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GARY S.

MAY
UC DAVIS CHANCELLOR
FIFTH FLOOR, MRAK HALL
UNIVERSITY OF CALIFORNIA, DAVIS
ONE SHIELDS AVENUE
DAVIS, CA 95616

CHAPTER I

DANNY GRAY’S “Me Too”— PARTS UNKNOWN


OPEN LETTER

Open Letter to UC Davis Chancellor Gary S. May about the December 12, 2017
Davis Enterprise article “MeToo Arrives at the University of California”

Dear Chancellor May


When I read the December 12, 2017 article “MeToo Arrives at the University of
California” written by Tanya Perez and saw Danny Gray’s direct story about this in his
published blog, it crossed my mind that his name was familiar to me. I quickly
discovered that Danny Gray was listed as one of the many defendants in Edith F.
Cartwright’s several sexual harassment and wrongful termination lawsuits in 2003-2010
against the UC Regents and several employees from UC Davis. I knew some of these
individuals or had come across their names during my employment with the UC Davis
Medical Center from 1999 to 2012 and my wrongful termination lawsuit filed in
December 2013 in the Sacramento County Superior Court, which is still unresolved.

In my Motion for Reconsideration filed on February 20, 2015, I mentioned Edith


Cartwright’s lawsuit with the words:

“If Plaintiff would have known about the Vergos v. The UC Regents case
in November 2012, then Plaintiff would have objected, for the record, not
to have his case heard by Skelly reviewer UC Davis Associate Vice
Chancellor Allen Tollefson in November 2012. Tollefson had been sued
for sexual harassment in Randy Vergos v. The Regents of University of
California.
Allen Tollefson also appeared as a Defendant in the 2009 05-2439 -
Cartwright v. University of California Davis case in the 9th United States
District Court, Eastern District of California, together with another UC
Davis Associate, Vice Chancellor Dennis Shimek, whom Plaintiff has met

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while representing his coworker in an Administrative Remedies complaint.
The above-listed Defendants , Stephen Chilcott, Danesha Nichols, Cindy
Oropeza. Brent Seifert. and Mike Boyd are cold-blooded violators of law
and University of California policies. These five individuals are solely
responsible for Plaintiff's wrongful termination especially Defendants
Chilcott and Defendant Boyd. These individual defendants did not hesitate
to hold Plaintiff, like a hostage, away from his job for more than one year-
violating Investigatory Leave Policy-and then took from Plaintiff his job
and office, which was granted him by a signed Settlement - Agreement
with The Regents of the University of California in February 2009. These
individuals are cold-blooded "witch hunters" who were preparing to
seriously injure, if not kill, Plaintiff at the UC Davis Medical Center
Trauma Unit # 11 on May 31, 2012, as evidenced by their criminal, sick
thoughts. These five individuals are also directly responsible, by their
activities, for covering up the illegal activities of a twice-convicted child
pornography felon on the company
Covering up child pornography activities in company reports is not an
official proceeding authorized by law.
This is a naked truth in this case, as well as in the case cited in the
decision in Vergos, Supra, 146 Cal. App. 4th, with Plaintiff's Skelly
Officer Allen Tollefson (Plaintiff's Opposition to SLAPP, Exhibit No.
034.) as a Defendant in Vergos Case who sexually harassed another
man in the relevant time .Now Allan Tollefson hold an Associate Vice
Chancellor position at the UC Davis . This how the free speech law
protects child pornography felons, sexual harassers, psychopath' s
supervisors who stalking their subordinates, thieves, and other white-collar
UC criminals.

In Vergos v. McNeal Allen Tollefson is portraitlike as sexual predator


hitting on his subordinate Randy Vergos calling Randy Vergos as "my boy
toy" and "my bitch." Or Tollefson followed Randy Vergos around,
sometimes came up behind him, stared at Randy Vergos’ hair and body,
made comments about the penises of other men, said one man had pretty
lips, tugged at his own (Tollefson's) crotch, and got angry when Randy
Vergos refused to move into Tollefson' s office."

I was inspired and encouraged to address the following story to the UC Davis Chancellor
because you are a new Chancellor who I believe is not yet molded into the corrupt UC
system. The other reason that I am writing to you was the Motion in Limine that was filed
in the Edith Cartwright lawsuit on 1/14/2010 in U.S. District Court Eastern District of
California by the UC Regents’ legal counsel. This motion will introduce my story in
Chapter II of “Danny Gray ‘Me Too’ – Parts Unknown.”

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CHAPTER II
DANNY GRAY “Me Too” – PARTS UNKNOWN – CASE NO. CV 05 02439 MCE-
KJM DEFENDANTS’ MOTION IN LIMINE NO. 2 TO EXCLUDE
IRRELEVANT (“ME TOO”) EVIDENCE

In this chapter, I will insert some of the University of California’s irrelevant “ME TOO”
evidence without my comments. It will give the UC Davis Chancellor some insight about
the Nazi-like UCOP and campus regimes that operate under the umbrella of the rewritten
“Mein Kampf” mixed with the Carl Marx Communist Manifesto and entitled “UC
Principles of Community.”

In order to try and prove that her termination was discriminatory,


Defendants expect Plaintiff to offer evidence of alleged discriminatory
treatment of other University employees
(ALSO KNOWN AS “ME TOO” EVIDENCE)
Plaintiff asserts that “in or around 2001, Defendants were concerned with
problems regarding racism, sexism and homophobia within the University
and commissioned various studies which confirmed the hostile
environment.”
Furthermore, in her Third Amended Complaint (“TAC”), Plaintiff offers
several instances where she believes other employees suffered wrongful
treatment, including, but not limited to:
1. Rene Barney made a complaint about discrimination and retaliation,
but “no meeting” occurred. (TAC, ¶ 52.)
2. Annette Cross and Donna McDaniel committed suicide because of
harassment and sex-based discrimination. (Id. at ¶ 81.)
3. Ivette Rivera, Rene Barney, and Pam Pane quit or were otherwise
separated from employment because of harassment and sexual orientation
discrimination. (Id.)
4. “Employees of color Kenneth Black, Linda Turner, Kenneth Daly,
and John Williams are just four of dozens of employees of color that have
suffered race, ethnicity, and color-based harassment and discrimination.”
(Id.)
Managing Agent Jerry Keen, a white male, made sexual innuendos to
female employees. (Id.)
Plaintiff also generally alleges in her summary judgment opposition that
Jane Lepisto hit another employee with a binder and was not terminated,
while Plaintiff’s employment was terminated for a lesser degree of
misbehavior.

ARGUMENT

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The Evidence of Discrimination or Discipline Involving Other Employees
is Irrelevant as No Employee Was “Similarly Situated” To Plaintiff

of all the people identified above, there is no evidence that any of them
were “similarly
situated” to Plaintiff. Plaintiff is a gay, Native American, Hispanic woman
who worked in the Grounds Department as a senior manager and was
supervised by Sal Genito. Plaintiff was terminated for threatening and
intimidating three subordinate employees who also worked in the Grounds
Department.
None of the people listed by Plaintiff as being “similarly situated” had
“similar jobs or
displayed similar conduct.” For example, Jane Lepisto was a “rank and
file” employee, not a senior manager (or even a manager), who was
[allegedly] suspended for one week for hitting a oworker with a binder.
Lepisto did not work in the Grounds Department and was not supervised by
Sal Genito. Lespisto committed an act of violence toward a coworker, not a
subordinate employee. Accordingly, she was not “similarly situated” to
Plaintiff.

On 2003 May 15, 2003 supervisor Jane Lepisto struck Co-Worker Karen Curly with a
three-pound binder by smashing the binder on Curly’s head. UC Davis “disciplined”
Lepisto by giving Lepisto two days paid leave. In 2003 Spring, Plumber Dave Keller
threatened to “kill” Co-Worker Steve Smith and Co-Worker Randy Vergos. UC
Davis disciplined Plumber Keller by giving Plumber Keller one week paid leave. In 2005
Plumber Rob Stewart threatened Supervisor Dave Monell. UC Davis disciplined
Plumber Stewart by assigning him to two anger management classes.

Here, Plaintiff is likely to make a “ME TOO” argument based upon the
following improper evidence:
Plaintiff asserts that “in or around 2001, Defendants were concerned with
problems regarding racism, sexism and homophobia within the University
and commissioned various studies which confirmed the hostile
environment.” First, this evidence predates Plaintiff’s termination by at
least two years. Second, this is evidence occurring before January 14, 2003
and Plaintiff is estopped from using it. Finally, there is no foundation to
connect this alleged “concern” to Plaintiff.

TWO EMPLOYEES COMMITTED SUICIDE BECAUSE OF


HARASSMENT AND DISCRIMINATION

Plaintiff alleges that Annette Cross and Donna McDaniel committed


suicide because of harassment and sex-based discrimination. This is a wild,

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speculative conclusion. Moreover, there is no evidence to suggest that
anything endured by Cross or McDaniel shares commonality with Plaintiff
or that Genito was the bad actor.

THREE EMPLOYEES QUIT OR WERE SEPARATED FROM


EMPLOYMENT BECAUSE OF HARASSMENT AND SEXUAL
ORIENTATION DISCRIMINATION

Plaintiff’s contends that Ivette Rivera, Rene Barney, and Pam Pane quit or
were otherwise separated from employment because of harassment and
sexual orientation discrimination. This is another wild, speculative
conclusion for which there is no link to Plaintiff’s employment or
termination. Moreover, the circumstances regarding each of these
individual’s employment is complex and cannot be reduced to simple,
isolated conclusions. Further, there is nothing to suggest that Sal Genito
had anything to do with these individual’s employment.

AFRICAN-AMERICAN EMPLOYEES AT UC DAVIS HAVE


SUFFERED RACE DISCRIMINATION AND HARASSMENT

Plaintiff contends that “Employees of color Kenneth Black, Linda Turner,


Kenneth Daly,
and John Williams are just four of dozens of employees of color that have
suffered race,
ethnicity, and color-based harassment and discrimination.” Plaintiff was not
an employee of “color.” In addition, the circumstance of these “dozens” of
employees’ employment bears no connection to Plaintiff’s employment or
her termination.

Jerry Keen

Plaintiff claims that “Managing Agent Jerry Keen, a white male, made
sexual innuendos
to female employees.” Jerry Keen left the employment of the University in
the 1990’s.
Moreover, this allegation bears no connection to Plaintiff’s employment or
termination in 2003.
As in Goff, any testimony regarding allegedly unfair, wrongful or
retaliatory treatment of other University employees should be excluded.
Evidence pertaining to treatment of other
employees lacks probative value as it does nothing to advance Plaintiff’s
allegations that she was subjected to unlawful discrimination or retaliation.

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Pattern and Practice Evidence is Not Appropriate in This Case

Pattern and practice and “similarly situated” theories are quite similar. To
the extent
Plaintiff is trying to submit evidence of a pattern or practice discrimination,
such evidence is also inappropriate in this individual discrimination case.
(Celestine v. Petroleos de Venez. SA, 266
CONCLUSION

For the foregoing, Defendants request that the Court enter an in limine
order excluding Plaintiff from submitting “ME TOO” evidence.

Dated: January 14, 2010


GORDON & REES, LLP

Signed by the “ Devil Advocate “ for the Regents of the University of California
Mark S. Posard, Esq.

CHAPTER III
“MeToo” ARRIVES AT THE UNIVERSITY OF CALIFORNIA

(https://www.davisenterprise.com/local-news/ucd/uc-davis-administrator-levels-
sexual-assault-charges-against-emeritus-professor/).

I found the Tanya Perez article and Danny Gray’s confession, “MeToo Arrives at the
University of California” (hereafter MeToo) interesting because in my more than thirteen
years of employment at the UC Davis Medical Center (UCDMC; June 1999–December
2012) and subsequent lawsuits against the University of California, I witnessed
deception, conspiracy, collusion, sexual harassment and harassment in general, child
pornography, the suicide of bullied and harassed employees, provocations, and whatever
you could name involving the inhumane treatment of students and university employees
by rotten and corrupt administrators from the UC Office of the President and their well-
paid thugs at the university’s ten campuses, who were carrying out and covering up
retaliatory attacks and violation of students’ and employees civil and human rights.

The 2013 UC Davis Climate Survey conducted by Rankin & Associates showed that 24%
of surveyed UC Davis employees (4,000 of 11,500) suffered while working in Davis’s
hostile and discriminatory work environment. The most recent survey conducted on all
UC campuses showed that the situation in no better on other campuses, and the
percentage of employees suffering hostile and discriminatory work environments remains

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steady around 25%.

The University of California Regents and the rotten and corrupt UC administration
converted the Employment for Cause policy, the unconstitutional UC “Principles of
Community” manifesto, State of California Government Code Section 8547-8547.13, and
the California Code of Civil Procedure §425.16 into a shield to protect UC’s white-collar
criminals from prosecution and into a tool for vicious retaliation, prosecution, and the
violation of employees’ civil and human rights. The state law enforcement agencies are
powerless against the almighty University of California, which is attached to the state’s
administration and legislature like a parasite, showing nice colors to the outside world
that do not correspond to the 57,288 students, 4,728 faculty members, and 32,616 staff
members who have reported experiencing exclusionary, intimidating, offensive, or hostile
conduct, as outlined in Rankin & Associates’ final report. The state’s legislature and
administration are numb to and do not care about the discrimination and the civil and
human rights violations.

Danny Gray should be considered one of these statistics who reveals a different image of
the UC administration, as a body that cares little about the violation of civil and human
rights. Perhaps Danny Gray also falls into the tragedy category described. Perhaps the
UC administration’s fascism- or communism-like philosophy draws on a remark by Kurt
Tucholsky from 1925: “Der Tod eines Menschen: das ist eine Katastrophe.
Hunderttausend Tote: das ist eine Statistik!” This could be translated to the UC climate as
follows: “One devastated and destroyed UC Davis employee or student life is a tragedy; a
thousand is a statistic.”

In addition to my own horrible experiences of harassment and retaliation behind a façade


of human decency, I also defended others against UCOP mafia and UC Davis thugs and
bandits armed with the titles of HR specialists, managers, supervisors, directors,
investigators, chancellors, and vice chancellors. However, the article makes it sound like
UC Davis’s campus old boys’ club is testing the new chancellor by trying to draw the
chancellor into a hot tub filled with boiling water. Very clever.

CHAPTER IV
“MeToo “-PARTS UNKNOWN- DANNY GRAY’S “Sweet Dream”

I have two children: Joanna, the older, is around Danny Gray’s age and graduated from
UC Santa Cruz as a cellular and molecular biologist. George graduated from California
State University in Long Beach with a business degree. They both worked hard as
students to support themselves beyond the financial help their parents could offer. As a
father, I cannot imagine what I would do if I found out that my daughter or son had been
raped, sodomized, or harmed in any way by their professors. For sure I would raise hell
and go after the criminals until justice was served.

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In his “MeToo” story, Danny Gray did not mention his parents who sent him to UC
Davis. The details he provides are most likely true, but the story sounds more like a
flamboyant exaggeration or the lyrics to the 1983 song “Sweet Dreams” (https://www
.youtube.com/watch?v=MKPA4_DZdAg), or the story of a con artist who used his skill
to make UC Davis music professor Kern Holoman (retired), the lover in the story, UC
HR vice chancellor Dennis Shimek (retired), and UC chancellor Larry Vanderhoef (died
2015) into his “sugar daddies” to milk them until they retired or died. The song’s lyrics
run

Sweet dreams are made of this.


Who am I to disagree?
I travel the world
And the seven seas.
Everybody’s looking for something.
Some of them want to use you.
Some of them want to get used by you.
Some of them want to abuse you.
Some of them want to be abused.
Sweet dreams are made of this.
Who am I to disagree?
I travel the world
And the seven seas.
Everybody’s looking for something.
https://www.youtube.com/watch?v=qeMFqkcPYcg

“Sweet Dreams” perfectly describes Danny Gray’s character and his “bon voyage”
traveling the world supported by Professor Holoman’s dollars and envelopes full of
French francs to be spent at his pleasure a Professor Holoman’s favorite Parisian
restaurant. How Shimek and Vanderhoef behaved in supporting Danny Gray’s desires
and needs and condoning their friend Professor Holoman’s love affair with him is a story
that still needs to be fully told.

• Danny Gray had weekly lunches in UC Davis restaurants with Professor Holoman
and paid for by Holoman.
• March 1987: Holoman allegedly raped and sodomized Danny Gray in Holoman’s
private residence in Davis, CA.

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• 1987: Gray enrolled in a six-week “summer abroad” course in Cambridge, UK.
• 1987: Gray visited Paris with an envelope full of francs received from Holoman
to spend given French currency at Holoman’s favorite restaurant there.
• Fall 1987: Holoman allegedly makes a drunk sexual assault on Danny Gray,
raping and sodomizing him in Holoman’s Mendocino County beach house. This
was after Gray’s return from Cambridge.
• Fall 1987: Gray reported Holoman for sexual assault to UC Davis’s associate vice
chancellor, Dennis Shimek.
• 1988: Gray enrolled in UC Berkeley as a visiting student for one semester.
• 1988: Gray went to India on a UC Davis education abroad program and lived
there for the 1988–89 academic year.
• Late summer, 1989: Gray returned to Davis and went straight to Shimek to tell
him that he intended to rejoin the university symphony, whose conductor was
Holoman, the alleged sexual predator who raped and sodomized Gray on two
occasions. Shimek told Gray that he was very welcome to do so.

Danny Gray’s quid pro quo of 1990–91.

• By fall 1990, Danny Gray had set his sights on graduate school, specifically the
University of Chicago’s PhD program in South Asian History. I am not sure at
this point whether he wanted to be a historian or a musician. To pursue his dream,
Gray asked his sexual predator and rapist Professor Holoman for help in exchange
for being raped and groped. In his Quid Pro Quo, Gray reported that he had not
had sex with Holoman in Holoman’s office but had permitted Holoman to have
some fun and grope him there two or three times during the period when he was
writing his letter of recommendation. Gray related with shocking cynicism that
Holoman told him, “Here is your payment” as he gave him the letter . Gray did
not want to be treated like a prostitute by Holoman.
• Fall 1991: Holoman visited Gray for the last time, in Chicago, and allegedly tried
to grope and kiss him but was pushed away. In despair after losing his sexual
abuser, Gray quit his graduate program and rode his bicycle six thousand miles
around the United States. Who paid for this trip?
• 1996: Five years later, Gray called Shimek at UC Davis (he must have had
Shimek’s direct number) and blackmailed him, threatening to reveal his love
affair with his sexual predator and rapist Professor Holoman to the Sacramento
Bee if Shimek demoted Holoman from the deanship he had been promoted to in
March 1995.

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• Holoman submitted his resignation as dean in April 1996. Chancellor Larry
Vanderhoef accepted it, and he stepped down effective June 30, 1996, for family
reasons, according to an official UC Davis communication dated April 30
(enclosed). It is unknown whether Danny Gray had tried to contact him and repair
their relationship since 1991.
• March 18, 1997: One year after Holman resigned, he agreed to be punished for
his misconduct by a one-month suspension without pay, and to attend counseling
at his own expense. The March 18 letter of suspension under threat of termination
was signed by Vanderhoef. It did not mention Danny Gray’s name. It is unknown
whether Gray’s threat to reveal his affair was the main reason for the letter or
whether Vanderhoef was aware of other misconduct by Holoman. The letter was
issued through a voluntary agreement between Holman and Shimek and does not
specify the misconduct Holman was accused of or by whom.
• 1999: Gray graduated from San Francisco’s UC Hasting Law School and joined
the California bar. Law school and residence in San Francisco were very
expensive. It would be interesting to find out who supported Gray in San
Francisco and in the law degree he has never fully utilized, as Gray has been an
inactive attorney at law since 2001.
• In 2001, Shimek, though he did not want remember Gray’s love affair with
Holman, had no choice but to hire Gray to UC Davis as an HR labor relation
specialist or analyst.

In 2001, Danny Gray somehow did not care that he had been sodomized and raped by a
professor there and came back to UC Davis in a job provided to him by Associate Vice
Chancellor Shimek. It had to be a very odd situation for Vanderhoef and Shimek, to have
someone around them in the HR department who was allegedly raped, sodomized and groped
several times by their friend Holoman, well-known domestically and abroad as the conductor
of the UC Davis Orchestra. God only knows how they coped and still managed, in such a
situation, to further cover up Gray and Holoman’s rape and sodomy romance.
It is unknown at this point whether Danny Gray came back to Davis to milk the
university and his sponsors or with the hope of restoring his broken romance with his
sweetheart, or sugar daddy, ten years after Professor Holoman abruptly left his Chicago
apartment in 1991. It would be interesting to find out whether university paid Dany
Gray’s education in UC Hasting Law School?

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CHAPTER V
“MeToo”- DANNY PARTS UNKNOWN- “Glitter and be gay”

Larry Vanderhoef, a member of Sword and Sandals, led UC Davis for 25 years—first as
provost and executive vice chancellor (1984–1994) and then as chancellor (1994–2009).
Rumors were published that Vanderhoef had a $2 million special account that he was
allowed to spend however he wished. This allegation was based on information provided
by a former member of the UC Davis Academic Senate.
https://localwiki.org/davis/Larry_Vanderhoef

After being named chancellor in 1994, Vanderhoef vowed to bring a world-class performing arts
center to UC Davis.

• “There were any number of people who advised against building a performing
arts center, told him it was just a pipe dream,” said Don Roth, the center’s
executive director. “He listened to them, but he saw the need. He had the vision
to push it through, knowing it would be meaningful not just to our students but
to the entire region. He’ll be remembered for that.”

Read more here:


http://www.sacbee.com/news/local/obituaries/article39380853.html#storylink=cpy

On September 28, 1994, the Fall Opening Convocation and the Inauguration of Dr.
Larry N. Vanderhoef as Fifth Chancellor of the University of California, Davis, began in
the UC Davis Recreation Hall with the musical interlude “Glitter and Be Gay” from
Candide (Leonard Bernstein composer) performed by Lenore Turner-Heinson and the
UCD Symphony Orchestra—with Professor Kern Holoman as conductor.

Holoman’s selection for Larry Vanderhoef inauguration dedicated to new chancellor


was not a coincidence. “Glitter and Be Gay” dedicated to his partnership with Larry
Vanderhoef which includes the following lyrics is speaking for itself.

Glitter and be gay,


That's the part I play;
Here I am in Paris, France,
Forced to bend my soul
To a sordid role,
Observe how bravely I conceal
The dreadful, dreadful shame I feel.
Ha ha ha ha!

https://www.youtube.com/watch?v=aVsLMxam21I

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Apparently in 1997, Danny Gray who could not stand Holoman close relation with
Vanderhoef blackmailed Vanderhoef via Dennis Shimek and Vandehoef issued letter of
suspension for professor Holoman to keep Danny Gray of his and Holoman and Shimek
back Like Vanderhoef. Danny Gray was looking for revenge out of his jealousyafter
professor Holoman told him “Goodbye”

Professor Holoman was a Francophile. In 1989, the French government named him a
chevalier of the Ordre des Arts et des Lettres; in 1999, Holoman was elevated to the
rank of officier in the order. Maybe he was dedicating “Glitter and Be Gay” to Danny
Gray in memory of their dramatic relationship—or in memory of the envelopes full
of francs he gave to Danny Gray in 1987 to spent in his favor Parisian restaurant. The
goodbye kiss on envelope with francs was the message “Toujours, K.”

In addition to his scholarship, teaching, and conducting, UC Davis Music Professor and
UC Davis Symphony Orchestra Conductor Dallas Kern Holoman was instrumental in
planning and fundraising for the $57 million needed to build the 1,800-seat Mondavi
Center. The UC Davis Symphony Orchestra was the first to perform in the center, which
opened in 2002 as one of Northern California’s premier performance venues. The
orchestra has called the center home ever since.

The “class performing arts center” in UC Davis became the obsession of Vanderhoef and
his good friend Holoman. However, Professor Holoman’s special friendship with
undergraduate student Danny Gray could have ruined their dream and their careers.

In 2006, Vanderhoef found himself on a collision course with the UC Davis faculty.

Jerold Theis works at UC Davis as a medical microbiology professor; his research


interests include forensic pathology and foodborne parasites. In January 2006, Theis—the
chair of the Academic Freedom and Responsibility Committee in the Academic Senate—
created a petition for a vote of no confidence regarding Vanderhoef’s leadership. Theis
argued that the university administration had become bloated and that Vanderhoef had
“wasted millions of dollars of state money to preserve the power structure.”

Vanderhoef presided over the largest increase in administrative officers in the history of
the campus.

In late March 2006, Theis began investigating claims made by one of the center’s former
surgeons, Casey Daggett, against the UC Davis Medical Center. Casey alleged that after
he raised complaints against the UC Davis Medical Center’s practices, the university
pressured him into resigning by threatening to ruin his medical career. Casey’s
complaints included cases of “patient maltreatment, inappropriate sexual relations and
personal harassment in the workplace.”

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On June 2, 2008, Vanderhoef announced his resignation as chancellor.

Shortly after, on November 21, 2008, UC Davis announced that Professor Holoman was
stepping down from his position as the Barbara K. Jackson Professor of Orchestral
Conducting. Holoman was scheduled to step down the following June, ending a
distinguished 30-year tenure.

CHAPTER VI
“MeToo” DANNY GRAY – PARTS UNKNOWN - “My Toy Boy and My Bitch”

Yolo County Superior Court Randolph Vergos vs. The Regents of the University of
California, Allen Tollefson and Julie McNeal , Case No. CV 02-16

Danny Gray was hired in 2001 as a UC Davis HR Analyst or HR Consultant by Vice


Chancellor Dennis Shimek. On 09/19/2002 UC Davis employee Randolph Vergos filed a
lawsuit in the Yolo County Superior Court against the UC Regents and two of his UC
Davis superiors, alleging sexual harassment as well as retaliation and other unlawful acts,
claiming that his superiors had been making his employment and life miserable.

The lawsuit was docketed in the Yolo County Superior Court as Randolph Vergos vs. The
Regents of the University of California, Allen Tollefson and Julie McNeal, Case No. 02-
16. The case was assigned to Superior Court Judge Hon. Thomas Warriner. Randy
Vergos was represented in his complaint by attorneys Geraldine Armendariz from San
Francisco. Allen Tollefson and Julie McNeal were represented by the Porter Scott law
firm from Sacramento.

Randy Vergos was employed in the UC Davis Facilities Management as an inspector,


planner, and estimator. His direct supervisor was Allen Tollefson, who is today the Head
of Facilities Management Department with the title Associate Vice Chancellor and an
annual salary of $222,000. In 2002, Julie McNeal was a Director of UC Facilities
Management and Allen Tollefson’s superior.

Randy Vergos alleged that he was sexually harassed in his employment by his supervisor
Allen Tollefson and that Julie McNeal refused to recognize the substance of Vergos’s
grievances or take effective action to prevent the recurrence of Tollefson’s conduct or
protect Vergos from future unwelcome contact with Tollefson.

“In Vergos, Allen Tollefson is portrayed as a sexual predator hitting on his


subordinate Randy Vergos by calling him "my boy toy" and "my bitch."

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Vergos also alleged that Tollefson followed him around, came up
unexpectedly behind him, stared at his hair and body, made comments
about the penises of other men, said that one man had pretty lips, tugged at
his own (Tollefson's) crotch, and got angry when Vergos refused to move
into Tollefson's office.”

In November 2012, I met Allen Tollefson on the UC Davis Main Campus; he was
assigned as a Skelly Reviewer to review my case with intent to terminate my
employment.

I learned about the Vergos case in 2015 due to my self-representation in a wrongful


termination lawsuit that I filed on December 4, 2013 in the Sacramento County Superior
Court against the university and nine individuals from the UC Davis Medical Center. The
case was docked in the Court as Case No. 34-2013-00155479 Jaroslaw (“Jerry”)
Waszczuk v. The Regents of the University of California, University of California Davis
Health System, UC Davis Medical Center, UC Davis, Ann Madden Rice, Mike Boyd,
Stephen Chilcott, Charles Wichter, Danesha Nichols, Cindy Oropeza, Brent Seifert,
Patrick Putney, Dorin Daniliuc, and Does 1 Through 50, Inclusive.

In my Motion for Reconsideration (anti-SLAPP motion) filed in Court on


02/20/2015, I addressed Allen Tollefson as follows:

“If Plaintiff would have known about the Vergos v. The UC Regents case
in November 2012, then Plaintiff would have objected, for the record, not
to have his case heard by Skelly reviewer UC Davis Associate Vice
Chancellor Allen Tollefson in November 2012. Tollefson had been sued
for sexual harassment in Randy Vergos v. The Regents of University of
California.

The Court of Appeal, Third Appellate District (3DCA) Case Vergos v. McNeal, Case
No. C051469

On August 5, 2005, three years after Vergos filed the lawsuit against UC Regents ,
Tollefson and McNeal , the attorneys Michael Pott and George Acero from the notorious
Porter Scott law firm, representing the UC Regents, Tollefson, and McNeal, somehow
managed to file a special motion to strike on behalf of Julie McNeal (anti-SLAPP
[Strategic Lawsuit Against Public Participation] motion) pursuant to Code of Civil
Procedure 425.16 (C.C.P § 425.16). This anti-SLAPP motion was accepted by Yolo
County Superior Court(Hon. Judge Thomas Warriner), then denied on 11/22/2005, and a

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Porter Scott lawyer representing university automatically filed an appeal in 3DCA,
known as Vergos v. McNeal, Case No. C051469.

The timing of a special motion to strike is governed by section 425.16(f):

The special motion may be filed within 60 days of the service of the complaint or,
in the court’s discretion, at any later time upon terms it deems proper. The motion
shall be scheduled by the clerk of the court for a hearing not more than 30 days
after the service of the motion unless the docket conditions of the court require a
later hearing.

The 60 days filing time for anti-SLAPP from the time of the complaint being filed by the
Plaintiff is dictated because of the discovery-limiting under section 425.16(g).

Vergos filed the lawsuit in 2002; most likely, document production, discovery, and
interrogatories that are not permitted by section 425.16(g) were done in this case. The
language of this section provides for filing after the 60-day period only “in the court’s
discretion.” But not after partial or full discovery in the case.
The Yolo County Superior Court only has an internet option to review the Register of
Action (ROA); there is no option to pay by credit card to retrieve the case file via internet
and print or save it, as is offered by the Sacramento County Superior Court and other
courts. As such, I did not have time to go to the Yolo County Superior Court to review
the trial court file of the Vergos case than I don’t know all details what happened in the
Yolo County Superior and how the Vergos case ended in the Yolo County Superior
Court in 2007.

The appeal was argued on December 13, 2006 by attorneys George Acero and James A.
Michael. On January 23, 2007, the Court of Appeal, Third Appellate District (3DCA)
justices Hon. Rick Sims, Hon. Harry E. Hull, Jr., and Hon. Tani Cantil-Sakauye reversed
the trial court judgment and granted to Julie McNeal the anti-SLAPP in certified opinion
for publication (attached), known and cited as Vergos v. McNeal (2007) 146 Cal.App.4th
1387 (Vergos).

I don’t know how it was possible for the trial court to accept an anti-SLAPP motion 3
years after the filing of the complaint. I am scratching my head wondering how it was
possible that 3DCA on its own motion did not dismiss the McNeal appeal, knowing that
the anti-SLAPP motion was filed 3 years after Vergos filed his complaint against
Tollefson and McNeal in Yolo County Superior Court .
Justice Hon. Tani Cantil-Sakauye was a UC Davis undergraduate and graduated from the
UC Davis School of Law, Justice Hon. Harry E. Hull prosecuted sexual assaults as a
former U.S. Circuit Court Judge, and Justice Hon. Rick Simms, with his experience as an

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Adjunct Professor of Law with Harvard Law School J.D. degree, had strong knowledge
about Title IX and how sexual harassment and sexual predators in school should be
handled. Director Julie McNeal had no any knowledge or qualifications to handle sexual
harassment complaints and Tollefson’s predatory behavior. Tollefson wanted to have
Randy Vergos under his desk in his office for his homosexual pleasure. Tollefson’s
predatory sexual behavior and despicable harassment should have been reported by
McNeal to the Title IX UC Davis Office instead of being covered up in the UC Davis
Facilities Management Department in collaboration with and with the blessing of UC
Davis HR Associate Vice Chancellor Dennis Shimek, HR Manager Humberto Garcia,
and Analyst Danny Gray, newly hired by Dennis Shimek, who allegedly was raped and
sodomized by UC Davis music professor Kern Holoman on several occasions.

I again took a closer look at the Vergos v. McNeal case, which was used against me in
trial court and in 3DCA in 2014-2017. In October 2017, I contacted by email Randy
Vergos’s attorney James A. Michel, who argued the case in the 3DCA in December
2006, and asked him whether he still had the appeal briefs and trial court documents on
his computer. Mr. Michel responded that he was only helping in this case as a research
attorney on appeal and didn’t keep the file on his computer because he does not
specialize in such litigations. However, he argued the case on 12/13/2006 for some
reason

It is still a mystery to me why Geraldine Armendariz, the leading attorney representing


Vergos, did not argue the case on appeal instead of James Michel. Armendariz’s name
caught my attention in October 2017 because at the same time that an unpublished
opinion was issued anti-SLAPP motion filed by the UC Regents attorneys in December
2014 against my wrongful termination complaint, a San Francisco, State Bar of
California Court judge of the same last name (Armendariz) signed a stipulation
punishing my dismissed in December 2014 attorney Douglas Stein, who defrauded me
of my retainer, and colluded with UC Regents attorney Michael Pott and Sacramento
Superior Court Judge David I. Brown he knows for over 20 years .

This stipulation signed by the Hon. Lucy Armendariz completely ignored a long time
relationship between Douglas Stein and Hon. David I. Brown of “knowing each other”
for more than twenty years. (See stipulation and my protest to stipulation, attached.)
Apparently, Douglas Stein’s wife discovered his relationship with Judge Brown at some
point and divorced him, devastating him financially. As a result, in September -December
2014 Stein attempted to sell my case for approximately $300,000 to UC Regents legal
counsel Michael Pott from Porter Scott law firm with the help of his longtime friend
Judge Brown who was dragged in the dirty Stein’s and Pott’s game against me . State Bar
Investigator Laura Sharek and Deputy Trail Counsel Laura Higgins and the 3DCA
Justices did not wanted to hear about Douglas Stein and Hon. David Brown of “knowing
each other for more than twenty years .

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http://members.calbar.ca.gov/fal/Member/Detail/131248

The Yolo County Superior Court only has an internet option to review the court
Register of Action (ROA); there is no option to pay by credit card to retrieve the case file
via internet and print or save it, as is offered by the Sacramento County Superior Court
and other courts. As such, I did not have time to go to the Yolo County Superior Court to
review the trial court file of the Vergos case and fully review the facts what happened to
Vergos case.
The Yolo County Superior Court Register of Action in the Vergos case shows that, after 3DCA
issued the certified opinion for publication in the anti-SLAPP motion Vergos v. McNeal (2007)
146 Cal.App.4th 1387 (Vergos) on January 23, 2007, the Peremptory Challenge (CCP
§170.1- 170.6) to disqualify the judge was filed, and the whole case was dismissed on
April 27, 2007. At this point, I don’t know whether the case was settled by the UC
Regents with Randy Vergos. What I know is that the Third Court of Appeal Third
Appellate District, by certified opinion for publication cited as Vergos v. McNeal (2007)
146 Cal.App.4th 1387 (Vergos), empowered and gave protection from prosecution to the
white collar criminals and child pornography lovers listed in my wrongful termination
lawsuit as Defendants Stephen Chilcott, Danesha Nichols, Brent Seifert, Mike Boyd,
Cindy Oropeza, Charles Witcher, and others like them Wendy Delmendo, Steven
Drown, Teresa Parker, Gina Harwood, Travis Lindsey, Gina Guillaume-Holloman,
Humberto Garcia, Dr. Shelton Duruisseau, Robert Taylor, Betty Andreos, Larry
Vanderhoef, Ralph Hexter, John Lohse, Charles Robinson, Judith Rosenberg, Veronica
Busby ; Hugh Parker, Matt Carmichael, Dr. Carol Kirshnit, Robert Waste, Vincent
Johnson, Sheryl Vacca, Bruce Hupe, John Fox, Nicholas Eversole, Dennis Shimek,
Rahim Reed, Leslie Moore , Cinthia Vroom, David Levine, Dr. Darin Latimore, Michael
Allen, Roy Ashburn, Joseph Epperson, Karen Petrulakis, Peter Eng, Carissa Andersen,
Margaret Vu, John Perez,Sala Marbella, Marilyn Tays, Anna Orlowski, Daniel Dooley,
Mia Belk, Stan Nosek, Michael Sheesley, Claire Pomeroy, Ann Madden Rice, Robert
Loessberg-Zahl, Dwaine Duckett, Jeremiah Maher, and many others connected to them,
including rapists, sexual predators, and other “bandits” of all colors protected by the
University of California, other public schools, and governmental entities like the
including California Courts

In my May 25, 2015 meet and confer letter to California Deputy Attorney General
Ashante Norton, representing the California Unemployment Insurance Appeal Board
(CUIAB) in the 3DCA appeal pending since May 2015 in Petition for Writ of Mandate
case Waszczuk v. CUIAB, Case No. C0254 with Real Party in Interest (RPii) UC Regents,
I wrote (letter enclosed):

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“The State of California's Attorney General's Office is the author of the
Civil Rights Handbook and the enforcing agency for these civil rights. The
University of California, unintentionally or intentionally, has become a safe
haven for many managers and supervisors who have violated employees'
civil and human rights. I could compare the scale of this protection to that
provided by the Catholic Church for clergy accused of child abuse, taking
into consideration the amount of money each organization has paid to
victims due to lawsuits and out-of-court settlements.

Most likely, the scale of the violations of employees' civil and human rights
in the university environment is much higher than has been disclosed, as
employees fear losing their employment and are often unwilling to
jeopardize their families’ wellbeing.”

Yolo County Superior Court Case No. 03-76 Edith F. Cartwright vs. Regents of
University of California, Dennis Shimek, Daniel Gray (Danny Gray), Humberto
Garcia, Allen Tollefson, and Julie McNeal.

On or around January 14, 2003, shortly after Randy Vergos filed his lawsuit against the
UC Regents and his two superiors Allen Tollefson and Julie McNeal, Vergos’s friend and
coworker Edith F. Cartwright filed her own lawsuit against the UC Regents and five UC
Davis employees.
The lawsuit included two of the same defendants as Vergos’s 2002 lawsuit: sexual
predator Allen Tollefson and his boss, Facilities Management Department Director Julie
McNeal.
Surprisingly, the lawsuit also included Daniel “Danny” Gray, who had just been given
the position of HR analyst/consultant in the UCD HR Department. Gray received this
position after he graduated from the UC San Francisco Hastings College of Law.
UCD HR Assistant Vice Chancellor Dennis Shimek worked together with UCD HR
Manager/Supervisor Humberto Garcia. I met Shimek and Garcia in circumstances similar
to those described in Vergos’s and Cartwright’s lawsuits. The California and Federal
Courts and state and federal agencies are full of lawsuit and complaints against UC
bandits and predators who have notoriously violated UC students’ and employees’ civil
and human rights; The deep rooted corruption in UC system spread out like cancer to
court and state governmental agencies including California courts

Cartwright’s First Amended Complaint (FAC) was filed on 11/12/2003 and alleged
discrimination and retaliation. The FAC stated eight Causes of Action (COA) and also
provided additional information:

• Cartwright began her employment with UCD in or around August 1987.

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• In 1992, Cartwright filed a sexual harassment complaint with the UCD HR
Department; after the investigation concluded, UCD settled out of court with
Cartwright in 1994.
• Cartwright can’t access the 1994 Settlement Agreement with the UC Regents
because HR most likely did not provide her a copy of the agreement.
• Cartwright is Native American and is the only Native American superintendent in
the UCD Facility Services.
I don’t know why Gray—who allegedly was sexually assaulted as a student and raped
twice by UCD Music Professor Kern Holoman—became a subject of Cartwright’s
lawsuit. Based on his “MeToo” story, whether he fell in love with Professor Holoman
and vice versa or whether Gray was or is a victim or con-artist or something else
altogether is difficult to determine.
A significant possibility exists that—both inside and outside the UC system—plenty
more people just like Gray have exchanged sex for favors such as graduation and good
jobs. Many of them most likely were poor students who became easy prey for the well-
organized gang of sexual predators and rapists who occupy high positions in the UC
system and who have connections with government officials, judges, and lawyers—many
of whom are just as despicable as the UC sexual predators and white-collar criminals.
My words are not empty.

In the other Edith Cartwright’s complaint filed in the Yolo County Superior Court
against UC Regents . UC Davis HR Vice Chancellor Denis Shimek and manager from
UCD Facilities Management Department Sal Genito III , Case No . CV- 05-1778 you
could read :

CONSPIRACY

Each of the defendants was a co-conspirator of the remaining defendants


and each planned, performed, failed to investigate, condoned, ratified,
failed to report, and concealed the misconduct.

HOSTILE WORK ENVIRONMENT

Defendant Employer has a HOSTILE WORK ENVIRONMENT in which:


1) Women in the Physical Plant-Facilities-Operational Department are
routinely subjected to sexual harassment, harassment, and discrimination;
2) People of same gender sexual orientation are routinely subjected to hate
crime, harassment, and discrimination; and
3) People of color are routinely denied advancement, wrongfully
terminated, and subjected to harassment and discrimination. On or about
2000, Defendant Employer commissioned a committee to investigate and
make findings regarding it "Staff Workforce Issues." On or about 2000
May 01, said committee completed said review and made the following

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finding:

"Racism, sexism, and homophobia are a part of our culture and it needs to
be acknowledged that they are going to be apart of our hiring committees[.]
The climate is unresponsive to those who look different, i,e., skin color. It
seems that this campus is removing diverse staff from 'UC high positions.
That is a pretty clear message that the folks at the top don't really value
diversity[.] Based on their availability in the workforce, the numbers of
women and persons of color in the UC Davis workforce lag in their
representation in several job groups[. O]only in service workers are persons
of-color over­ represented; women are over-represented in the laborers
groups[.)"
On or about 2002 to 2003, Defendant Employer commissioned a committee
to investigate and make findings regarding its "Organizational Culture and
Workplace Climate." On or about 2003 March 25, said committee
completed said review and made the following findings:
"The workplace climate is problematic. The human resource leadership
issues are serious and problematic. The moral is low for most of the staff.]
there needs to be an immediate effort to address a myriad of critical human
resource issues including: Accurate and consistent policy interpretation,
accurate job descriptions and job classifications, pay equity, hiring and
promotional practices, performance management, appropriate disciplinary
action, rewards and recognition, timely and accurate communications, and
management practices and issues of management/employee trust."
Peer Review Final Report, page
5. The HOSTILE WORK ENVIRONMENT has real impact on personnel.
Female Employees Management Supervising Officer Annette Cross and
Donna McDaniel committed suicide because of harassment and sex-based
discrimination by Defendant Employer. Same Gender Orientation
Employees Ivette Rivera, Rene Barney, and Pam Pane quit or were
otherwise separated from employment because of harassment and same
gender sexual
. orientation discrimination by Defendant Employer. Employees of Color
Kenneth Black, Linda Turner, Kenneth Daly, and "John" Williams are just
four of dozens of employees of color that have suffered race-, ethnicity-,
and color-based harassment and discrimination by Defendant Employer and
filed Department of Fair Employment and Housing Act complaints
therefore

PATTERN AND PRACTICE

Defendant Employer has a PATTERN AND PRACTICE of allowing male


Managing Agents to sexually harass junior female employees as follows:

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On or about 1988 Spring, sexual harassment pervaded the entire worksite.
Managing Agent Jerry Keen regularly made sexual innuendos-including
that junior, female Employee Kim Osmandson "wore breasty outfits,"
insisted that female employees accompany him to singles bars during lunch
breaks, insisted on buying female employees alcoholic drinks during lunch
breaks, insisted on opening doors for female employees in order to touch
and rub against female employees, and coerced several junior female
employees into having relations with him.
(b) On or about 1988 February, Managing Agent Katherine
Henderson admitted that Defendant Employer had a pattern and practice of
allowing Managing Agent Jerry Keen to sexually harass female employees.
Henderson stated, "You know Keen's going to come around. It's usually
between Wednesdays and Fridays after he comes back from Bumps (a
hetero-sexual, singles bar). It's just a matter of time before he approaches
you because he approaches all women. I just wanted to give you the heads
up. I just want to make sure you are not on his bad
side." Plaintiff Employee responded, "How do I do that?" Henderson
stated, "Be nice to him, placate him, do not be rude to him, do not reject
him."
{c) On or about 1988 March, Managing Agent Jerry Keen coerced junior
female employee Jane Doe into having sexual relations with him. Jane
Doe became pregnant and brought charges of sexual coercion and
harassment against Defendant Employer.

Nine years have passed since Edith Cartwright’s attorney Geraldine Armendariz wrote the
above statement published by UCOP mentioning Rankin & Associates Consulting, the
UC Campus Climate Assessment Project, and the UC System-Wide Final Report, which
cost approximately $600,000. This anonymously detailed survey, based on deep research
in examples such as the one found on Page 83 (“Exclusionary, Intimidating, Offensive
or Hostile Conduct”), shows that nothing was improved or changed in the UC system or
the California courts. UC students and employees are still being “raped” , abused, and
treated like sub-humans by UC bandits and California legal system judges and justices
associated with corrupt UC administration in every campus and every office, especially
HR offices and offices associated with Chancellors and Provosts, not to mention the
UCOP Headquarters in Oakland. In many cases, these situations are most likely similar to
the ones experienced by Vergos, Cartwright, and Gray, who were being trapped by the
sexual predators from the HR offices or other UC campus offices; the perpetrators were
aided by co-conspirators, and the investigations sought only to silence the victims by
destroying their lives and livelihoods.
http://campusclimate.ucop.edu/_common/files/pdf-climate/ucsystem-full-
report.pdf

On Page 84, the report states:

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Observations of Exclusionary, Intimidating, Offensive or Hostile Conduct

“Respondents’ observations of others experiencing exclusionary conduct


may also contribute to their perceptions of campus climate. Twenty-three
percent (n = 23,563) of all survey respondents observed conduct or
communications directed towards a person or group of people at a UC
campus/location that they believed created an exclusionary, intimidating,
offensive and/or hostile working or learning environment within the past
year. Most of the observed exclusionary conduct was based on race (20%, n
= 4,743), ethnicity (20%, n = 4,617), position (17%, n = 3,911), gender
identity (13%, n = 3,144), and political views (12%, n = 2,837).
Twenty-one percent of respondent marked “don’t know” as the basis (n =
4,871”

CHAPTER VII
“Me Too” – PARTS UNKNOWN – DANNY GRAY AND HIS FRIENDS

Besides the previously presented Yolo County Superior Court Case No. 03-76, Edith
Cartwright filed three other lawsuits against UC Davis HR “bandits” and sexual
predators.

Case No. 03-76 was filed in Yolo County in January 2003 against the Regents of the
University of California, SAL GENITO, ALLEN TOLLEFSON, DENNIS SHIMEK,
DANIEL GRAY (DANNY GRAY), HUMBERTO GARCIA, JULIE MCNEAL,
LOUIE J. SLAYTON, DARRELL RALLS, and AL MINE and was transferred by Edith
Cartwright’s attorney Barry Sabahat of Anchor Law Group from San Jose, CA to the
UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF
CALIFORNIA in Sacramento, California on April 13, 2005 and was docked in the Court
as Case No. 2:05-cv-00725-MCE-KJM.

In the other three cases, Edith Cartwright was represented by two legal counsels from San
Francisco: Geraldine Armendariz and Philip S. Horne, Esq. The three complaints were:

1. Eastern District of California, Case No.: CV 05725 – Complaint filed


April 14, 2005.

2. Yolo County Superior Court, Case No.: CV 05-1778 –


Complaint filed November 7, 2005.

3. Northern District of California, Case No.: C 05 4610 –


Complaint filed November 9, 2005.

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The above complaints against listed defendants were impressively assembled by Edith
Cartwright’s attorneys Geraldine Armendariz and Philip S. Horne with 22 Causes of
Actions (COA) and a great amount of applicable laws in a style closely akin to criminal
complaints and sentencing memorandums in criminal courts with the District Attorney,
giving tens of counts to convict the defendants.

Filed On November 7, 2005 in the Yolo County Superior Court, the Verified Complaint
for Damages and Injunctive Relief and Demand for Jury Trial for Discrimination And
Retaliation Case No CV 05-1778 with 22 Causes of Action and tens of witnesses, listed
below, shows the seriousness and intensity of the lawsuit against the University of
California and several individuals who decimated Edith Cartwright’s life and livelihood.

• NTERFERENCE WITH CIVIL RIGHTS (42 United States Code 1983)

• INTERFERENCE WITH CIVIL RIGHTS (Civil Code 52.1)


• CONSPIRACY TO INTERFERE WITH CIVIL RIGHTS
• (42 United States Code 1985)
• WHISTLEBLOWER RETALIATON (Government Code 8547.10)
• WHISTLEBLOWER RETALIATION (Labor Code 1102.5)
• DISCRIMINATION AND RETALIATION (20 United States Code 1681(a))
• DISCRIMINATION AND RETALIATION (42 United States Code 1981)
• DISCRIMINATION AND RETALIATION (42 United States Code 2000e)
• DISCRIMINATION AND RETALIATION (Government Code 12900)
• DISCRIMINATION AND RETALIATION (Common Law)
• DISCRIMINATORY THREAT (Civil Code 51.7)
• HARASSMENT OF A SEXUAL NATURE (Civil Code 51.9)
• FRAUD
• (Common Law)
• CONVERSION
• (Common Law)
• INTERFERENCE WITH BUSINESS (Common Law)
• DEFAMATION (Common Law)
• INVASION OF PRIVACY (Common Law)
• INTENTIONALLY CAUSING INJURY (Common Law)
• WRONGFUL BUSINESS ACT (Business and Professions Code 17200)
• NEGLIGENTLY CAUSING INJURY (Civil Code 1714 and Common Law)
• BREACH OF CONTRACT (Civil Code and Common Law)
• BREACH OF THE COVENANT OF GOOD FAITH AND FAIR DEALING
(Common Law)

LISTED WITNESSES IN THE CARTRIGHT LAWSUITS

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• Kevin Galard- University of California;
• SAL GENITO III- UNIVERSITY OF CALIFORNIA,
• Duane Goosen,- University of California;
• Katherine Henderson- University of California,
• Judy Holt- University of California;
• Dennis Jackson- University of California;
• Dave Keller - University of California;
• Charles Kennedy- University of California,
• Lin King- University of California
• Dee Dee Kitterman - University of California;
• Perry Laird- University of California
• ROBERT LOESSGERG-ZAHL- UNIVERSITY OF CALIFORNIA ,
• Lorraine Mallory- University of California ;
• George McKamy- University of California;
• John McKnight- University of California ,
• Chad Mikula- University of California;
• Jeff Mize- University of California,
• Chip Mrizek- University of California,
• Steve Nixon- University of California
• Leslie Nopp- University of California;
• STAN NOSEK- University of California
• Kenneth Pailey- University of California;
• Jeff Phillips- University of California;
• Terry Planiden- University of California ,
• Deborah Rabey- University of California ,
• Andrea Ramiro- University of California;
• Marion Randall,-University of California
• Ted Richards- University of California
• Karen Roth -University of California;
• MARBELLA SALA University of California ;
• Eleanor Sandoval- University of California ,
• Alberto Santana-University of California;
• DENNIS SHIMEK- UNIVERSITY OF CALIFORNIA
• Steve Smith- University of California;
• Jerry Sorensen- University of California
• June Taylor- University of California
• ALLEN TOLLEFSON- UNIVERSITY OF CALIFORNIA
• RANDY VERGOS- UNIVERSITY OF CALIFORNIA
• Susan Wagler- University of California

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• Deborah Wheeler- University of California;
• Karl Williams- University of California;
• Ivette Rivera,
• Dwight Smedley, Folsom Prison
• Steven Sneider
• Tom Tindel,
• Linda Turner
• John Wheeler- Woodland
• Mary Elizabeth White
• Jim and Barbara Wood,
• Michael Allred, University of California
• Cary Avery, University of California
• Rene Barney, University of California
• Kenneth Black, University of California
• Jill Blackwelder, University of California
• Melissa Boelman, University of California
• Marina Coldiron, University of California
• Carole Cukrov, University of California
• Kenneth Daly, University of California
• Terri Delamore, University of California
• Micki Eagle, University of California
• Matt Forrest, University of California

The long list of allegations outlined in the 22 Causes of Action and the long list of
Cartwright’s and the university’s witnesses did not help the battered and victimized
Cartwright to prevail and defeat her unscrupulous and vicious adversaries in the court.
Cartwright lost her battle against UC Davis thugs in the Yolo County Superior Court by
the Motion for Summary Judgment that was granted to the Regents according to
CONSOLIDATED CASE NO. 2:05-CV-02439 MCE-KJM PLAINTIFF'S MOTION IN
LIMINE #2 TO PRECLUDE EVIDENCE OF THE OUTCOME OF THE YOLO
COUNTY LAWSUIT (F.R.E. 403) that Cartwright filed in the U.S. District Court
Eastern District of California on 03/26/2010, which stated:

2.0 ARGUMENT
Under FRE 403, relevant evidence may be excluded "if its probative value
is subs tantially outweighed by the danger of unfair prejudice, confusion of
the issues, or delay, waste of time, or needless presentation of cumulative
evidence."
This exclusion requirement is particularly apropos to this case. Evidence
that Plaintiffs Yolo County lawsuit for discrimination was adjudicated in
favor of Defendants through summary judgment is exactly the kind of

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"MeToo"- DANNY GRAY SI-22-000025
PARTS UNKNOWN -UC DAVIS
evidence that FRE 403 was designed to keep away from a jury. To allow
Defendants to present evidence that they had prevailed in the Yolo County
lawsuit through summary judgment (i) would be highly prejudicial to
Plaintiff-it would only confuse the issues before the jury and put Plaintiff's
case in a negative light-and (ii) has no probative value to the issues of
retaliation, defamation and intentional infliction of emotional distress after
January 14, 2003 which were not adjudicated in the Yolo County action.
(Memorandum and Order, December 18, 2006, Docket No. 65, 14:8-14)
3.0 CONCLUSION
Pursuant to the authorilies cited supra and for the reasons stated above, this
Court must preclude Defendants from presenting any evidence to the jury
as to the outcome of the Yolo County case.

I don’t know why Cartwright lost the Summary Judgment motion with such experienced
lawyers as Philip S. Horne and Geraldine Armendariz representing her in the Yolo County
Superior Court . I did not read the court file from the Yolo County trial court. However, from the
copies of Cartwright’s two complaints that were filed as exhibits in the U.S. District Court
Eastern District of California, it was easy to determine that some parts of the retaliation
and termination of Cartwright’s employment by UC Davis bandits were a copycat
scenario of the retaliation and devastation of my life by gangsters from UCOP, UC Davis,
and the UC Davis Medical Center. Cartwright’s attorneys were similar to my attorney,
who apparently had had a “special relationship” with the Superior Court judge for over
20 years. Additionally, the Regents’ lawyers from Porter Scott removed from the
complaint the most important elements that were ground for Cartwright to prevail against
the Regents in the Summary Judgement and win the whole lawsuit in the Yolo County
Superior Court.

According to the amended complaint filed on October 31, 2003, 4 UC Regents signed
with Cartwright a written Settlement Agreement to settle the dispute and end the sexual
harassment, with written affirmation in the Settlement Agreement that the Regents would
not retaliate against Cartwright after the Settlement Agreement was signed. Cartwright’s
attorneys Philip S. Horne and Geraldine Armendariz ignored the written Settlement
Agreement that Cartwright signed with the Regents in 1994 . Neither Armendariz nor Horne
filed the motion to enforce the breached-by-Regents Settlement Agreement or stated whether the
signed settlement was enforceable.

Just like what happened to me, Cartwright was abruptly terminated in 2003 without
receiving an annual performance review for the years of 2001 and 2002. Cartwright’s
attorney in the complaint made note:

• [Note: Defendant Employer failed and refused to give Plaintiff Employee an


evaluation for 2001 and 2002]

26
"MeToo"- DANNY GRAY SI-22-000026
PARTS UNKNOWN -UC DAVIS
and lost the summary judgment.

The annual employee performance reviews in the UC system are governed and mandated
by UC or UC Davis Policy PPSM 23 and are not something that an employee can be
denied for two years and thereafter have their employment terminated.

The PPSM 23 like all UC policies has policies and procedures have the
force and effect of statute. (Santa Monica, supra, 77 Cal.App.3d at p. 135.),
It is well established that the policies of the University, including the
Personnel Policies for Staff Members (“PPSM”) and the UC Davis Policy
and Procedure Manual (“PPM”), have the force and effect of state statute.
Court Stated in (Kim v. Regents of University of California (2000) 80
Cal.App.4th 160, 165.)

By terminating Cartwright without providing her an evaluation for the last two years of
her employment, UC Davis despicably violated and disregarded the most important of its
own policies and procedures: that which regulates the relations between employer and
employees on an annual basis.

09/26/2012 01:25 PM
Fw: CEMRP2 Eligible Employees With Unsatisfactory Ratings
Carol Shimada ( Bill Gregory, Yvette Gutierrez
Gina Harwood, Travis Lindsey, Carol Shimada

Bill
Can you please go into eHR as there appears to be an eval in the system with an
unsatisfactory rating for JAROSLAW WASZCZUK EMPLOYEE ID 100007732. Once
you located it please cancel the evaluation totally out of the system (i.e., delete).
Steve has indicated that he was on leave for the majority of the review period and should
not have been evaluated with an unsatisfactory rating.
Yvette-
Can you please initiate a deferral on this employee as well, pushing the eval date out
a year to September 2013?
Gina-
Can you advise the dept that we have done this? Steve shared with me the pending action
on this
employee and that we will probably want to correct the system immediately.
Thanks to you all, any questions let me know.

27
"MeToo"- DANNY GRAY SI-22-000027
PARTS UNKNOWN -UC DAVIS
Carol
Carol Shimada ext:4-2718 Manager,
Compensation/Collective
i i / / d

Cartwright’s lawyers failed to appeal the Judgement on Motion for Summary Judgement,
thus giving Edith Cartwright little chance to prevail in the Federal District Court, where
her complaint never should have been filed or transferred from the Yolo County Superior
Court in the first place.

The former UC legal counsel Michael Pott from the Porter Scott Law firm, who
represented the UC Regents against Edith Cartwright’s friend Randy Vergos in the Yolo
County Superior Court and the Court of Appeal, Third Appellate District Vergos v.
McNeal, 53 Cal.Rptr.3d 647, 146 Cal.App.4th 1387 (Cal.App. Dist.3 01/23/2007) in an
anti-SLAPP motion, authored the pamphlet “Six Tips To Prepare Employee Evaluation,”
which advises employers on how significant and important employee evaluation is in terms of
court action brought by an employee against the employer. The pamphlet was published on the
Porter/Scott webpage. It stated:

“Employee performance evaluations are a critical part of the employer-


employee relationship. Well-done evaluations provide guidance and
feedback to employees to help them develop and improve their skills. This,
in turn, benefits the organization. Performance evaluations are also an
important part of minimizing liability if an employment dispute arises. If an
employee challenges a disciplinary action or termination based on
performance problems, a fair and accurate evaluation can be a critical piece
of evidence in defending the case. Conversely, a poorly prepared evaluation
can undermine the employer’s credibility before a judge or jury, or worse,
provide the plaintiff-employee with the evidence needed to prove their
claim.”

It appears that Randy Vergos’s counsel Geraldine Armendariz misrepresented Vergos


and lost his case against sexual predator Allen Tollefson and his partner in crime Julie
McNeal in the Yolo County Superior Court and the Court of Appeal, Third Appellate
District (3DCA). She allowed the Regents’ lawyers to file an anti-SLAPP motion against
Randy Vergos’s complaint 3 years after Vergos filed the original complaint in the Yolo
County Superior Court. Armendariz did not appeal the despicable 3DCA decision in the
anti-SLAPP motion to the Supreme Court. Randy Vergos was raped by the UC system,
his own legal counsel, and the California legal system, which allows thugs and sexual
predators like Tollefson to thrive in UC campuses and prey on students and vulnerable
subordinates.

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"MeToo"- DANNY GRAY SI-22-000028
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It would be interesting to find out whether Geraldine Armendariz knew about Danny
Gray’s complaints against UC Davis Associate Vice Chancellor Dennis Shimek about
being allegedly raped twice by UC Davis Music Professor Kern Holoman and having the
crime be condoned and hidden by Dennis Shimek and UC Davis Chancellor Larry
Vanderhoef.

Surprisingly, in Edith Cartwright’s complaints, DANNY GRAY is not listed as a


witness, and neither is UC Davis Chancellor LARRY VANDERHOEF who, in 1997,
signed a letter suspending UCD Music Professor and Symphony Orchestra Conductor
Kern Holoman, who allegedly raped Danny Gray. Vanderhoef’s close ally and friend
UCD Associate Vice Chancellor Dennis Shimek, who knew the secret of Holoman’s
relationship with undergraduate student Danny Gray, was being targeted in similar
lawsuits to Danny Gray’s as a defendant.

The name of listed witness Sala Marbella caught my attention. From 2011-2014, Sala
Marbella participated in retaliation attacks against several employees from the UC Davis
Medical Center from the Medical Office of the Students and Residents Diversity. The
employees reported credit card embezzlement committed by the manager’s office. UC
Davis auditor William Prindible was called to do an audit report. The auditor conducted
an audit that confirmed credit card embezzlement by the manager’s office. The two
employees who reported the fraud and the 60-year-old auditor William Prindible, who
had bipolar disorder, were fired from the job. I was asked to help one of the employees,
Seema Mani, with a PPSM 70 complaint with HR. She reported the embezzlement, and
she was demoted and reassigned for the complaint she filed with the UCMC HR
Department. She was later fired from the job as well.

I reviewed all of Seema Mani’s grievance documents, including but not limited to the
February 3, 2014 Letter of Intent to Demote, the March 10, 2014 Letter of Demotion
from Assistant II to Assistant I with wage decrease, and the Investigation Report dated
October 31, 2013 prepared by an HR consultant. Instead of representing Seema Mani in
the Step II grievance hearing, which never should have occurred, I have decided to
publish my review as an open letter and submit it to UC President Janet Napolitano as an
example of the insidious UC administration and climate that has harmed thousands of UC
employees.

On June 18, 2014, I addressed Sala Marbella in the letter I sent to UCOP Principal
Investigator Judith Rosenberg as follows:

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"MeToo"- DANNY GRAY SI-22-000029
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As I stated in my previous letter dated June 9, 2014, I will keep you
informed about the UCDHS management's retaliatory action against Ms.
Seema Mani. Also, as in my previous letter, the crux of this letter is a
statement derived from the HR Investigation Report written by UCDMC
HR Consultant Veronica Busby dated October 31, 2013: "Telling a lie
about having a conversation with someone is fairly innocuous compared
to a lie regarding someone making threatening statements." The victim of
such a lie is UC Davis School of Medicine Office of Student and Resident
Diversity Administrative Assistant II Ms. Seema Mani. Ms.
Mani's superior, Interim Manager Marbella Sala, told such an innocuous
lie.

Shortly after I sent you my open letter dated June 9, 2014, I received
information that the 4'innocuous liar" Ms. Marbella Sala-who retaliated
against Ms. Seema Mani and, together with Mr. Latimore, defaced,
defamed and harmed her with unlawful demotion and reassignment- in fact
was formerly convicted as a thief in criminal court. I searched the record in
in the Sacramento County Superior Court and found the case: No.
87M04333 Penal Code No. 484. Ms. Sala was sentenced for her crime on
December 21, 1998. At the time, Ms. Sala was not a troublesome teenager-
by my best estimate, she was a 30-year-old, grown woman, taking into
consideration her length of employment with the University of California.
Ms. Sala's conviction in criminal court was important, yet probably would
never have surfaced if she had not lied to Ms. Mani and later to the HR
investigator in order to create a false report and
to demote and remove Ms. Mani from the Office of Student and Resident
Diversity.

Prior the Seema Mani’s case in 2013 I was asked to help to 60 years old worker Frank
Gonzales who was employed in UCDMC paint shop.
It is unthinkable for a normal person that an employee could be viciously attacked by UC
Davis management right away upon his return from workers compensation disability and
during the arrangement of his mother’s funeral because he filed a legitimate complaint
against an unwarranted letter of expectation using UC Davis Policy PPSM 70. I was
representing this battered by UC Davis management 60-year-old UC Davis Medical
Center worker, Frank Gonzales, who has a long-time outstanding work record with UC
Davis Medical Center, the and worked in the same department where I worked in for 13
years. I was representing Frank Gonzales with the U.S. Equal Employment Commission
in discrimination case EEOC Charge No. 555-2015-00068C, which was filed with EEOC
on October 9, 2014. The EEOC personnel from the Oakland office are terrified of dealing

30
"MeToo"- DANNY GRAY SI-22-000030
PARTS UNKNOWN -UC DAVIS
with the University of California and wer making all kinds of excuses not to have this
case against UC. I don’t not know the reason; perhaps it is because Janet Napolitano is
President of the University of California or EEOC has no proper resources to deal with
the UC Davis administration’s discriminatory behavior toward employees.
In June 2013 on behalf of his coworkers, whom I was helping to cope with abuse and
retaliation from UC Davis management, I asked California Senate President Pro Tempore
Darrell Steinberg, State of California Assembly Member and Chair of the Higher
Education Committee Das Williams and Roger Hernandez, California Assembly Member
and Chair of the Labor and Employment Committee, for help. I thought that maybe he
would get some help from the Darrell Steinberg due to his prompt help in 2000 to restore
employment of four employees from the UC Davis Medical Center Integrated Access
Unit. These employees were complaining about safety issues in their workplace, and they
were escorted out of the job. I was asked to help them as well
Darrell . Steinberg responded to inquiry but refused to help. If in 2013 had known about
60-year-old William Prindible , who was fired from his job because he was doing his
duty, than I would have mentioned this to Darrell Steinberg. The previously mentioned
William Prindible was suffering from bipolar disorder, as was Darrel Steinberg’s
daughter, Jordana, when she was 7 years old, according to many publications. Also,
Darrell Steinberg’s daughter suffered and recovered from more serious mental illness in
very challenging and heart-touching journey. Mr. Steinberg daughter’s illness was a
motor for the Proposition 63.
However, in 2013 I did not know that Darrell Steinberg had secured for himself the
prestigious Director of Policy and Advocacy position for the new UC Davis Behavioral
Health Center of Excellence, the $7.5 million UC Davis center that was funded by
Proposition 63, California’s tax on millionaires to fund programs for people who are
mentally ill. Steinberg, a longtime advocate for mental health programs, wrote the 2004
measure, and the institution was funded by a measure he championed while in the
Legislature. It was a remarkable achievement. However, I am not sure whether Steinberg
knew before he became a Director of Policy and Advocacy for the new UC Davis
Behavioral Health Center of Excellence how many thousands of UC employees,
including myself, were forced to visit psychiatrists and psychologists to seek help
because of unscrupulously abusive, vindictive Nazis like the corrupted UC administration
and management.
Since 2016 Darrel Steinberg is a Mayor of Sacramento
https://www.scribd.com/document/373191529/The-Devil-s-Advocates

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"MeToo"- DANNY GRAY SI-22-000031
PARTS UNKNOWN -UC DAVIS
CHAPTER VIII
“MeToo” DANNY GRAY – PARTS UNKNOWN – EDITH F. CARTWRIGHT’S
LITIGATIONS AGAINST REGENTS OF THE UNIVERSITY OF CALIFORNIA
IN U.S. DISTRICT COURTS

TO BE CONTINUE

Submitted on March 7, 2018 , by electronic mail

Jaroslaw Waszczuk
2216 Katzakian Way
Lodi, CA 95242
Phone 209.339.1982
E-mail: jjw1980@live.com

32
"MeToo"- DANNY GRAY SI-22-000032
PARTS UNKNOWN -UC DAVIS
GARY S. MAY
UC DAVIS CHANCELLOR
FIFTH FLOOR, MRAK HALL
UNIVERSITY OF CALIFORNIA, DAVIS
ONE SHIELDS AVENUE
DAVIS, CA 95616

CHAPTER I

DANNY GRAY’S “MeToo” PARTS UNKNOWN


OPEN LETTER

Open Letter to UC Davis Chancellor Gary S. May about the December 12, 2017,
Davis Enterprise Article “MeToo Arrives at the University of California”

“Many of the reports of abuse emerge after years and sometimes decades
of silence and shame. In the past, few if any institutions had adequate
reporting and investigative processes, UC Davis included. Our protocols
and processes have improved greatly over the years.”
Gary S. May

Dear Chancellor May,


With all due respect to you as a person and a new Chancellor, I am not sure how you
arrived at the idea that the UC investigative process has “improved greatly over the
years.”
You just replaced Greek-born Chancellor Linda Katehi, who was subjected to a
$1,000,000 witch hunt orchestrated by President Janet Napolitano because she did not
like Chancellor Katehi’s foreign accent. I can’t think of any other explanation why
Napolitano spent $1,000,000 in three months to make Katehi into a chancellor emerita
and replace her with a chancellor who has almost the exact same credentials.
I know a bit about the problems that having a foreign accent can invite in UC Davis. One
of my managers once said “somebody give this Polack a bad evaluation and fire him.”
Another manager tried to get me to “step outside” with him; when I refused, he did not
1

"MeToo"- DANNY GRAY SI-22-000033


PARTS UNKNOWN -UC DAVIS
hesitate to threaten to “send the gestapo on [my] ass.” He eventually made good on that
threat and sent gestapo from the UCOP IV Department of RSHA to take care of me and
Chancellor Katehi thereafter. Please don’t be outraged that I am using terminology from
the Third Reich and Soviet Union in my stories. I use the terms because I was subjected
to them at UC Davis. I dealt with hearing Polack and gestapo more than you would
probably believe. I never expected to be treated so poorly in this country. I am an
immigrant. Before I came to America, if had known what my life would be like here,
then I might have decided to stay in a communist prison rather than agree to be deported.
Those were my options: remain in prison or be deported with a one-way passport. I had
more respect from guards in a communist prison than I have received from the UCOP
gestapo and their thugs from UC Davis and the UC Davis Medical Center (UCDMC).
The sanction letter that you served to Professor Baldini exactly described the methods
that I experienced from the UCOP gestapo.
On May 31, 2012, I was lucky to arrive home in one piece after visiting the UCDMC
earlier in the day. Chancellor Katehi is lucky that she did not join California Senator
Leland Yee on his vacation in Federal Correctional Institution, Fort Worth, Texas. Yee—
now Register Number 19629-111—was hunted down by the UCOP gestapo for his
“Bernie Sanders” ideas to improve investigative protocol in the UC system through 2010
Senate Bill SB 650 and other anti-UCOP bills. In January 2010, Yee requested a state
audit to improve investigative protocol. Subsequently, UC President Yudof and UC
Davis Chancellor Vanderhoef found themselves in court and were facing one year in
prison because of Senator Yee and SB 650. The allegations against Yudof and
Vanderhoef stemmed from their malicious oppression of UC Davis Registered Nurse
Janet Keyzer. This was too much for the UCOP gestapo; it was also the reason that Janet
Napolitano became a UC President in 2013 and that UC Davis alumna Honorable Tani
Cantil-Sakauye is currently Chief Justice of the State of California.
In her publicized research, Jennifer Skeem (professor of psychology from UC Irvine)
emphasized that:

“An individual doesn’t necessarily need to be physically violent or a


common street criminal to have psychopathic traits,” she says. Skeem
points to Gordon Gekko, the unscrupulous financial executive played by
Michael Douglas in the 1987 film “Wall Street,” as someone with all the
signs of psychopathy. She cites the Ponzi scheme mastermind Bernie
Madoff and Enron executive Andrew Fastow—ruthless, detached
individuals who showed little remorse for robbing victims of their life
savings—as real-life examples.

"MeToo"- DANNY GRAY SI-22-000034


PARTS UNKNOWN -UC DAVIS
The part two of the first chapter will be sent within a few days as time allows.

By this DANNY GRAY’S “MeToo” PARTS UNKNOWN


Chapter XIII I am respectfully appealing to you, Chancellor May, to disregard Nichols’s
witch hunt report aimed at Professor Baldini and his family and to let Professor Baldini
return to his normal duties and normal life.

CHAPTER XIII
“MeToo” – MAESTRO CHRISTIAN BALDINI

THE HDAPP INVESTIGATION OF UCD MUSIC PROFESSOR AND UCD


SYMPHONY ORCHESTRA CONDUCTOR CHRISTIAN BALDINI

Summary of Investigative Findings from HDAC170177 Sexual Harassment


Allegations, Orchestra; Brief Summary of How Case Came to Title IX Office

While carefully reading the Summary of Investigative Findings, I noticed the following:
Brief Summary of How Case Came to Title IX Office: On May 12,
2017, an official from the Harassment & Discrimination Assistance and
Prevention Program (HDAPP) spoke with Witness A, who reported
that the Complainant had alleged a concerning interaction between
the Complainant and Respondent. On May 18, 2017, Complainant met
with an official from HDAPP. Complainant received written notice of
the present investigation by electronic mail on June 20, 2017.
Respondent was notified of the allegations against him by electronic
mail on June 20, 2017.
• On May 12, 2017, an official from the Harassment & Discrimination Assistance
and Prevention
Program (HDAPP) spoke with Witness A, who reported that the

Complainant had alleged a concerning interaction between the Complainant and


Respondent. On May 18, 2017, Complainant met with an official from HDAPP.

"MeToo"- DANNY GRAY SI-22-000035


PARTS UNKNOWN -UC DAVIS
Complainant received written notice of the present investigation by electronic mail
on June 20, 2017. Respondent was notified of the allegations against him by
electronic mail on June 20, 2017.

The above statement indicates that Professor Baldini’s alleged concerning interaction
with the Complainant was reported to HDAPP on May 12, 2017, by a person other than
the Complainant. The statement does not indicate whether allegations were reported in
person or by phone hotline, email, or fax. The statement does indicate whether HDAPP
called the Complainant and coerced her into filing a formal report or whether the
Complainant came to the office voluntarily six days later on May 18, 2017.

15. At 6:37 p.m. the same night, Respondent sent Complainant an email.

15. At 6:37 p.m. the same night, Respondent sent Complainant an email
saying that he should have invited Complainant to print a score with
him, that they could have in his office and that "I was very much
enjoying spending time with
YOU."
Both parties agreed that the November 18, 2016 meeting ended when
Respondent said he needed to go print a score. Attachment C reflects the
content of Respondent's follow-up email communication, and neither
party disputed it. Both parties stated that Complainant did not respond to
the message.
16. After winter break, on January 14, 2017, Respondent contacted
Complainant to ask if she was okay and to suggest times to talk later that
week.
Attachment C reflects the content of that communication, and neither
party disputed it.
17. Complainant responded on January 16, 2017 that she was fine and
did not need a meeting.
Attachment C reflects the content of that communication, and neither
party disputed it. Complainant credibly stated that she consulted with
non-orchestra friends about how to respond to the meeting request and
she decided to be clear that she did not want a meeting even though it
was difficult for her to disappoint people.
18. Respondent replied that he did not want an "official 'meeting" and
that she should let him know if she ever wanted to try
Attachment C reflects the content of that communication, and neither
party disputed it.

"MeToo"- DANNY GRAY SI-22-000036


PARTS UNKNOWN -UC DAVIS
19. Toward the end of the year, Complainant went to Respondent's office
to ask to borrow
the Mondavi[hat was their first one-on-one communication since
January.
The parties agreed that Complainant and Respondent did not interact
one-on-one or over email between the January exchange and the May
time frame, when Complainant went to Respondent's office to ask
permission to borrow the Mondavi

The above statement should be the end of the story. However, the email was concerning
because it included “I was very much enjoying spending time with YOU.”
The HDAPP investigator did not pursue the remark and did not question Professor
Baldini or ask him to explain himself and his motives. The Complainant also did not
elaborate whether she considered the statement to be offensive or sexually suggestive.
Following the email communication on January 17, 2017, Professor Baldini did not make
any further attempt to contact the Complainant via email or phone or to approach her
during orchestra rehearsal.
Furthermore, the investigation report does not clearly state why the Complainant left UC
Davis after she reported Professor Baldini.

Letter of Censure and Notice of Disciplinary Action: September 28, 2017

Chancellor May, according to your September 28, 2017, Letter of Censure and Notice of
Disciplinary Action (in strict confidence), Professor Baldini was not admonished as
stated in the Davis Enterprise article but was severely punished with a long suspension
without pay and the threat of termination of his employment. This was based on
information outlined in Summary of Investigative Findings written by Danesha Nichols
or her subordinate from the HDAPP office.

Accordingly, you will be suspended without pay for winter quarter,


2018, during which time you will have all of your normal faculty
privileges suspended. Accordingly, from January 1 through March
23, 2018, you will not be permitted to be present on University
property without prior written permission from the Associate Dean
of Humanities, Arts and Culture Studies, Claire Waters. You will
not be permitted to spend or draw upon University research or
111 This letter quotes from the version of the Faculty Code of Conduct
that was in effect throughout academic year 2016-17.

"MeToo"- DANNY GRAY SI-22-000037


PARTS UNKNOWN -UC DAVIS
Professor CHRISTIAN BALDINI September 28, 2017 Page 3
gift funds, or be reimbursed by the University for travel or other business
related expenses. You will not be permitted to publicly represent
yourself as a UC Davis faculty member during this time. Because you
are an academic year appointee receiving your 9 month salary spread out
over 12 months, your pay will be suspended for a period of 4 months,
from December 2017 through March 2018.
For the duration of the period of suspension, you may make use of the
services of the Academic and Staff Assistance Program
(http://www.hr.ucdavis.eduy/asap/). You also may contact the Davis
Division of the Academic Senate and or DIRECTOR DANNY GRAY
of the Office of Academic Affairs (dgray@ucdavis.edu or 530-752-
2090) without prior permission. However, if you need to communicate
with any other faculty, staff, or students, or to gain access to your office
or any other UC Davis facility for any reason, please contact Associate
Dean Waters. If you do not adhere to the terms of your suspension,
you may be subject to further disciplinary action.
A copy of this letter will be retained in a confidential file maintained in
the Office of the Vice
You also may contact the Davis Division of the Academic Senate and or
DIRECTOR DANNY GRAY of the Office of Academic Affairs
(dgray@ucdavis.edu or 530-752-2090) without prior permission., Chancellor May
stated in his “execution “ letter

My understanding is that on September 25, 2017, through his attorney, Professor


Baldini accepted the proposed sanction of suspension without pay for one
quarter. This is a significant monetary loss for the modest salary of a professor
and a conductor of the UC Davis Symphony Orchestra. The professor’s motive
for not to contesting the punishment or negotiating with the Chancellor’s office
for alternate resolution remains a mystery. Perhaps the stressed and humiliated
professor did not want to deal with the very unprofessional “my way or the
highway” ultimatum in your sanction letter.
On December 29, 2017, Professor Baldini provided the Davis Enterprise with his rebuttal
statement concerning the devastating blows to his family life and career that were
delivered by the Summary of Investigative Findings. My best guess is that after he read
the December 12, 2017, Davis Enterprise Danny Gray “MeToo” story, Professor Baldini

"MeToo"- DANNY GRAY SI-22-000038


PARTS UNKNOWN -UC DAVIS
figured out that he was framed by “Americanos.” He probably sang “Don’t Cry for Me
Argentina” as his song of despair.
Crafted with evil intentions, the pseudo-investigation report by Nichols (most likely as a
joint venture with Gray and Wendi Delmendo) was an obvious prelude to Gray’s
“MeToo Arrives at the University of California.” The article details 30 years of an
allegedly unwelcomed sexual relationship with UC Davis Music Professor and Orchestra
Conductor Kern Holoman.

December 2017: Professor Baldini’s Statement

https://www.davisenterprise.com/files/2017/12/Statement-by-Christian-Baldini-.pdf

Over a year ago, a member of the UC Davis Symphony Orchestra felt


that my behavior towards her was inappropriate. I am devastated by the
accusation and terribly sorry about the effect on my student. I accept
responsibility for the misunderstanding and have taken many steps to
ensure nothing like that will ever happen again. I am glad to work in a
place where these issues are taken seriously.
During a brief conversation in my office, the student in question
expressed interest in knowing more about my culture, music and regional
foods. When she mentioned she would love to dance but that she was
terrible at it, in a very casual way I volunteered to teach her a couple of
tango steps, and upon her enthusiastic acceptance of my offer we
proceeded to do a brief tango demonstration which at the time seemed to
be completely harmless and innocent. Even though nothing sexual was
intended, I deeply regret that over time this was perceived by my student
in such a way. My faults are failing to recognize that my behavior could
have a reaction in her that was unintended. I feel contrite and remorseful
that one of my students would have felt this way by something I did, and
I deeply apologize for any stress and pain this may have caused.
I was born and raised in Argentina and for the first 24 years of my life I
lived in a society where (non sexual) physical contact was widely
accepted as a normal and daily form of communication. Greeting with a
kiss on the cheek, hugging and touching is common in the culture of my
upbringing, and I am not saying this to justify my actions, but simply to
point out that after living in the US for 14 years, I am acutely aware of
these cultural differences. I thought I had learned through experience and
that I was successfully adapting myself in different cultures and contexts,

"MeToo"- DANNY GRAY SI-22-000039


PARTS UNKNOWN -UC DAVIS
and that the way I was handling myself around my students was
perfectly acceptable. My calling the student a "bad girl", which I fully
admitted saying, was done in reference to her having knocked off a
magnetic name plate on my office door with her backpack, the first time
she came to my office. It never occurred to me that calling someone a
"bad girl" in this context could be perceived as a sexual type of
comment. After this unfortunate incident was brought to my attention, I
realized that after all these years I am still learning to adapt to US
customs. I obviously need to be a lot more careful and considerate, and I
must make sure to prevent anything like this from ever happening again.
I always ask my students to come and talk to me if anything needs to be
discussed. I am obviously not a counselor, and I never intended to be
one. In fact many times I have referred my students to counseling and
I've spent hours on the phone with our counselors explaining what the
situation might be with a certain student. This student and I never
exchanged text messages or called one another. All of our
communications were done through email and I volunteered to provide
to the university's investigator, and did provide, all of our email
correspondence, in an attempt to be as open and transparent as possible. I
know I am not perfect and that if I ever say or do anything that is
perceived as hurtful or offensive, I like to be able to address that and
make things better. I need to be able to learn from my own mistakes. I
want to be perceived as approachable and easy going. And I want
students to know that if we understand each other better, we will be able
to serve the music in front of us much more powerfully.
The system must absolutely protect and support individuals from
harassment and assault. We must offer everyone a safe learning
environment. But the system must also promote a healthy and balanced
scenario in order to allow our professors to express themselves freely
and provide a rich cultural network of support to their students.
Christian Baldini (December 2017)
I don’t know whether Professor Baldini is a Non-Senate or Senate Academic
Appointee. However, General University Policy APM-150 provides for Non-
Senate Academic Appointees as follow:

• For non-Senate academic appointees who are subject to peer review for
performance evaluation, demotion and dismissal for unsatisfactory work
performance shall involve the regular peer review process. Such a peer review
shall be advisory to the administrator authorized to institute the demotion or
dismissal action.

"MeToo"- DANNY GRAY SI-22-000040


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TYPES OF CORRECTIVE ACTION AND DISMISSAL
• Corrective action is a written warning, written censure, suspension without pay,
reduction in salary, or demotion for good cause, including but not limited to
misconduct, unsatisfactory work performance, derelicti on of duty, or violation of
University policy.
• Written warning is a communication that informs the appointee of the nature of
the misconduct or deficiency, the method of correction, and the probable
consequence of continued misconduct or deficiency. A written warning is to be
distinguished from an informal spoken warning. An informal spoken warning or a
letter outlining performance expectations is not an official corrective action.

• A written censure is a formal written expression of institutional rebuke which


contains a description of the censured conduct. A written censure must be
delivered to the recipient and a copy must be maintained in a designated file or
files,

INVESTIGATORY LEAVE

• An appointee may be placed on immediate investigatory leave with pay, without


prior written notice, for the purpose of reviewing or investigating conduct which
in the judgment of the Chancellor requires removing the appointee from
University premises. While on such leave, the appointee's return to University
premises without written permission may create independent grounds for
dismissal. Such investigatory leave must be documented in writing after it is
instituted.

WRITTEN NOTICE OF INTENT

• The University shall provide a written NOTICE OF INTENT to the appointee


prior to initiating the actions of written censure, suspension without pay, reduction
in salary, demotion, or dismissal. The Notice shall state:
the intended action, including reasons for the action and the proposed effective
date; (b) the basis of the charges, including copies of pertinent materials
supporting the charges; (c) THE APPOINTEE'S RIGHT TO RESPOND
EITHER ORALLY OR IN WRITING WITHIN FOURTEEN (14) calendar
days of the date of issuance of the written Notice of Intent; and (d) the name of the

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PARTS UNKNOWN -UC DAVIS
person to whom the appointee should respond. No Notice of Intent is required for
a written warning.

I will refrain from elaborating further concerning how grossly UC policies and Professor
Baldini’s employee rights were violated by the witch hunt and ill-minded ultimatum
delivered to humiliate and devastate Professor Baldini. However, I am curious about the
following:
Who made the decision to transfer Gray from UCLA back to UC Davis and provide him
with the Director of Academic Employment and Labor Relations position? UC Davis was
where he was allegedly sexually assaulted on several occasions by Professor Holoman.
The victimization of Professor Baldini and his family appears to be part of Gray’s
unresolved trauma concerning his very controversial relationship with Professor
Holoman. Perhaps Gray is merely pursuing a vendetta against Professor Baldini in lieu of
Professor Holoman—utilizing two notorious UC Davis witch hunters, Nichols and
Delmendo, as well as the new UC Davis chancellor. Chancellor May, you likely don’t yet
have any clue how the UC mafia is connected. However, given the fact that you replaced
Chancellor Katehi—who was hunted down by Napolitano at a cost of $1,000,000, all
because Napolitano did not like Katehi’s Greek accent—you should know better.
Before he was allowed to publish a “MeToo” story detailing his “Holoman obsession” or
to hunt down others, Gray should have been asked to explain why he was sued in state
and federal courts in 2003–2010. Gray faced allegations that he was covering up serious
sexual harassment and writing phony HR reports when he was employed in UC Davis as
an HR consultant and analyst in 2001–2003.
I am reviewing lawsuits against the UC Regents from the Los Angeles County courts
because Gray was employed in the UCLA HR Department from 2003–2014. He most
likely investigated sexual harassment and discrimination cases during these 11 years of
employment with UCLA.
Because Gray (like Delmendo) is an inactive attorney registered by the State Bar, he was
possibly a Title IX officer in UCLA.
The allegations against Professor Baldini are nothing compared to the crimes committed
by the UC Davis bandits. Gray is very familiar with such crimes because he was listed as
a defendant in lawsuits that alleged discrimination and despicable sexual harassment.
Chancellor May, before you take further adverse action against Professor Baldini (who is
being victimized by witch hunters out to completely destroy his family, livelihood, and
career), you should ask Gray about the October 15, 2013, “Independent Investigative
Report on Acts of Bias and Discrimination Involving Faculty at the University of
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California, Los Angeles” and whether Gray investigated sexual harassment and
discrimination cases on the UCLA campus.
Investigation and Report by: Hon. Carlos Moreno (Ret.), Chair

https://www.ucop.edu/moreno-report/external-review-team-report-10-15-13.pdf
https://www.ucop.edu/moreno-report/

• In recent years several incidents of racial bias and/or discrimination have occurred
on the UCLA campus and garnered public attention. Subsequent university press
releases regarding the incidents, as well as statements by UCLA Chancellor Block,
also received attention.
• The incidents and the subsequent statements by UCLA officials caused
consternation among certain faculty members of color at the university. On June
15, 2012, roughly thirty such concerned faculty members sent Executive Vice
Chancellor Waugh a letter in which they requested a review of the campus racial
climate as well as the appointment of an independent review committee to address
the university’s policies and procedures for responding to incidents of racial bias
on campus.

Recently, former Supreme Court Justice Carlos Moreno was called to rescue the UC
underground organization from and downplay allegations of tampering with the State
Audit. Allegedly, Napolitano’s gestapo covered up the $175,000,000 stashed for transfers
to her Swiss bank account. I can’t think of any other explanation for why she stashed and
hid $175,000,000 from auditors.
http://regents.universityofcalifornia.edu/regmeet/nov17/b2attach3.pdf

Cruz Reynoso (Chair, Professor Emeritus, School of Law, UC Davis; Former Associate
Justice, California Supreme Court) is another rescuer for the UC mafia. Reynoso
authored “Justice to the Rescue,” “UC Davis November 18, 2011 Pepper Spray Incident
Task Force Report,” and “The Reynoso Task Force Report” to cover up the outrageous
November 18, 2011, pepper spray attack on protesting students. This assault was
orchestrated by former UC Davis Chancellor Vanderhoef’s mafioso; UC Davis Campus
Counsel Steven Drown removed and replaced UCD Chief of Police Anne Spicuzza,
Capitan Joyce Souza, and Lt. John Pike. In October 2011, I reported to these officials

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and reported child pornography activities in the UCDMC. My allegation was covered up
by Nichols, Delmendo, and Stephen Chilcott. I also brought to their attention the suicide
of UCDMC worker Todd Georlich; however, they had apparently been prohibited from
investigating. November 18, 2011, was the first unsuccessful attempt by Charles
Robinson and Steven Drown’s mob to discredit Chancellor Katehi. Watch your back,
Chancellor May, and read the reports about the UCOP Department of Discrimination and
Exclusion because—just like your predecessor—you could very quickly become a target
of the UCOP gestapo’s hunting games.
I am not sure why former Justice Reynoso or Justice Moreno are lending their names and
prestige to the UC mafia. I also don’t know why Reynoso would associate with notorious
UC mafia servant attorney George Acero.
http://www.crbasacramento.com/

Conclusion of this Chapter

Nichols is a classic example of a university witch hunter who intentionally engaged in


conspiracy against UC Davis employees including Professor Baldini. She and many
others have committed malicious acts of reprisal, retaliation, threats, and coercion. They
also directed, recommended, processed, and approved personnel actions including but not
limited to promotions, transfers, assignments, performance evaluations, suspensions, and
other disciplinary actions. One such action was my termination of employment and the
use of official authorities to influence other employees for the purpose of intimidating,
threatening, coercing, or commanding. This was perpetrated to interfere with my right to
disclose UC officials’ serious violations of law and university policies.

An attorney who knows that another attorney has committed a violation of the Rules of
Professional Conduct in a way that raises substantial questions as to the latter attorney’s
honesty, trustworthiness, or fitness must inform the appropriate professional authorities.
Nichols failed to act against and actually collaborated with Delmendo, Chilcott, and other
“bandits” in order to inflict harm and ruin lives.

For the reasons that I have provided, I am again respectfully appealing to you, Chancellor
May, to disregard Nichols’s witch hunt report aimed at Professor Baldini and his family
and to let Professor Baldini return to his normal duties and normal life and pay back his
financial losses because of this beyond human decency witch hunt by mob I dealing with
for 11 years.

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Nichols’s criminal witch hunt report, which was crafted in conspiracy with Delmendo
and most likely Gray, is destroying Professor Baldini, his family, and other innocent
parties. Because they covered up and condoned child pornography activities on university
premises, Nichols, Delmendo, and any who aided or actually participated in such
despicable and illegal activities should be prohibited from conducting any investigations
involving allegations of sexual misconduct or harassment. Their university computers
should be inspected and checked for possession of visual depictions of minors in sexually
explicit conduct.

Another possible reason that the UCOP bandits brought Gray’s “MeToo” story to light
and ordered UC Davis witch hunters to frame Professor Baldini is the wrongful
termination, discrimination, and sexual harassment lawsuit Un Nam Hui v. The Regents
of the University of California (Case No. 34201300138396CUWTGDS), which has been
pending in the Sacramento County Superior Court since January 14, 2013.
Un Hui Nam recently prevailed in this case on the appeal in the anti-SLAPP motion filed
by the notorious George Acero in 3DCA on September 25, 2013. In August 2005, Acero
and fellow Porter Scott law firm attorney Michael Pott filed a fraudulent anti-SLAPP
motion against UC Davis employee Randy Vergos, who was harassed by sexual predator
Allen Tollefson.
Attacking and publicly punishing Baldini and Holoman for alleged sexual harassment
and misconduct at almost the same time is far too convenient. Hopefully, court judges are
not stupid enough to buy such a hoax. Nichols was working with Delmendo, the
UCDMC, the UC Davis Chief Compliance Officer, and the Title IX Officer when a
young persecuted and sexually harassed doctor was crying for help. What did that doctor
get from Nichols, Delmendo, Chilcott, and Cindi Oropeza? More discrimination and
sexual harassment. Trust me, Chancellor: these folks are ruthless criminals.
Read the Court of Appeal, Third Appellate, certified and published opinion in Un Hui
Nam’s case. The original complaint lodged in the Sacramento County Superior Court is
accessible online. (Opinion from appellate court enclosed )

In conclusion, I am enclosing most recent small part of my personal “MeToo” story.A


few days ago, the California Supreme Court sent me their decision concerning my former
attorney Douglas Stein, who I hired to represent me in my wrongful termination lawsuit
against the UC Davis bandits. At the time, I did not know that Stein was in love with UC
Davis’s legal counsel Michael Pott from Porter Scott and Judge of Sacramento County

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Superior Court Hon. David Brown. Together, they colluded with $ 300, 000 on the table
to ignore my wrongful termination case.
STEIN ON DISCIPLINE
Case Number S245982

• The court orders that Douglas Edward Stein, State Bar Number 131248, is
suspended from the practice of law in California for two years, execution of that
period of suspension is stayed, and he is placed on probation for three years
subject to the following conditions: 1. Douglas Edward Stein is suspended from
the practice of law for a minimum of the first year of probation, and he will remain
suspended until the following conditions are satisfied: i. He makes restitution to
Jaroslaw Waszczuk in the amount of $14, 694.33 plus 10 percent interest per
year from June 2, 2014 (or reimburses the Client Security Fund, to the extent of
any payment from the Fund to Jaroslaw Waszczuk, in accordance with Business
and Professions Code section 6140.5) and furnishes satisfactory proof to the State
Bar's Office of Probation in Los Angeles; and ii. If he remains suspended for two
years or more as a result of not satisfying the preceding condition, he must also
provide proof to the State Bar Court of his rehabilitation, fitness to practice and
present learning and ability in the general law before his suspension will be
terminated. (Rules Proc. of State Bar, tit. IV, Stds. for Atty. Sanctions for Prof.
Misconduct, std. 1.2(c)(1).) 2. Douglas Edward Stein must also comply with the
other conditions of probation recommended by the Hearing Department of the
State Bar Court in its Order Approving Stipulation filed on October 24, 2017. 3.
At the expiration of the period of probation, if Douglas Edward Stein has complied
with all conditions of probation, the period of stayed suspension will be satisfied
and that suspension will be terminated. Douglas Edward Stein must also take and
pass the Multistate Professional Responsibility Examination during the period of
his suspension and provide satisfactory proof of such passage to the State Bar's
Office of Probation in Los Angeles within the same period. Failure to do so may
result in suspension. (Cal. Rules of Court, rule 9.10(b).) Douglas Edward Stein
must also comply with California Rules of Court, rule 9.20, and perform the acts
specified in subdivisions (a) and (c) of that rule within 30 and 40 calendar days,
respectively, after the effective date of this order. Failure to do so may result in
disbarment or suspension. Costs are awarded to the State Bar in accordance with
Business and Professions Code section 6086.10 and are enforceable both as
provided in Business and Professions Code section 6140.7 and as a money
judgment. One-third of the costs must be paid with his membership fees for each of the

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years 2019, 2020, and 2021. If Douglas Edward Stein fails to pay any installment as
described above, or as may be modified by the State Bar Court, the remaining
balance is due and payable immediately.

Best Regards,

Jaroslaw Waszczuk
2216 Katazakian Way
Lodi, CA 95242
Phone : 209-663-2977
e-mail: jjw1980@live.com

The next thirteen chapters of “Danny Gray’s ‘MeToo’: Parts Unknown” will be
completed and sent out within a few days.

Program Director
DANESHA and NICHOLS – SBN #2227784 „MeToo” – PARTS UNKNOWN
NICOLE
Sexual Harassment Officer
University of California, Davis
207 Third Street # 210
Davis, CA 95616
Tel. (530) 747-3864
Email: dnnichols@ucdavis.edu

1. General Information

Danesha Nichols, JD, graduated from the University of Pacific McGeorge School of Law
around 2002 and was admitted to the State Bar of California on December 3, 2002. She
was hired by UC Davis in September 2004 as Human Resources Principal Labor Relation
Consultant with a $53,000 annual salary, which was relatively low. She held this position
in the UC Davis campus HR Department. In 2008, Nichols was handling SBN #2015169,
an arbitration, together with her colleague UC Davis HR Assistant Dawn M. Capp, JD.
Nichols was representing the university in relation to my complaint against the university
administrators who organized a despicable manhunt against me and my coworker
William Buckans in 2005–2008.

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Just after the university was defeated in the arbitration, Dawn Capp, who was the leading
HR attorney in the arbitration, disappeared from the university landscape. DANESHA
NICHOLS survived the defeat and held her HR Principal Labor Relation Consultant
position at the UC Davis campus until October 2010.
In October 2010 DANESHA NICHOLS was deployed as a Investigator Coordinator in
the UC Davis Medical Center HR department, reporting to the UC Davis Health
Executive Director STEPHEN CHILCOTT, JD, SBN# 196905, who was leading and
coordinating the witch hunt against me in 2006–2008 with enormous authority and power
given to him by the UC Regents and the UC Office of General Counsel to eliminate me
from the UC payroll.
The HR Investigator Coordinator position in the University of California System is
a short-term position and may be defined in simple words as a “leader of a
coordinated hunt attack with other hunters from various departments against a
complaining employee until that employee is demoted, silenced or fired”—
something similar to the leader of pack of wolves or dingoes attacking their prey.
The attack of the witch hunters led by the Investigator Coordinator is being overseen by
UC campuses’ Chief Compliance officers like Ms. Delmendo who need another
Compliance officer to obey laws an UC policies and procedures , locally designated
officers who could be HR Directors, Vice Chancellors or Vice Presidents.
The Chief of Compliance officer is a university title that has nothing to do with
compliance with anything but rather is a smoke screen position meant to give a false
impression to employees who are complaining about corruption, management
misconduct, waste of university resources, harassment or retaliation that the employee
will be protected from retaliation.
Government Code Section 8547.10 (b) &(c) states that: b) Any person who
intentionally engages in acts of reprisal, retaliation, threats, coercion, or similar acts
against a University of California employee, including an officer or faculty member,
or applicant for employment for having made a protected disclosure, is subject to a
fine not to exceed ten thousand dollars ($10,000) and imprisonment in the county
jail for up to a period of one year. Any university employee, including an officer or
faculty member, who intentionally engages in that conduct shall also be subject to
discipline by the university.
(c) In addition to all other penalties provided by law, any person who intentionally
engages in acts of reprisal, retaliation, threats, coercion, or similar acts against a
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university employee, including an officer or faculty member, or applicant for
employment for having made a protected disclosure shall be liable in an action for
damages brought against him or her by the injured party. Punitive damages may be
awarded by the court where the acts of the offending party are proven to be
malicious.

This statute looks and sounds great. However, if anybody takes into consideration the 18
month time limit that university “witch hunters”—who call themselves investigation
coordinators, chief compliance officers, locally designated officers, principal
investigators, managers, or supervisors, etc.—have to conduct and finish their witch hunt,
employees who complain and who are then hunted down like animals have no chance to
survive the psychological terror, provocations, physical confrontation, discrimination,
bullying, attacks by coworkers, coercion, or preferential treatment on the part of vicious
and unscrupulous managers and supervisors etc.

The best example of this is my own retaliation complaints and the case of other UC Davis
Medical Center employees who I have represented and helped to defend themselves
against members of the university management who are vindictive beyond imagination
and are assigned witch hunters such as DANESHA NICHOLS or STEPHEN
CHILCOTT.

Furthermore, certified opinion for publication known as Vergos v. McNeal, 53


Cal.Rptr.3d 647, 146 Cal.App.4th 1387 (Cal.App. Dist.3 01/23/2007. the July 31, 2008
Supreme Court of California decision in the case Les G. Miklosy et al. v. The Regents Of
The University Of California Et Al, No. S139133, emboldened the University of
California witch hunters to the point that witch-hunting on the university campuses
became a kind of sport or safari, in which they had university campuses directors,
managers, and assigned witch hunters with titles such as chief of compliance officer and
investigation coordinator, such as DANESHA NICHOLS and others like WENDI
DELMENDO , hunt down employees.

2. Danesha N. Nichol’s Professional Misconduct

• To the best of my knowledge, Danesha N. Nichols J.D., has, since 2008, violated
the California State Bar Rules of Professional Conduct, knowingly assisted or
induced another to do so, or has done so through the acts of another.
• Since 2008, Danesha Nichols, in conspiracy with others, committed unlawful acts

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that reflect adversely on her honesty, trustworthiness, and fitness as employee of
public entity.
Since 2008, DANESHA NICHOLS, in conspiracy with STEPHEN CHILCOTT,
STEVEN DROWN, University of California General Counsel CHARLES
ROBINSON, and others engaged in misconduct involving dishonesty, the cover
up of fraud, deceit, and misrepresentation of her position as a UC Davis HR
attorney with the title of Principal Consultant and Investigation Coordinator and as
an attorney licensed by the State Bar of California.
• In the period from July 2011 to May 2012, DANESHA NICHOLS, as the UC
Davis Medical Center HR Investigation Coordinator, with full knowledge of her
wrongdoing and as a skilled attorney licensed by the State Bar of California, in
conspiracy with the Regents of the University of California and other University
of California attorneys, including but not limited to UC Davis Health System
Chief Counsel , ANNA ORLOWSKI, UC Davis Health System Executive
Director STEPHEN CHILCOTT, and other high-ranking UC Davis administrators
and managers, orchestrated and carried out despicable, indecent attacks against
myself and other university employees to cover up the enormous, multimillion-
dollar fraud against the Internal Revenue Service and the State of California
Franchise Tax Board, which was committed by the university administration
relative to the unlawful operation of a 27 MW cogeneration power plant and
illegal power sales.
• Danesha Nichols, as UC Davis HR employee and an attorney at law licensed by
the State Bar of California, by her blunt disregard and violation of state and
federal laws and of University of California policies and procedures, which are
equal to state statutes, by conspiring with other attorneys employed by the
university and with university administrators, violated my and other employee
civil and human rights by her despicable disregard for civilized society, laws,
and principles.

3. Statement of Facts

In 2008, DANESHA NICHOLS was involved in the arbitration process in relation to my


complaint against the vicious witch hunt carried out against me, which was ordered in
2006 by the university administration and was coordinated and carried out by STEPHEN

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CHILCOTT and STEVEN DROWN in conspiracy with other UC Davis Medical
Center directors and managers.

In October 2010, DANESHA NICHOLS was deployed from the UC Davis Campus to
the UC Davis Medical Center (UCDMC) lead the witch hunt against me and prepare the
false cause for my employment termination under the guidance of UC Davis Chief
Compliance Officer WENDI DELMENDO , UCDMC HR Executive Director STEPHEN
CHILCOTT, UC Davis Campus Counsel Steven Drown and coordination with CINDY
OROPEZA Inhuman Resources Department Manager for Affirmative Action/EEOC
Real Title: Manager Benefits, EEO, Resident/Fellow Program HR Administrator, Title
IX Officer — Sexual Harassment, Mediation Services, ASAP, No
Resolution/Exclusion in UC Davis Health System

I believe, that DANESHA NICHOLS’ deployment to UCDMC in October 2010 to


deliver final solution with my UC employment was done in emergency manner to
monitor the volatile situation relative to the blackmail petition for a pay rise that was
submitted to the UCDMC management by four individuals from the UC Davis Medical
Center 27 MW cogeneration facility to the Department Head CHARLES WITCHER . .
The mentioned petition was related to my earned wages in 2009 and indirectly to the
February 2009 settlement-agreement I signed with the regents which was trashed by the
UCOP bandits in 2011 with an attempt to end my employment in UCDMC Trauma Unit
# 11 or UCDMC Morgue on May 31, 2011.

DANESHA NICHOLS was already familiar with my 2006-2009 case, and she was ready
for me if I reacted to the blackmail petition. The blackmail petition was more than just a
petition.

In July 2011, I came under direct attack from Danesha Nichols, not knowing why she
was attacking me. I had never met her before, and she was very belligerent, calling my
office and giving me orders to meet with her, knowing that she was not my supervisor
and had to go through the proper channels with my managers in order to schedule a
meeting.

I documented her attacks in 79 pages of correspondence, which perfectly describe the


coordinated terror and intimidation attacks aimed at me between the period of May 1,
2011 and July 31, 2011.

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The 79 pages of correspondence, shows that DANESHA NICHOLS was a leader of a
pack of wolves or dingoes who attack and kill their pray.
The 79 pages of correspondence included the July 22, 2011 complaint letter sent to UC
Campus Counsel Steven Drown on the subject of DANESHA NICHOLS and as a
reminder to STEVEN DROWN that he signed, in February 2009, the Settlement-
Agreement on behalf of the Regents of the University of California. Steven Drown
responded on July 26, 2011. Neither STEVEN DROWN, DANESHA NICHOLS,
STEVEN CHILCOTT, UCDMC managers and directors, nor UC Davis Chief
“Compliance” Officer WENDY DELEMENDo—who guided DANESHA NICHOLS
and checked her compliance with the guidance to attack me and fire me from the job—
wanted to hear about WASZCZUK’S SETTLEMENT-AGREEMENT with the UC
Regents.
Since my open-heart surgery in 2006, I have been surviving on nine medications every
day; being terrorized did not help me to do my duty to keep the Hospital’s patients safe. I
was monitoring critical alarms. DANESHA NICHOLS and other bandits did not care
about UCDMC patients safety. Their goal was to erase me surface of the earth.
On August 3, 2011, due to the terror and stress I was experiencing, my physician placed
me for one month on stress-related sick-leave, and that was my last day I ever worked. I
was not permitted to come back to work after my work-related sick-leave, and I was
placed on endless investigatory leave by STEPHEN CHILCOTT’S orders.
On August 31, 2011, the “pack of wolves,” led by DANESHA NICHOLS, WENDI
DELMENDO, STEPHEN CHILCOTT, and other directors and managers, started their
hunting game again in preparation to terminate my employment, which was scheduled for
September 23, 2011 and was based on DANESHA NICHOLS fabricated false cause for
termination . I learned later from the UC Davis Public Record Act office that Danesha
Nichols’ witch hunt cause for my termination was destroyed and is not available.
On September 4, 2011, sick and tired of DANESHA NICHOLS’ attacks just after my
stress-related sick-leave, I sent an e-mail to Nichols with attached all my performance
reviews (evaluations) attached, which I had received in the course of my employment at
the UC Davis Medical Center from June 1999 to my last evaluation period in 2009/2010.
I thought that maybe my evaluations might make her think twice before launching into
another belligerent attack ordered by her superiors.
I did not ever receive my evaluation for the 2010/2011 evaluation period. The evaluation
was due in June 2011, July being the latest time for employees to be evaluated according
to UC policy.
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The September 2011 atmosphere has been well described in the various 71-page
correspondence with DANESHA NICHOLS and others
In the bulk of correspondence was a letter dated September 6, 2011, which I sent by e-
mail, together with several photos from the hospital showing me after I had undergone
open-heart surgery. I thought it would prevent DANESHA NICHOLS and others from
terrorizing me further. However, it did not work.
The attempt to terminate me on September 23, 2011 was prematurely disclosed and my
physician placed me again on stress-related sick-leave.
On October 4, 2011, I filed a complaint with the State Bar of California against Executive
Director of Human Resources Department in UC Davis Medical Center Stephen Edward
Chillcott, Bar # 196905 and Danesha Nicole Nichols, Witch Hunter in the Human Resources
Department and subordinate of Chillcott, who coordinated the witch hunt between Danesha
Nichols , Wendi Delmndo , Steven Drown and UCOP Gestapo , The Chilcott’s unethical
behavior, conspiracy and gross misconduct requires 10 more paged of paper to describe it.

Due to constant unfounded accusations by Danesha Nichols, Chillcot and Charles


Witcher, and other bandits , I thought that maybe someone had filed the false complaint
with the UC Davis Police Department and accused me of violence and discrimination and
other crimes Plaintiff did not commit. To clear this issue, on October 6, 2011 I asked UC
Davis Police Cpt. Joyce Souza from the Professional Standard Unit to search my Police Record
and check if any record with my name was there.

In in his eight-page e-mail entitled “Request for Information in regards to the unfounded
accusation against me from UCDMC HR Attorneys and other individuals,” I pasted
multiple examples of the despicable, unfounded, and defacing Plaintiff accusations. .
In his e-mail to UC Davis Police Cpt. Joy Souza with cc. to UC Davis Police Lt. John Pike (the
same Lt. John Pike who was pepper spraying protesting students on November 18, 2011 on the
UC Davis Campus).

I wrote to Cpt. Joyce Souza on October 5, 2011 in his eight pages e-mail letter:

• “Dear Captain Souza:


I have been working for 12 years in the UC Davis Medical Central Plant
Operation and Maintenance, Sacramento Department. In last few months I have
been constantly accused by the UCDMC HR Attorney Danesha Nichols and
PO&M Department Manager Charles Witcher of being violent, making
discriminatory comments, etc. without any factual evidence in my employment
record, like evaluation or written or verbal warning.

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I would appreciate it if you would let me know if any complaint has been filed by
anyone against me with the UC Davis Police Department (UC Campus or UC
Medical Center) for the abovementioned fabricated accusations and allegations for
the period from
March 1, 2011 to the present time.
If so, then I would be glad to hear from the UC Davis Police Department that the
allegations against me are being investigated, and I will be glad to answer any
question related to the complaint. I would be glad to talk with the UC Police
Investigation Unit/Detectives instead of crooked HR Attorneys from UCDMC.”

On October 6, 2011, Captain Joyce Souza from the UC Davis Police Department
responded to Plaintiff’s inquiries dated October 5, 2011, in regard to despicable
and unfounded accusations fabricated by the Defendant against Plaintiff. Captain
Joyce Souza, in her response, wrot e:

Dear Mr. Waszczuk,


I have performed a check of our records system and there is nothing noting your name.
Please let me know if you need any further assistance.
Captain Joyce A. Souza
UC Davis Police Department
I noticed that Captain Joyce Souza cc’d her e-mail response to her superior, UC Davis
Police Chief Annette Spicuzza, and UC Davis Chief Compliance Officer Wendy
Delmendo, who assigned, in July 2011, UC Davis attorney Danesha Nichols to conduct a
pseudo-investigation against me to fabricate a cause for my termination of employment
on September 23, 2011, which did not happen.

On December 22, 2011, I met DANESHA NICHOLS but later regretted the meeting
with her. I did not know or suspect why the ongoing witch hunt was taking place and why
they had employed such enormous manpower to destroy one employee. On that day, I
drove to UC Davis Medical Center to pick up my private things from my office after I
had been removed by Stephen Chilcott’s or the Chancellor’s orders following my stress-
related sick-leave. Despite my doctor not giving his permission, on December 5, 2012,
my health insurance was canceled, my title was changed to Program I, which I did not
know the meaning of, and my disability claim was denied. I thought that I would be
terminated within days.

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After the meeting with Danesha Nichols, I was not permitted to come back to work and I
was placed back on investigatory leave, which became the permanent solution to keeping
me out of the premises until my employment was terminated in December 2012.

I did not know in December 2011 that the regents had negotiated a new fraudulent power
sale contract with Sacramento Municipal Utility District for the UCDMC 27 MW
cogeneration power plant, where I had been employed as an operator between June 1999
and March 2007.

I was not welcome to comeback due to the illegal power generation and sale fraud , and I
was persona non grata even though I was not concerned during the course of my
employment with the university about the regents’ power generation and their contracts
with CAISO and SMUD .

On April 13, 2012, I received a Letter of Intent to Suspend for 10 days based on out blue
despicable allegations witch crafted by Danesha’s Nichols’ , Stephen Chilcott’s and
Wendy Delmendo . I was furious, but at the same time, I was surprised that I had
received a suspension rather than a termination letter after eight months of absence from
work due to three months of stress-related sick-leave and five months of phony
investigatory leave.

Through a Public Record Act request, I received four investigation reports that
DANESHA NICHOLS had fabricated for the period of March 2011 to February 2012.
DANESHA NICHOLS, through her superior writing skill, made me looks worse in
her witch crafted reports than a twice-convicted child pornography felon, who was
illegally accessing the UCDMC HVAC shop computer to surf the Web despite being
on probation and being prohibited from touching any computer by a court order
Case: 2: 6 –cr- 00418-LKK, The United States of America v. Sean Christopher Robideaux,
United States District Court, Eastern District of California, Indictment Violation(S) 18
U.S.C § 2252 () (4)(B) – Possession of Visual Depiction of Minors in Sexually Explicit
Conduct). (Court Order Enclosed )
The child porn activities in the HVAC shop were reported in July 2011 by my
coworker. Danesha Nichols, as the investigation coordinator and a skilled attorney
of law, instead of reporting this sick individual to the authorities and obtaining a
restarting order, covered up the activities in her report, and my coworker Kenny
Ded who reported the child porn activities activities, was attacked by his
supervisors and DANESHA NICHOLS and was forced to quit two years later.

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The child porn twice convicted felon motto “Silence or I Kill You” displayed on the
social media Facebook convinced a ill and criminally minded DANSHA NICHOLS .
WENDI DELMENDO and STEPHEN CHILCOTT who are apparently loves child
pornography that child porn twice convicted felon should have better and more
secluded place to surf child porn in UCDMC HVAC shop . As I learned Chilcott gave
my job and my office to Sean Rubidoux’s father William Robidoux who had access to
the HVAC shop 24 hours a day and could bring his sick minded son even at night to
please his desire for child pornography.

The DANESHA NICHOLS witch crafted reports were not only basis for my suspension
but were witch crafted to harm me psychologically and financially, to outrage and
provoke and to eliminate me by UCDPD Lt, James Barbour Glock on May 31, 2012.
The Reports were part of a planned preparation and ill-minded provocation by the
UCDMC HR psychologists and UC Davis new Chief of Police Matt Carmichael. The
provocation was most likely ordered by the General Counsel CHARLES ROBINSON
with recommendation and feedback from Stephen Chilcott and HR psychologists. The ill-
minded plan was quite simple. Suspending an employee without pay and after 8 month of
absence instead of let him comeback to work lure him to premises and serve him
another investigatory leave with a new fabricated accusation which could make the
employee so fed up, he would quit the job, or he would become very angry and hostile by
letting him know that he would be prohibited from coming back to work and that a new
witch hunt is under way.

On May 31, 2012, I was lured onto the premises by written order in the Letter of
Suspension. The UC Police Department Lt James Barbour who was bribed with a
$35,000 raise was waiting for me to make sure that I would be delivered to the UC Davis
Medical Center Trauma Unit # 11. A Trauma Unit supervisor was waiting to receive me
if I was still breathing, or if not, I would most likely be sent to the UC Davis Medical
Center Morgue.

The provocation did not work. On May 31, 2012, a new witch hunt notice entitled
“Investigatory Leave “ was handed to me and I was not permitted to return to work. I
calmly walked away from the provocation, and the Manager of the HR Workers
Compensation Department Hugh Parker, who was assigned to coordinate the provocation
with all forces in standby, sent to the assembled team, which I called the UC Davis Death
Squad, a disappointing e-mail. I was not angry when I was served the new witch hunt

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notification, and I was redirected to the Human Resources building for questioning by the
assigned witch hunter Brent Seifert J.D.

At the beginning of the month of May 2012, the UC Davis Chief Compliance officer,
in collaboration with the UC Davis Health System Executive Director Stephen Chilcott,
attempted to assign DANESHA NICHOLS to continue her witch hunt against me.
DANESHA NICHOLS refused.
She put a lot of effort into fabricating four different witch hunt reports to get me fired and
she was not recognized for her effort, as STEPHEN CHILCOTT was in 2007, after I was
removed from the UCDMC Central Plant. The UC Davis Health System Executive
Director, instead of promoting DANESHA NICHOLS to fill the vacant HR Labor
Relation Manager position he hired in April 2012 a white Caucasian who did not have
previous HR witch hunt experience as DANESHA NICHOLS had. . DANESHA
NICHOLS already had 10 years’ experience in the HR as a witch hunter not to mention
the fact that she is a woman and an African-American and should be considered for
promotion according to discrimination and exclusion policy and guidance .
On December 1, 2014, in the filed Court Declaration in Support of the Special Motion to
Strike Defendant DANESHA NICHOLS under penalty of perjury, DANESHA
NICHOLS stated, “I did not harbor any unlawful motives or biases towards
Waszczuk during the course of my investigation, nor did I retaliate against him for
filing whistleblower complaints.”
I did not file or signed any whistle blowing complaint. Wendi Delmendo filed one
without my ok.
Danesha Nichol’s Declaration is total perjury under the law of the state of California
under Penal Code section 118(a), which states, “Every person who, having taken an
oath that he or she will testify, declare, depose, or certify truly before any competent
tribunal, officer, or person, in any of the cases in which the oath may by law of the
State of California be administered, willfully and contrary to the oath, states as true
any material matter which he or she knows to be false, and every person who
testifies, declares, deposes, or certifies under penalty of perjury in any of the cases in
which the testimony, declarations, depositions, or certification is permitted by law of
the State of California, under penalty of perjury and willfully states as true any
material matter which he or she knows to be false, is guilty of perjury.” Kulshrestha
v. First Union Commercial Corporation, 93 P.3d 386, 33 Cal.4th 601, 15 Cal.Rptr.3d
793 (Cal. 07/19/2004); Supra S115654; People v. Laws, 120 Cal. App. 3d 1022, 178 Cal.
Rptr. 102 (Cal.App.Dist.1 06/26/1981)

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Penal Code section 134 provides, “Every person guilty of preparing any false or
antedated book, paper, record, instrument in writing, or other matter or thing, with
intent to produce it, or allow it to be produced for any fraudulent or deceitful
purpose, as genuine or true, upon any trial, proceeding, or inquiry whatever,
authorized by law, is guilty of felony.” People v. Jensen, 94 Cal. App. 3d 451, 156 Cal.
Rptr. 447 (Cal.App.Dist.1 06/27/1979)
DANESHA NICHOLS was constantly retaliating against me and others harboring
unlawful motives to cover up university administrators’ crimes and fraud. Danesha
Nichols’ investigation reports are total fraud and were fabricated to inflict harm on me
and to violate my and others civil and human right
To be continue .

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