDU CEO SUKHWINDER SINGH and
10

administrator JOEL DOMINQUEZ alleged hereinabove with particularity
11
234

Defendant Interim breached mandatory statufory duties imposed by Penal

12

13 Code Section 11166 by failing to report plaintiffs JONES JONES DYSON SAIS eviction from
14

Facility

uncertified

6

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

JONES JONES DYSON SAIS

Snowview was a serious deficiency under Section 89201 s
uncertified

defendants OATES WILSON in

violation of

H

eviction

from

uncertified

Facility

6

1 causing plaintiffs to remain with
S Code Section 1508 with no supervision

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

JONES JONES DYSON SAIS and defendants OATES WILSON s eviction

25
26

from

unauthorized

uncertified

Facility

6 Snowview due to financial malfeasance of defendants Interim

27 defendants directors FREDDIE WILSON AJAY MALHOTRA BHUPINDER CHHUDU defendant
2g CEO SUKHWINDER SINGH defendant administrator JOEL DOMINQUEZ and defendants Oates and

50
COMPLAINT

1

Wilson constituted an unusual incident under Section 88061 4 and a serious deficiency under Section

2

89201 s

1

3
237

4

Defendant Interim breached mandatory statutory duties imposed by Section 88061 4 by

5

failing

to report plaintiffs

JONES JONES DYSON

and

SAIS

eviction

from

uncertified

Facility

6

6
7

Snowview
238

g

Defendant Interim s breach of mandatory statutory duties imposed by Section

9 88061 by failure to report plaintiffs JONES JONES DYSON and SAIS eviction from uncertified
10

Facility

6

Snowview

was a

serious

deficiency

under

Section 89201

1

s

that caused plaintiffs to

11
remain with uncertified

defendants OATES WILSON in

H

violation of

S Code Section 1508 with no

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

plaintiffs suffered ongoing abuse and neglect

16

239

Defendant Interim breached mandatory statutory duties imposed

by

Section 89206

by

1

failing to

notify CPS

of plaintiffs

JONES JONES DYSON

and

SAIS

eviction

from

Facility

6

18

Snowview constituting a serious deficiency under Section 89201 s

1 causing plaintiffs to remain with

19
uncertified

20
21

defendants OATES WILSON in

violation of

H

S Code Section 1508 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
240

In 3 11

plaintiffs JONES

JONES DYSON and SAIS defendants OATES WILSON

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

personal rights under sections

89372 1

2

51

COMPLAINT

4

5

6

B

8

9

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

2 not allowed to eat the same food as

4
defendants OATES WILSON

s

family

3

not allowed to eat at the same table as defendants

5
4

OATES WILSON

deprived

food

of adequate

5

suffered

6
the

opening
g
9

8

abuse

refrigerator or

witnessed

entering the food pantry

7

the abuse and neglect of plaintiffs

sleep deprivation

6 prohibited from

suffered corporal punishment physical and mental

JONES JONES

and

DYSON among

others

9

coerced and threatened to lie to social workers

10

242 Defendants OATES WILSON breached mandatory statutory duties imposed by Sections
11
89234 d

and

89361

d

by failing

to notify deferidant Interim

of

the

move

to

uncertified

Facility

7

12
13

Bluegrass

243

14
15

g9218

16

c

Defendants OATES WILSON breached mandatory statutary duties imposed by Section

by failing

244

to submit an application

The identical factual

for

approval on

scenario alleged

79

in

Facility
111

7

Bluegrass

with regard

to uncertified

2

Facility

17
Dulce

112

141

Facility

3

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

6

Snowview

was repeated witli regard

to uncertified

Facility

Defendant Interim s administrator defendant JOEL DOMINGUEZ did not issue a Certificate

on

Facility

contact

7 Bluegrass

putting

plaintiffs

defendant Interim made no site visit provided no supervision

SAIS

JONES JONES and DYSON at risk of foreseeable harm

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

7

Defendant Interim continued to engage in acts of financial malfeasance based on payments

from the U S Department of Health and Human Services California Department of Social Services and
San Bernadino Department

of

Social Services for

plaintiff

SAIS

52

COMPLAINT

placement

in

uncertified

Facility

7 in

1

violation of

H

S Code Section 1508 unbeknownst to said government funding agencies with no

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

Defendant CEO SUKHWINDER SINGH continued to engage in acts offinancial

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

H

S Code Section 1508 unbeknownst to

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

Defendants directors FREDDIE WILSON AJAY MALHOTRA and BHUPINDER

CHHUDU

continued

to breach mandatory statutory duties imposed

by

Section 88063

c

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

Defendants directors FREDDIE WILSON AJAY MALHOTRA and BHUPINDER
continued

to

breach mandatory statutory

duties

imposed

by

Section 88063

c

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

H

plaintiff

SAIS

placement

in

uncertified

Facility

7

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

suffered ongoing abuse and neglect
249
CHHUDU

9
10

Defendants directors FREDDIE WILSON AJAY MALHOTRA and BHUPINDER

continued to

breach mandatory statutory duties imposed

by

Section 88063

c

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

Social Services for

plaintiff

SAIS

placement

in

uncertified

Facility

7

12
13
14
15
16

Bluegrass

in

violation of

H

S Code Section 1508 unbeknownst to said government funding agencies

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

Defendants directors FREDDIE WILSON AJAY MALHATRA and BHUPINDER

18
CHHUDU

continued to

19
20 operating
21
22

uncertified

breach mandatory statutory duties imposed

Facility

7

Bluegrass

in

violation of

H

by

Sections 80000 1

3 and 88018 by

S Code Section 1508 unbeknownst to

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

Defendants OATES WILSON continued to engage in inimical conduct by operating

uncerti ced

Facility

7 Bluegrass in

violation of

H

governmental funding agencies alleged herein

54

COMPLAINT

S Code Section 1508 unbeknownsf to

i

252 Defendants OATES WILSON continued to engage in acts of financial malfeasance by

1
2
3

taking federal

state

and

county

payments

for

plaintiff

SAIS

s

foster

care

in

uncertified

7

Facility

Bluegrass unbeknownst to governmental funding agencies alleged herein

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

7 Bluegrass apparently unaware defendant was uncertified and

Facility

6
operated at least six uncertified homes since 6 07 with four evictions and five months homeless due to

g defendants financial malfeasance alleged above with particularity
9

In ar about 10 18 11 defendant RAMNIT came on board as defendant Interim s

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

7

violation of

H

S Code Section 1508

15 unbeknownst to said governmental funding agencies
16

256

Defendant RAMNIT

continued

to operate uncertified

Facility

7 in violation of Health and

17

Safety

Code Section 1508 to

procure and maintain more

foster

child placements

for

uncertified

Facility

18
Bluegrass
19
257

20
21
22

Approval to

On 1 20 12 defendant administrator RAMNIT issued defendant WILSON a Certificate of

operate a certified

family

home located

at a

different location

than uncertified

Facility

7

Bluegrass

23
258

Defendant RAMNIT and thereby breached mandatory statutory duties imposed by Section

24
89240
25

a

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

On 10 3 12 defendant Interim revoked defendants OATES WILSON s Certificate of

55

COMPLAINT

7

1

Approval

2

on

1 issued on 11 16 06

Facility

260

On 6 25 13 the California Department of Social Services Department filed and served

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

1 purportedly located on Bluegrass

5
261

According to the ACCUSATION defendant Interim issued defendant OATES one

6

Certificate of Approval on 11 16 06 in effect untilrevoked 10 3 12 whereas defendant OATES lived in 8
g

different locations between 11 16 06 to 10 3 12 evicted from four with foster children and homeless for

9 five months with foster children
10
262

Unbeknownst

to the

Department

Facility

1

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

1

Facility

Topmast on 12 4 07 UDVS 701833 defendants OATES WILSON did not reside on

14 Bluegrass unti12011
15
16

263
Exemption

ACCUSATION CDSS No 6712269202 petitioned to

Rescind Previous Criminal Record

of defendant Wilson

17
264

ACCUSATION CDSS No 6712269202 alleged

CONDUCT INIMICAL under Health and

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

On or about April 16 2012 defendant Wilson forcibly and against her

a

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

ACCUSATION CDSS No 6712269202 alleged PHYSICAL ABUSE PERSONAL

26 RIGHTS VIOLATIONS
27
28

section

89372

as

follows

defendant Wilson

struck

under Health and

18

Safety

Code

sections

1534 b

1558

a

1596 885

Regulation

Between and on or about November 16 2006 to October 12 2012

three foster

children

JONES JONES

56

COMPLAINT

and

DYSON

19 On at least one occasion

1

during

the

period

from

about

December 2011 through January 2013

defendant Wilson while wearing a

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

If I wasn t hurt I d get

4
Y u

5
ACCUSATION CDSS No

266

6712269202

20

alleged

In or about March 2012 defendant

6

Oates made threatening statements to plaintiff D JONES to the effect that she would put him in the
g

hospital

9

21

In or about February 2012 defendant Oates choked child 4
The ACCUSATION

267

alleged with respect

to

plaintiff

R JONES

that defendant Oates

10
slapped

choked

attempted

to

slammed the child to the ground and

pull off plaintiffls acrylic nails

11

prevented the child from going up the stairs by dragging her down Choked plaintiff R JONESJ
12
ACCUSATION CDSS No

268

13

14 from December 2011
15

through

plaintiffJ in the face causing

16
plaintiffJ

with a spoon

January

2012

bleeding

handle

6712269202

alleged

with respect

to

On several occasions during the period

plaintiff

hit plaintiff with a belt

D JONES

defendant Oates

hit plaintiff with a small bat

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

On several occasions in or about 2011

19
20
21
22

with respect

plaintiffJ

to plaintiff

on

the head

hit plaintiffJ

S DYSON defendant Oates

and about

the

body

on

the

head

with

her fist

hit

made plaintiffJ squat and or run while holding heavy objects

as form of discipline

23
270

ACCUSATION CDSS No 6712269202

alleged

REPORTING REQUIREMENTS

24
Health
25

and

Safety

Code Sections 1534 b

and

1558

a

Regulation

section

89361

a

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

In addition to the findings in the ACCUSATION defendants OATES WILSON assaulted

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

Oates and Wilson s family

not allowed to eat at the same table as defendants Oates and Wilson

deprived

6

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

forced plaintiffs to scrub

alls floors vacuum and sweep floors lift rugs move and replace furniture clean toilets
bathrooms nightly

several

hours in

the

early morning before

school

kitchen and

suffered sleep deprivation forced

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

forced to walk to school on crutches 3 miles each way

23
273

In addition defendants OATES WILSON assaulted battered and terrorized plaintiffs

24
ADAMS GALVANS and SAIS and forced plaintiffs to witness the abuse and terror of each other and all
25

26 the other children
27

274

The ACCUSATION further

alleged

RECISSION OF PREVIOUS CRIMINAL RECORD

28 EXEMPTION and LACK OF GOOD CHARACTER Health and Safety Code Sections 1522 and
58

COMPLAINT

r

1

1558

a

2

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

3 demonstrate good character engaged in conduct inimical as alleged in paragraphs 17 18 19 and 25
4
above

5
275

On August 29 2013 the Department issued a default decision against defendant WILSON

6

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

wilson s previously granted criminal exemption
11
276
12
13

The Department s duly served Default Decision informed defendant WILSON of the right to

request the decision be vacated within seven 7

days after the Department mailed the default decision and

14 order to defendant Wilson and the procedure to make said request
15
16

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

and mental abuse

trauma humiliation intimidation threats

59
COMPLAINT

embarrassment

and

shame

deprivation of

1

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

suffering for which defendants are liable
Plaintiffs are informed believe and thereupon allege that said injuries will result in some

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

1

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

incident expenses incurred

and

to be incurred in the future

3

For loss

of earnings incurred and future loss of earning capacity according to proof 4 For pre judgment interest

17
according to

proof

5

For

costs of suit

incurred herein

and

6

For such other and further relief as the

18
19

Court deems just and proper

20
21
22

SECOND CAUSE OF ACTION

FOR NEGLIGENCE PER SE

VIOLATION OF MANI ATORY STATUTORY DUTIES

23

PLAINTIFFS DEANDRE JONES REANDRANE JONES ISAIAH SAIS SALEENA GALVAN
24
MARK GALVAN

SURPRISE ADAMS SHAWNA ADAMS

SUAVE DYSON AGAINST

25
26

DEFENDANTS INTERIM SUKHWINDER SINGH FREDDIE WILSON AJAY MALHAOTRA

27

BHUPINDER CHHUDU KHUSHANUD AZARIAH JOEL DOMINGUEZ SHAHZIA RAMNIT

28

LISA OATES NAWAB WILSON and DOES 1 20

60
COMPLAINT

1

283

2

284

3

by

Plaintiffs

1 282 as though fully set forth

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

H

4

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

3

g
9

evictions

142

208 Eviction

158

and

homelessness

Facility

4

5

Facility

alleged with

159
197

specificity in

167 Eviction

79 111

4

Facility

208 Homelessness

168
231

209

2

Facility
186

112 141 Facility

Facility

232

6

Facility

5

195
240

10
Eviction

Facility

6

240

258

Facility

7

11
285

Defendant Interim breached mandatory statutory duties alleged with specificity in

12
13
14

g

91 92 93 97 100

189 200 201 203

103

206 213

119 123

124

129

223 234 235 237

131

134

146

158

162

163

165

167 172

178

181

239 245 causing plaintiffs members of the protected

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

Defendant SUKHWINDER SINGH breached mandatory statutory duties alleged with

20 specificity in
21
22

64 H

S Code Section

1508

90 108

122

139 147 164 173

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

BHUPINDER CHHUDU breached mandatory statutory duties
136

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

Defendants administrators KHUSHANUD AZARIAH JOEL DOMINGUEZ and

6
SHAHZIA RAMNIT breached mandatory statutory duties

alleged

in

84 89 116

121

145 164

178

g

198 212 229 230 233 236 255 256 257 258 causing plaintiffs members of the protected class to

9

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

punishment extreme neglect evictions and homelessness
12
2g9

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

nervousness hopelessness shame

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

1

PLAINTIFFS PRAY for judgment against defendants and each of them as

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

3

1

25 000 00

2 For medical

and

incident

expenses

incurred

and to

be incurred in tlie future

3

For loss

2 of earnings incurred and future loss of earning capacity according to proof 4 For prejudgment interest
3

according to

proof

5

For

costs of suit

incurred herein

6

and

For such other and further relief as the

4
Court deems just and proper
5

THIRD CAUSE OF ACTION
6
FOR INTENTIONAL

gNFLICTgON OF EMOTIONAL DISTRESS
9

PLAINTIFFS DEANDRE JONES REANDItANE JONES ISAIAH SAIS SALEENA

10

GALVAN MARK GALVAN

SURPRISE ADAMS SHAWNA ADAMS

SUAVE

11

DYSON AGAINST DEFENDANTS IN

ERIM SUK IWINDER S NGH FREDDIE

12

WILSON AJAY 1VIALHOTRA BHUPINDER CHHITDU

13
14

USHANUD AZARIAH JOEL DOMINGU

15

Z SHAHZIA RAMN T LISA OATES NAWAB

WILSON and DOES 1 20

16

291

Plaintiffs reallege pars 1 290 as though fully set forth

17
292

Defendants operated a kids for cash

scam for six years off the backs of foster children of

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

H

S Code Section 1508 with

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

2

112 141

Facility

3

142

158

28

63

COMPLAINT

Facility

4

159

167 Eviction

1

Facility

2

209

3

4

168

186

231

Facility

6

293

Facility
232

5

195

208 Eviction

240 Eviction

Defendants despicable

outrageous

Facility

6

Facility

240

kids for cash

5
258

197

Facility

208 Homelessness

7

scam either intentional or carried out

4

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

2

as certified

in

H

violation of

S Code Section 1508 abandoned

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

Defendants directors WILSON MALHOTRA and BHUPINDER CHHUDU held out
defendants OATES WILSON

16
violation of

as certified and operated uncertified

Facility

2 as certified in

S Code Section 1508 knowing or should know defendant Interim provided no supervision

H

17

and little if any contact putting plaintiffs JONES JONES and DYSON at risk of foreseeable harm
18

owing or should know plaintiffs suffered ongoing abuse and neglect

19

296

20
21
22

Defendant SINGH held out uncertified defendants OATES WILSON as certified and

operated uncertified

Facility

2

as certified

in

violation of

H

S Code Section 1508

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

2

out

as certified

in

violation of

H

S Code Section 1508 while abusing and terrorizing plaintiffs knowing

28
plaintiffs suffered severe ongoing pain neglect mental and emotional abuse

64

COMPLAINT

ir

298

1
2
3

Defendant Interim held out defendants uncertified OATES WILSON as certified

and operated uncertified

3

Facility

as certified

in

violation of

H

S Code Section 1508 knowing or

should know defendant Interim provideii 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
S
abuse and neglect

6
299

g
9

Defendants directors WILSON MALHOTRA and BHUPINDER CHHUDU held

out uncertified

defendants OATES WILSON

in

H

violation of

as certified and operated uncertified

Facility

3 as certified

S Code Section 1508 knowing or should know defendant Interim provided no

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

3

as certified

in

violation of

H

S Code Section 1508 knowing or should

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

Defendarit administrator AZARIAH held out uncertified defendants OATES WILSON as

Facility

3

violation of

H

S Code Section 1508

certified and operated uncertified

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

H

and

WILSON held themselves

and operated uncertified

Facility

S Code Section 1508 provided no supervision and little if any contact

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

i

y

1
2

Defendant Interim held out uncertified defendants OATES WILSON as certified and

303

operated uncertified

Facility

4

as certified

in

violation of

H

S Code Section 1508 knowing or should

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

defendants OATES WILSON

uncertified

violation of

H

as certified and operated uncertified

Facility

4 as certified in

S Code Section 1508 knowing or should know defendant Interim provided no

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

4

as certified

in

violation of

H

S Code Section 1508 knowing or should

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

Defendant administrator AZARIAH held out uncertified defendants

20 OATES WILSON
21
22

as certified and operated uncertified

Facility

4

as certified

in

violation of

H

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

know plaintiffs suffered ongoing abuse and neglect
24
307

Defendants OATES and WILSON held themselves out as certified and operated uncertified

25
26

Facility

4

as certified

in

violation of

H

S Code Section 1508 knowing or should know defendant

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

1

operated uncertified

Facility

5

as certified

in

violation

of H

S Code Section 1508 knowing or should

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

Defendants directors WILSON MALHOTRA and BHUPINDER CHHUDU held out

6
uncertified

g
9
10

violation of

defendants OATES WILSON

H

as certified and operated

uncertified

Facility

5 as certified in

S Code Section 1508 knowing or should know defendant Interim provided no

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

5

as certified

in

violation of

H

S Code Section 1508 knowing or should

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

5

as certified

in

violation

of H

S Code Section 1508

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

Defendant Interim covered up concealed plaintiffs M GALVAN JONES JONES and

24
DYSON

s

homelessness

with

homeless

uncertified

defendants OATES WILSON in

violation of

H

S

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

should know plaintiffs suffered ongoing abuse and neglect

67

COMPLAINT

f

2
3

Defendants directors WILSON MALHQTRA and BHUPINDER CHHUDU covered

313

1
up

M GALVAN JONES JONES and DYSON s homelessness with homeless

concealed plaintiffs

defendants

uncertified

WILSON

OATES

in

violation of

S Code Section 1508 knowing or should

H

4

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

ongoing abuse and neglect
Defendant SINGH covered up concealed plaintiffs M GALVAN JONES JONES and

314
9
10

DYSON

s and

defendant OATES

WILSON

s

homelessness in

violation of

H

S Code Section 1508

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

plaintiffs suffered ongoing abuse and neglect

Defendant administratar AZARIAH covered up concealed plaintiffs M GALVAN

315

JONES JONES

and

DYSON

s and

defendant OATES WILSON

s

homelessness in

violation

of

H

S

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

should know plaintiffs suffered ongoing abuse and neglect
316

Defendant Interim held out uncertified defendants OATES WILSON as certified and

operated uncertified

Facility

6

as cerEified

in

violation of

H

S Code Section 1508

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

abuse and neglect

317

uncertified

violation

r

Defendants directors WILSON MALHOTRA and BHUPINDER CHHUDU held out

defendants

of

H

OATES

WILSON

as certified and operated uncertified

Facility

6 as certified in

S Code Section 1508 knowing or should know defendant Interim provided no

68

COMPLAINT

e

1

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

6

as certified

in

H

violation of

S Code Section 1508 knowing or should

5

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

abuse and neglect

9

319

Defendant administrator AZARIAH held out uncertified defendants

10
OATES WILSON

as certified and operated uncertified

Facility

6

as certified

in violation

of

H

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

14 should know plaintiffs suffered ongoing abuse and neglect
15

320

Defendant administrator DOMINGUEZ held out uncertified defendants OATES WILSON

16
as certified and operated uncertified

6

Facility

as certified

in

violation of

H

S Code Section 1508

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

20 plaintiffs suffered ongoing abuse and neglect
21

321

Defendant Interim held out uncertified defendants OATES WILSON as certified and

22
operated uncertified

Facility

7

as certified

in

violation of

H

S Code Section 1508 knowing or should

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

26 abuse and neglect
27
28

322

uncertified

Defendants directors WILSON MALHOTRA and BHUPINDER CHHUDU held out
defendants OATES WILSON

as certified and operated uncertified

69
COMPLAINT

Facility

7 as certified in

y

Y

1

violation of

H

S Code Section 1508 knowing or should know defendant Interim provided no

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

7

in

as certified

violation of

H

S Code Section 1508 knowing or should

6

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

abuse and neglect

10
324

Defendant administrator DOMINGUEZ held out uncertified defendants OATES WILSON

11
as certified and operated uncertified

Facility

7

in

as certified

violation of

H

S Code Section 1508

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

15 plaintiffs suffered ongoing abuse and neglect
16

325

Defendant administrator RAMNIT held out uncertified defendants OATES WILSON as

17
certified and operated uncertified

Facility

7

as certified

in

violation of

H

S Code Section 1508

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

21 plaintiffs suffered ongoing abuse and neglect
22

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

At all times herein defendants operated a despicable outrageous

kids for cash scam to

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

4

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

4

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

1

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

incident expenses incurred

and

to

be incurred in

the

future

3

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

5

For

costs of suit

incurred herein

and

6

For such other and further relief as the

20 Court deems just and proper
21
22

FOURTH CAUSE OF ACTION

FOR CONSPIRACY

23
PLAINTIFFS DEANDRE JONES

LZEANDRANE JONES ISAIAH SAIS SALEENA

24

GALVAN MARK GALVAN

SUItPRISE ADAMS SHAWNA ADAMS

SUAVE

25
26

DYSON AGAINST DEFENDAN TS INTERIM SUKHWINDER SgNGH FREDDIE

27

WILSON AJAY MALHOTRA BHUPINDER CH IUDU

28

KHUSHANUD AZARIAH JOEL DOMINGUEZ SHAHZIA RAMNIT LISA OATES NAWAB

i

COMPLAINT

i

WILSON and DOES 1 20

1
2

329

3

330

Plaintiffs reallege pars 1 328 as though fully set forth
At all times herein defendants INTERIM defendants board members defendant CEO

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

Federal Foster Care Funds California Dept of Social Services DSS

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

abuse and neglect perpetrated

by

defendants OATES WILSON

unchecked

12
331

13

At all times herein

defendant INTERIM defendants board members defendant CEO

14 defendants Administrators and OATES WILSON placed accepted plaintiffs foster children in seven
15

facilities

16

uncertified

332

by

INTERIM

over a period of six years

in

violation of

H

S Code Section 1508

Defendant INTERIM defendants board members defendant CEO defendants

17
Administrators

in cahoots with defendants OATES WILSON perpetrated the

kids for cash scam

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

mental abuse and neglect at

3

334

the

hands

of

defendants OATES WILSON

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

took no action held said homeless uncertified

children

6

defendants out as certified by INTERIM in cahoots with defendants OATES WILSON in violation of
g

H

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

As a result of defendants kids for cash

scam plaintiffs suffered terror trauma PTSD

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

1

PLAINTIFFS PRAY for judgment against defendants and each of them as

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

z

1

25 000 00

2 For

medical and

incident

expenses

incurred

and

to be incurred in the future

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

5

For

costs of suit

incurred herein

and

6

For such other and further relief as the

4
Court deems just and proper
5
6
DATED October 2

L014

LAW OFFICES OF L WALLACE PATE

8
9

By

10

L Wallace Pate Esq Attorneys for Plaintiffs
il
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28

74

COMPLAINT

a

DEMAND FOR Ji1RY TRIAL

1
2
3

Plaintiffs hereby demand trial by jury of all causes of action

4
5
DATED October 2

014

LAW OFFICES OF L WALLACE PATE

6
7
8
9

By

10

L Wallace Pate Esq Attorneys for Plaintiffs
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28

75

COMPLAINT

SUPERIOR COURT OF CAU

R

G

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

4

Equity

5

Eminent Domain

6

Family

7

Guardianship

8

Harassment
Mandate
Name Change
Personal Injury
Personal Property
Probate

9
0

0

11
12
13

Law

Ground

Petitioner resides within the district

Petitioner or conservatee resides within the district

Performance in the district is expressly provided for

The cause of action arose within the district
The property is located within the district

Plaintiff defendant petitioner or respondent resides within the district

Petitioner or ward resides within the district or has property within the district
Plaintiff defendant petitioner or respondent resides within the district

The defendant functions wholly within the district
The petitioner resides within the district
The injury occurred within the district

The property is located 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

THIS FILING WOUL D

The defendant functions wholly within the district
The defendant functions wholly within the district
The property is located within the district
The lower court is located within the district

The property is located within the district

The petitioner defendant plaintiff or respondent resides within the district
NORMALLY FALL WITHIN JURISDICTION OF SUPERIOR COURT

The address of theinaccident
perFormance
party detention place of business or other factor which qualifies
the
designed district js

this case fer filin
i
NAME

IN

above

t

c
J

d

TE TITLE QR OTHER QUA JFY NG FACTOR

RESS

C

j

CITY
STATE

I declare
on

under

d

penalty of perjury that the forego

7

at

is tr

ZIP CODE

nd correct and that this declaration was executed

2

l

Signature ofAttomey Party

13

16503 360

Rev 06 2014

CERTIFICATE OF ASSIGNMENT

California