Motion For Reconsideration in The U.S. DISTRICT COURT Washington State

Case 2:21-cv-01276-RAJ Document 258 Filed 10/21/22 Page 1 of 20
Hon. District Judge Richard A. Jones

1
6
UNITED STATES DISTRICT COURT FOR THE
7
WESTERN DISTRICT OF WASHINGTON
8 AT SEATTLE
9
CAROLYN SIOUX GREEN, Case No. 2:21-CV-01276–RAJ
10
11 Plaintiff, PLAINTIFF CAROLYN SIOUX GREEN’S

MOTION FOR RECONSIDERATION
12 v.
ORAL ARGUMENT REQUESTED
13 UNITED STATES OF AMERICA, ET AL JURY DEMAND
14 Defendants.
15 Noting Date: October 21, 2022.
16
The Plaintiff CAROLYN SIOUX GREEN (“CSX”) respectfully moves this Court to grant
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the Motion for Reconsideration for the ruling of October 7, 2022. (Dkt. #253). Local Civil Rule 7(h).
18
19 (Dkt. #219) overlooked that the Drug violations against the United States are timely. Plaintiff is
20 requesting a change in the order of Dkt. #219 and to have my case reinstated. Justice requires this
21 matter be set for trial, and that the statute of limitations be equitably tolled for the older portions of
22
the record. Washington State restored her Right to Bear Arms November 1, 2019. Plaintiff also
23
requests that her firearm rights be restored in the remaining 49 states.
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Your honor, if I may, although not customary, please first review Dkt. #220-3: Carolyn’s
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Brain Health from a medical professional in November 2021. See DIGITAL DRUGS-1 Bench Copy
26
27 BINDER pp. 423-438, prior to reading the rest of this Motion for Reconsideration. Thank you.
28 PLAINTIFF CSX MOTIONS FOR RECONSIDERATION

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Plaintiff would like to address the Court regarding the Prayer for Relief Sought. The amount
1
2 stated is one-and-a-half-billion dollars. The point, Life is priceless. There is no monetary amount that
3 can replace the years wrongly taken from my life from my physical injury not being appropriately
4 treated, to then be maimed. Then discarded in an asylum. To then have to ask for a walking cane.
5
Life is a gift given by Our Creator. Solutions are listed in the Injunctive and Declaratory Relief, to
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include other means of compensation as the Court determines. Dkt. #30 pp. 196-234.
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Objection & in Opposition see Dkt. ## 186, 233-morphine and other drug related violations,
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#248. CSX Declaration #235 exceeded the page limit; therefore, it was replaced with a shorter
9
10 version #249 to comply with page limit. Defendant U.S. Attorney misinformed the Court in #247
11 about Plaintiff’s Objection dockets. Above is the correct application to the Objection of #219. The
12 other dockets refer in further support of the motion to joinder Doe-Providence #48, the catalyst.
13
14 I. THE COURT OVERLOOKED OR MISAPPREHENDED
15 1. Bad faith is defined as: “actual or constructive fraud, or a neglect or refusal to fulfill
16 some duty…by some interested or sinister motive.” Bentzen v. Demmons, 842 P.2d 1015, 349
17
n.8 (Wash. App. 1993), see also Spencer v. King County, 692 P.2d 874, 1 208 (Wash. App.
18
1984) (bad faith implies acting with tainted, fraudulent or ill will motives.
19
Gross negligence is defined as: “the failure to exercise slight care. It is negligence
20
21 that is substantially greater than ordinary negligence. Failure to exercise slight care does not
22 mean the total absence of care but care substantially less than ordinary care.” Washington
23 Pattern Instruction [WPI] 10.07. The Washington Supreme Court defines gross negligence as
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“gross or great negligence, that is, negligence substantially and appreciably greater than
25
ordinary negligence. Its correlative, failure to exercise slight care, means not the total
26
absence of care but care substantially or appreciably less than the quantum of care inherent in
27

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ordinary negligence.” Nist v. Tudor, 407 P.2d 798, 331 (Wash. 1965), see also Boyce v.
1
2 West, 862 P.2d 592, 665 (Wash. App. 1993) (gross negligence is “...negligent acts [that fall]
3 greatly below the standard established by law for the protection of others against
4 unreasonable risk of harm...”).
5
Gross negligence, and bad faith, are both shown then proven with substantial
6
evidence throughout the matter before the Court. Fraud, as well as timely drug violations.
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2. Formal complaints with perfected service are October 2018, not September 2022.
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(Dkt. #219 p. 2 @ 9). (See Hon. Judge Jones Drugs-1 Bench Copy Binder. DIGITAL
9
DRUGS-1 BINDER attached). Federal drug violations are listed in Dkt. # # 233, 69.
10 a) Dkt. #116: Proof of service mailing and correspondence for morphine violations.
11 b) Dkt. #117: Proof of service mailing; Dkt. #183 personal note re morphine.
12 c) Dkt. #200: NOTICE of Filing of Paper or Physical Material with the Clerk.
13 d) Dkt. #233: Morphine and other drug related violations are timely.
e) Dkt. #30 pp. 279-290, drug violations.
14
15
3. Drug Interactions
16 A. The Dept of Veterans is in violation of their Code of Conduct. Dkt. # # 209, 56.
17
Defendants have a duty as stated “You will receive to the extent that you are eligible,
18
prompt and appropriate treatment for physical or emotional disorders or disabilities in the
19
least restrictive environment necessary for that treatment free from unnecessary or
20
21 excessive medication (drugs).” emphasized.
22 B. Drug Interaction of Mr. Kenny Campbell Vietnam War Veteran: 10 major, 61 moderate
23 C. Drug Interactions of CSX 2003-2014: 7 major, 10 moderate

24
(1) 2006: shows the month of February that carried on for years: 6 major, 10 moderate
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(2) 2005-2014: 3 major; Morphine and Clonazepam and Methadone “Opiates in
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combination with benzodiazepines carries a 5x increase for adverse outcome
27

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including death,” and “may have opioid hyperallergic.” SIX-YEARS on morphine

1
2 and methadone simultaneously with a benzodiazepine.
3 (3) Drug Interactions by Dept of Veterans in 2001: 6 major, 16 moderate

4 2001: Western: 1 major, 5 moderate
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2001: Providence: 8 major, 17 moderate
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(4) According to JAMA Internal Medicine in 2016 the off-label drug uses account for
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more than 44% more adverse effects.
8
(5) Dkt. # 98 is seen in DRUG-1 BINDER pp. 15-23
9
10 (6) See Drug Transparency Dkt. # # 69, 70, 71, 72, 73, 74, 75
11 (7) Other Veteran Drug Interactions can be further accessed by logging into:
12 a) www.drugs.com
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b) Username: 984980
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c) Password: betterthinking984980
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d) After logging in to drugs.com, go to the top right corner that shows username
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17 “984980”. Then click on “My Interactions List”. There you will find my
18 mostly verified drug interactions as well as those of other Veterans.
19 4. See Hon. Judge Jones Drugs-1 Binder Bench Copy. DIGITAL DRUGS-1 BINDER
20 pp. 423-438 with Digital Drugs-1 Reference sheet at the end of this docket. I have never been
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to war. Now imagine dragging your broken butt through this system after you’ve been to war
22
and fought for this country. On a drug cocktail. And, most respectfully for the freedoms you
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personally enjoy. I believe you owe it to the WarFighter Veterans–America’s treasures in this
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25 county to reinstate this case matter, for their benefit. Plaintiff no longer considers herself a
26 Veterans due to the criminal mistreatment and neglect. Id. p. 437. (Dkt. #66 pp. 33-36).
27

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• View: https://www.youtube.com/watch?v=ErbUZtBgFdg
1
• View: https://www.facebook.com/watch/?extid=CL-UNK-UNK-UNK-
2
IOS_GK0T-GK1C&v=2706768036111954
3
• View: https://www.youtube.com/watch?v=J06uW6XlTOk
4
• https://www.imdb.com/title/tt7664948/
5 • View: https://www.usmedicine.com/current-issue/va-continues-
6 inconsistent-measurement-of-veteran-wait-times-for-care/
7 • View: https://www.youtube.com/watch?v=Qz0-
8 XzEq3x8&list=PLVC0WUxi0530sZYe8rvs-8fZwP0M-5xdG&index=1
• View: https://www.youtube.com/watch?v=dozpAshvtsA&t=326s
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• Additional testimonies can be provided.
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11
5. Pharmacy lacks meaningful accountability with many drugs missing on the formal
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pharma data record with the Dept of Veterans Puget Sound: Celebrex, Methacarbomol,
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Gabapentin, Lidoderm patches, Citalopram, Paxil. Numerous prescription refills not listed.
14
15 Drugs not recorded on the pharmacy dispensary record. A few examples,
16 a) 8 of 12 refills yet the initial 8 prescriptions of Methacarbomol are missing on the

pharma data record. Id. pp. 381, 403-405.
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b) 3 of 4 refills yet no record on pharma data record, 2015, for Feb. 22, 2015.
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Celebrex at the maximum dose, yet the pharma record is sparce. Id. p. 397-399.
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c) Gabapentin. I was on the maximum dose for nearly 10+ years. The pharma record
20 does not reflect this. The medical records show the scripts. Inaccurate and missing
prescriptions on pharma record. Id. pp. 400-401.
21
22 d) Artificial tears, eye drops. Id. p. 406. I have more eye drops accounted for in 2-
years than Dept of Veterans has in the entire 16 years prescribed and recorded,
23 with bottles to prove it. Lacks any meaningful pharma accountability.
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e) This is only a small portion noted in this document. This case matter has the
25 records and documentation showing lack of pharma accountability.
26
27

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6. Factual, not alleged as the Magistrate Judge stated. (Dkt. #219 p. 6 at 15) The
1
2 excessive drugs prescribed 1996-2017 with evidence provided to the Court.
3 My well-documented physical injury was masked and treated with drugs. I was
4 denied appropriate medical procedural care while active-duty. After being injured for 1 1/2
5
years, I was reprimanded for seeking to talk to a doctor after appointments hours about my
6
injury. (#57 flash drive). USCG Support Center Seattle prescribed me inappropriate drugs
7 Dkt. #124-1: pp. 50, 52, 99-103, 136, 174.csx
with no procedural care for my injury. Then on purpose honorably discharged me physically
8
injured without medical care. At my first unit, Station Chetco River, I was prevented in
9
10 writing from seeing the Civil Enlisted Advisor (CEA). This was during before and after
11 hostile abusive treatment. The CEA is considered a Civil Rights Officer in the Military. See
12 Dkt. # #54, 57 Binder in flash drive, DIGITAL DRUGS-1 Binder pp. 478-509 for CSX
13
references; located at the end of the physical binder of the same. (Id. p. 9 at lines 18-19).
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In 2022, I am now mostly recovered, my brain and body are still mending, from my
15
honorable active-duty service from 1991-1995. And, from 2001. Due to the intentional
16
17 prevention of adequate appropriate medical care while active duty, CSX is requesting a
18 similar recommendation regarding the Department of Defense (DoD) Commands authority
19 seen in 2022. In 2022, the DoD is moving ahead with recommendations to combat sexual
20 assault; Independent Review Commission on Sexual Assault in the Military.2 Namely due to
21
Miss Vanessa Gonzales murder where she was dismembered, in 2020.3, 4 This was after she
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reported sexual harassment problems to her Command. Remarkably, two-decades later the
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same behavior tolerances of abuse and criminal mistreatment continued. Commands should
24
25 not have the authority to prevent, prohibit, interfere, create obstacles, for physically injured
26 members on American soil. My case was entirely preventable.
27

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EXCESSIVE DRUGS PRESCRIBED TO MASK-TREAT MY PHYSICAL INJURY

1
WITH A “MILD” CASE OF POST TRAUMATIC STRESS; (Dkt. # # 56-1, 209, 54).
2
3 USCG
1994: Six (6) drugs, 1995: Ten (10) drugs.
4
5 DEPT OF VETERANS
1996: Four (4) drugs,
6 1997: Five (5) drugs,
7 1998: Six (6) drugs,
1999: Seven (7) drugs,
8 2000: Six (6) drugs,
2001: Twenty-one (21);
9 Plaintiff was chemically lobotomized by Defendant. This is illegal. (#56).
CSX was issued a walking cane I had to ask for. This was after being
10 kidnapped by Defendants who committed perjury then abused with chemical
11 restraints. (See Exhibits GREEN BINDER, Hon. Judge Jones Drugs-1 Binder
Bench Copy. DIGITAL DRUGS-1 BINDER).
12 “Injured her R buttock, hips, neck and back. Patient will be put on mood
stabilizers and antidepressants.” (June 12, 2001) Dept of Veterans.,
13 2002: Ten (10) drugs,
14 2003: Eleven (11) drugs;
“... last time I had a brisk walk around the (apartment) compound without the
15 sense that I am dragging my right leg–the first time since my injury”
(Injured Feb. 21, 1994) (January 8, 2003). (with emphasis).,
16 2004: Nine (9) drugs,
17 2005: Twelve (12) drugs, CHRONIC OPIOID THERAPY STARTED
2006: Eleven (11) drugs, CHRONIC OPIOID THERAPY
18 2007: Nine (9) drugs, CHRONIC OPIOID THERAPY
2008: Eight (8) drugs, CHRONIC OPIOID THERAPY
19 2009: Eight (8) drugs, CHRONIC OPIOID THERAPY
2010: Six (6) drugs, CHRONIC OPIOID THERAPY
20
2011: Six (6) drugs, CHRONIC OPIOID THERAPY
21 2012: Six (6) drugs, CHRONIC OPIOID THERAPY
2013: Seven (7) drugs, CHRONIC OPIOID THERAPY
22 2014: Nine (9) drugs, CHRONIC OPIOID THERAPY
2015: Seven (7) drugs, CHRONIC OPIOID THERAPY
23 2016: Eight (8) drugs, CHRONIC OPIOID THERAPY
2017: One (1) drug;
24
June 9, 2017, 13 YEARS OF CHRONIC OPIOID THERAPY ENDED due to
25 my self-discontinuance (Dkt. #69). Defendants refilled and dispensed
morphine repetitively after Plaintiff reported she discontinued this narcotic, a
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Schedule II Class Drug. (Dkt. ## 70, 71, 72, 73, 74, 98).
27

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7. Medical experts have testified, published articles in peer reviewed literature, and
1
2 produced sworn affidavits on the harmful effects of these drugs. Brain function is impaired.
3 Neuropathways are disrupted making them inoperative. These drugs create dysfunctions
4 affecting the frontal lobe, temporal lobe, parietal lobe, occipital lobe, cerebellum, brain stem,
5
as well as other functions. Dkt. #68 Medical Expert Affidavits, testimony: Dr. Peter C.
6
Gøtzsche, Dr. Grace E. Jackson, Dr. Robert Whitaker, Dr. Peter Breggin expert testimony.
7
See also Ann Blake-Tracy, Mad in America, Rob Wipond, Jim Gottstein. There are online
8
groups/pages assisting people damaged by these drugs. (Dkt. #66 pp. 6, 9-10, 13-17).
9
10 Medical experts refute Dkt. #219 p. 8-10+. The book, “The Body Keeps Score the
11 Score” by Bessel Van Der Kolk,, M.D. refutes. #219. The Diagnostic and Statistical Manual
12 (DSM) refutes #219.
13
8. When I asked Dept of Veterans, Dr. Anthony J. Mariano, an employee, a Director in
14
the Pain Clinic how care works. Dr. Mariano replied, “There is only so much care to dispense
15
to each veteran so we don’t run out of peanut butter; this way everyone gets a little
16
17 something”. I refer to his explanation as doses of care. Rations of care. I was informed by
18 Jeffery E. Swanberg, a Dept of Veterans Privacy Officer employee, that “The system is
19 designed to set you up for failure,” stated in 2017. (emphasized).

20 9. It took the Dept of Veterans 4.6 years plus 690 days from the initial injury while on
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active duty totaling 2370 days (6.49 years or 78 months) to start treatment of my severe
22 2002, csx
physical injury. April 10, 2022, “begin sacroiliac prolotherapy treatments for iliac upslip.”
23
85 appointments before my first doctor. Dkt. #209 p. 12. See also Dkt. #30 pp. 221-225,
24
25 pp. 348 at line 11 through p. 351 to line 9. For maiming see Dkt. #30 pp. 155 at line 13
26 through p. 158 to line 12, p. 164 at 21-22, p. 165, p. 221-225.
27

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Defendants delayed cervical spine treatment to 2017 Jan 04 from the first notation of 1992
1
2 July 22. The first procedure for my cervical spine (neck) took nearly 22 years. CSX neck,
3 “...showed severe facet degeneration at C2-3 and also facet changes at C3-4.” Id. p. 299 at
4 lines 6-13. (Dkt. # #56-1, 57 flash drive contents). The Pain Clinic was the worst with delays,
5
and with no notice of appointment cancellations.
6
10. Excessive prescribing of medications-drugs is gross negligence, medical malpractice,
7
and bad faith. To treat a physical injury with sedation and benzodiazepines and tranquilizers
8
and “mood stabilizers and antidepressants” and neuroleptics marketed as antipsychotic drugs,
9
10 and narcotics. (Dkt. #56: Notice of Paper/Physical Material: Original patient rights, #209).
11 a) Plaintiff without seeing a Primary Care Provider for seven (7) months was able to
refill liquid-Morphine repetitively. Dept of Veterans refilled and dispensed liquid-
12 morphine. Dkt. #36-1 p. 79 line 16-21, p. 107 at lines 1-17, in particular pp. 110–120.
13 Seen in Dkt. #30 as pp. 279–290.
14 b) “... last time I had a brisk walk around the (apartment) compound without the sense
that I am dragging my right leg–the first time since my injury” (Injured Feb. 21,
15 1994) (Jan. 8, 2003) Dept of Veterans.
16
c) “Injured her R buttock, hips, neck and back. Patient will be put on mood stabilizers
17 and antidepressants.” (June 12, 2001) Dept of Veterans.
18
d) June 28, 2000 Dkt. #84, just as recorded in the court records in Dkt. 17-2 matter 2:20-
19 01804-JLR pp. 2-3, and matter 3:20-06112-BHS Dkt. 72-2 p.5 of listing in tort claims
filing. Dr. Charles Paxon, “This has never been treated directly except by massage
20 and physical therapy.” “Low back pain is constantly present but not major issue until
she feels the hip is out. The hip..... malfunction at times for no apparent reason....”
21
22 e) March 5, 2002 “She has a positive Gilet test on the right side. She has a short right
lower extremity by about half-inch. Her ischial tuberosity is actually high by more
23
likely an inch. The iliac crest on the right is high by about an inch or more. ...” Id.
24
f) Dkt. #85: Dr. Mark A. Tomski Beginning date = Oct. 23 1995, Ending = May 17,
25 2004. Diagnosis and treatment: “Chronic Recurrent Si Dysfunction”. Years of this
disability: 9 years”. Dated 01/03/2005. I paid Dr. Tomski out of pocket for years.
26
27

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g) From 2015 through 2022, Plaintiff has had numerous effective and appropriate
1
medical treatment procedures to recover and mostly overcome these injuries. CSX
2 has paid out of pocket. For years my injuries were masked with drugs instead of
procedural treatment. It wasn’t until I had completely self-discontinued the daily
3 anesthetizing drugs December 20, 2016. Then especially the morphine June 9, 2017
that my injuries manifested as unresolved. Dkt. # # 80, 81, 82, 83, 84.
4
h) Brains do not heal overnight. It takes years. It is possible. I’m living proof.
5
6
11. The excessive drug prescriptions were used to mask and then treat my physical injury
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with a “mild” case of post-traumatic stress. Dkt. #209 p. 6; Dept of Veterans Patient Rights
8
2). “You will receive to the extent that you are eligible, prompt and appropriate treatment for
9
10 physical or emotional disorders or disabilities in the least restrictive environment necessary
11 for that treatment free from un necessary or excessive medication.” Defendant is in violation
12 of numerous other patient rights. The excessive prescribed drugs, with brain dysfunctions
13
drugs create, saturated in complex trauma contributed to Plaintiffs untimely filing within the
14
statute of limitations. Drugs and trauma cause brain cognitive impairments with anesthetizing
15
drugs to include thirteen (13) years of Chronic Opioid Therapy and other inappropriate off-
16
17 label drugs. (Dkt. ## 68, 98). (Hon. Judge Jones Drugs-1 Bench Copy Binder. DIGITAL
18 DRUGS-1 BINDER).
19 12. Even in November and December 2021 Dept of Veterans is still marred by intentional
20 delays, “blocking vets from getting outside care,” as Vietnam Veterans denied help as they
21
bleed out their ears.” (Dkt. #36-1 pp. 78–84). In 2019, by Defendants own admission as the
22
causation and significant contributor of Veteran’s suicide (Dkt. #94, DRUGS-1 DIGITAL
23
BINDER p. 32). Wait-times and cancellations in Plaintiff’s matter. Id. p. 22. Scandals of
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25 wait-times in 2014. In March 2021, Dept of Veterans is plagued with unacceptable
26 appointment cancelations.
27

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13. BAD FAITH, & GROSS NEGLIGENCE, 2001

1
2 a) The SAME PERSON initialed in three-different legal capacities = criminal impersonation. As
3 Court Clerk and Deputy Court Clerk and Filing Court Clerk. (Dkt. #52-1 pp. 55-56).
4 b) No Revised Code of Washington (RCW) laws were followed for either forensic or civil.
5
c) No processes were followed. None.
6
d) Legal clinical standards were ignored.
7
e) No grave disability. I did not meet the legal criteria for forceable commitment. Grave disability
8
standard not met. (Dkt. #111 pp. 26-27).
9
10 f) No danger to myself or others. Dangerous standard not met.
11 g) No due process seriously abridged.

12 h) No initial interview. No interview at Western.
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i) No great weight. (Dkt. #52-2 p. 241; CP-540).
14
j) No physical exam. (Dkt. # 52-1 pp. 58-59, p. 170; CP 55-56. CP-469).
15
k) No previous psychiatric episodes. (Dkt. #52-2 p. 241; CP-540).
16
17 l) No family psychiatric history. (Dkt. #52-2 p. 241; CP-540).
18 m) No previous hospitalization. (Dkt. #52-2 p. 241; CP-540).
19 n) Not a previous Regional Support Network client. (Dkt. #52-2 p. 241; CP-540).
20 o) No previous Chemical Dependency treatments. (Dkt. #52-2 p. 241; CP-540).
21
p) No justification for forced treatment under Administrative Policy 8.06, or 71.05 RCW’s.
22
q) No crime was committed. No charges filed for an isolated incident of erratic driving.
23
r) No right to refuse. Dkt. # 52-2 p. 468, CP-54.
24
25 s) No legal counsel. (Dkt ##229, 229-1, 230, 230-1).
26 (See DIGITAL GREEN BINDER / Hon. Judge Jones Bench Copy).
27

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t) Pierce County (and Thurston County) Superior Court did not hold Defendant to any statutes,
1
2 regulations, state and/or Federal laws, nor policies, to include the U.S. Constitution. Just as Hon.
3 Magistrate Judge David Christel did not hold Defendants to the same legal standards. Perhaps
4 there is unconscious bias by the Court. It would be unfair, bias, and partial of the Court to now
5
hold the Plaintiff to a different legal standard. It is unfair to permit defendants to escape
6
responsibility. Thus, the Court concedes admitting to selective justice.
7
8
14. The Magistrate Judge is wrong when he stated 2014 to 2018 in (Dkt. #219 p. 7 at 13)
9
10 that CSX planned a frozen cookie business. This frozen cookie business was started in 2001.
11 (Dkt. # 248 p. 2 at 2-4. Dkt. #128 NOTICE of filing Paper/Physical Material, Dkt. #110
12 series). This was started prior to the kidnapping and with criminal treatment at Providence.
13
See Hon. Judge Jones GREEN Binder, DRUGS-1 Binder. The GREEN DIGITAL Binder has
14
matter 3:22-05258-JCC Dkt. 45 (as that was my binder copy file. I was not able to print 3:22-
15
01276-RAJ file. The GREEN Binder is comprised of more than #111. See Other Binder Dkt.
16
17 Lists attached. See Dkt. #156-5 p. 14. The Magistrate Judge is wrong (#219 p. 6 at 17-18).
18
19 II. NEW MATTERS APPLY TO EQUITABLE TOLLING

20 Resolving the violent trauma of what happened to me in 2001, I discovered my Second
21
Amendment rights were infringed upon in 2018, from 2001. (Dkt. #95) I have been in contempt of
22
Court more than once not knowing that my right to bear arms were infringed. On August 14, 2019, I
23
filed for Restoration of Rights in Thurston County Superior Court.
24
25 In “The Body Keeps the Score, Brain, Mind, and Body in the Healing of Trauma,”
26 individuals with trauma, complex trauma, addressing what’s known as Broca’s area is of the speech
27

2:21-CV-01276-RAJ
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center of the brain. When damaged, one cannot put their thoughts and feelings into words. “Trauma
1
2 by nature drives individuals to the edge of comprehension, cutting us off from language based on
3 common experience or an imaginable past.” The excessive drugs Dept of Veterans prescribed
4 impaired functioning thus creating more delay. “Drugs cannot ‘cure’ trauma; they only dampen the
5
expressions of a disturbed physiology.” (with emphasis). Complex trauma is linked with more severe
6
cognitive impairment and compartmentalization. Compartmentalization is a coping mechanism to
7
adapt.
8
Equitable tolling applies in this case. Medical evidence and Plaintiff’s cognitive impairment
9
10 functioning delays are proven throughout the Court records and filings. Trauma It is medically
11 established that unresolved trauma is activated around certain triggers. An individual can do fine in
12 areas not activated. As stated in the DSM IV (1994–2013): “persistent avoidance of stimuli
13
associated with trauma...” “Efforts to avoid activities, places, or people that arouse recollections of
14
the trauma;.” “Avoidance of or efforts to avoid people, conversations, or interpersonal situations that
15
arouse recollections of traumatic event(s).” Trauma can be physiological and/or psychological. Thus,
16
17 it is not uncommon for trauma to impair an individual’s functionality. In this situation, crippling
18 drug effects also masked physical injuries and made it difficult to regain other areas in life.
19 Trauma impaired Plaintiffs ability to comprehend a cause of action. See also Cada v. Baxter
20 Healthcare Corp., 920 F.2d 446 (7th Cir. 1990).
21
Hon. Judge Richard A. Jones, CSX cannot remove the unconscious bias from the Court. The
22
23 pharmaceutical juggernaut needs to have its appetite halted. CSX respectfully requests that the Court
24 consider the Solutions listed in the Injunctive and Declaratory Relief: Dkt. #30 pp. 196-234.
25 An Oral Argument is requested to help me verbally express my case instead of only in

26
writing.
27

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III. CONCLUSION
1
2 The Statute of Limitation is timely for drug violations against Defendant United States
3 Department of Veterans Administration. Plaintiff respectfully requests this Court grant Carolyn
4 Sioux Green’s Motion for Reconsideration. CSX is requesting a change in the order of Dkt. #219
5
and to have my case reinstated. Justice requires this matter be set for trial, and that the statute of
6
limitations be equitably tolled for the older portions of the record. Plaintiff also requests that her
7
firearm rights be restored in the remaining 49 states.
8
I declare under penalty of perjury that the forgoing statement is made under penalty of
9
10 perjury under the laws of the state of Washington and Arizona foregoing is true and correct, and I
11 am competent to testify to the matters set forth herein.

12
13 RESPECTFULLY SUBMITTED this 21st day of October 2022.
14 s/ Carolyn Sioux Green

s/ CANDIDCAROLYN®
15 CAROLYN SIOUX GREEN
PO Box 38097, Phoenix, Arizona 85069
16 (253) 588-8100, candidCarolyn@gmail.com
17 Plaintiff Self-represented
18
19
20
21 Note: Dkt. #253 re:(4). Plaintiff’s PACER fee waiver was GRANTED by Chief United States
District Judge Hon. David G. Estudillo on September 19, 2022. (See Courts email to plaintiff
22 09/19/2022 @ 2:40 PM sent by ES). (See Dkt. #239).
23 Reference:
1). https://www.usatoday.com/story/opinion/2021/03/05/veterans-affairs-wait-time-medical-appointment-
24 trump-mcdonough-column/6820715002/ 2). https://www.defense.gov/News/News-
Stories/Article/Article/3167285/dod-services-moving-ahead-on-recommendations-to-combat-sexual-assault/
25 3). https://www.panoramas.pitt.edu/news-and-politics/case-vanessa-guill%C3%A9n-military-crimes-united-
states 4). https://www.military.com/daily-news/2021/05/25/i-am-vanessa-guillen-act-praised-calls-removing-
26 cos-sexual-assault-prosecutions-mount.html
27

2:21-CV-01276-RAJ
PAGE - 14
Hon. District Judge Richard A. Jones

1
3
DRUGS-1 DIGITAL BINDER
DOCKET NUMBERS
4
5
Binder Front Pocket left side (placed after 3 and 4)
6 1) 54: Carolyn Sioux Green AKA: NOTICE (“NOTICE”) of Paper/Physical Material filed
with the Clerk
7
2) 220-4: American Disabilities Act (ADA) Effective Communications, Request for ADA
8 Accommodations, Attachments, + Dkt 13
9
10 DKT #s in Binder
3) 65 p. 105: Carolyn Green photo comparison 1998 & 2002
11
12
13 5) 98 pp. 2-10: DRUG TRANSPARENCY 1994-2017 Excel sheets
14 6) 65 p. 179: Carolyn Green photo comparison (the maiming process continues) 1996 & 1999
15 7) 65 p. 166: Carolyn Green photo comparison 1996 & 1998

16 8) 66 p. 37, and seen in 73 p. 21: Carolyn Green photo comparison 1993, 1997, 1999, 2003
17
9) 57: Carolyn Green photo of her more animated. See Notice flash drive
18
19
20
21 12) 67 p. 23: Carolyn Green photo comparison 1999, 2009, 2019
22 13) 65 p. 184: Carolyn Green photo comparison 2001 & 2019
23 14) 95 p. 107: DRUGS and criminal mistreatment First 24 hours at Providence

24
15) 113-1 p. 16: DRUGS and criminal mistreatment First 24 hours at Providence
25
16) 114-14 p. 50: “I still have several physical signs of deep bruising....” after 5 days
26
17) 113-1 p. 10: Providence ER May 31, 2001 restraint record + DRUGS
27
28 DRUGS-1 DIGITAL BINDER FILE: 2:21-CV-01276-RAJ

PLAINTIFF CSX MOTION FOR RECONSIDERATION
PAGE - 1
18) 114-14 p. 8: Visual of restraints and DRUG combination

1
2 19) 114-13 p. 14: Ice cream tops front side with DRUGS
3 20) 114-13 p. 15: Ice cream tops back side with DRUGS
4 21) 114-14 p. 12: Providence DRUGS, still waiting for court appointed attorney
5
22) 65 pp. 13-16: PROVIDENCE ILLEGAL FORCED DRUGGING
6
23) 95 p. 106, also partly redacted in Dkt 110-3 p. 15: I NEED A JUDGE
7
24) 64 p. 33, and seen in 110-3 p. 14: Carolyn’s trademark
8
25) 114-13 p. 90: I NEED A JUDGE (not redated version)
9
10 26) 74 p. 49 and seen in 65 p. 12: Illegally Forced Injected Haldol
11 27) Reported neg side effects of Haldol, front side. See Notice 176 p. 1
12 28) Reported neg side effects of Haldol, back side. See Notice 176 p. 1
13
29) 113-3 p. 64: Providence’s illegal standing order drug administration
14
30) This Dkt. #: Providence exhibit PSPH 034: Illegal standing order drug administration
15
31) This Dkt. #: Providence exhibit PSPH 035: Illegal standing order drug administration
16
17 32) 74 p. 48 American Gaslighting (Haldol dkt located in Dkt. 57 drug excel sheet)
18 This Dkt. # Haldol neg drug effects reported
19 33) 64 p. 31: Harmful side effects of Haldol Extrapyramidal Effects aka (EPS)
20 34) 95 p. 108: Providence illegal injections of Haldol to a competent individual
21
35) 57: NOTICE, Providence Illegal Forced Drugs prior to Court
22
36) 57: NOTICE, Providence medical abbreviations/terms
23
37) 95 p. 109: Providence DRUGS
24
25 38) 111 p. 45: Court venue change Providence to Dept of Veterans
26 39) 64 p. 35: Providence transfer to Dept of Veterans with illegal forced drugs
27

PAGE - 2
40) 62 p. 65: Dept of Veterans medical record transferred due to Providence perjury
1
2 41) 65 p. 154: h/o right hip pain (secondary to h/o shipboard fall)
3 42) 62 p. 51: DEPT OF VETERANS1 ILLEGAL FORCED DRUGGING

4 43) 62 p. 72: DEPT OF VETERANS ILLEGAL STANDING ORDER
5
44) 67 p. 13: I could hardly write my name 06/21/2001
6
45) 62 p. 12: I could hardly write my name 06/21/2001
7
46) 114-13 p. 96: ...”asking to Petition the doctor & Court to present my documents as evidence
8 and have my hearing conducted according to the rules of evidence.”
9
47) 93 p. 239: Maiming process
10
48) 65 p. 150: How Care Works at Dept of Veterans
11
49) 62 p. 4: “Fighting to get out of her restraints” No interview.
12
13 50) 62 p. 19: WESTERN ILLEGAL FORCED DRUGGING
14 51) 74 p. 98, and seen in 62 p. 18: WESTERN ILLEGAL FORCED DRUGGING
15 52) 62 p. 46: “COMPETENT”

16 53) 62 p. 51: DEPT OF VETERANS ILLEGAL FORCED DRUGGING
17
54) 67 p. 16, and seen in 65 p. 159: Dept of Veterans Orientation Handbook. Reduced to this
18
55) 67 p. 17: Dept of Veterans Orientation Handbook. Reduced to this
19
56) 67 p. 15: Dept of Veterans “And I couldn’t even fill out the form”
20
21 57) 62 p. 142 combined with 65 p. 7: CSX Requesting a WALKING CANE!!
22 58) 64 p. 44: 2001 DRUGS THERAPEUTIC DUPLICATION
23 59) 110-1 pp. 9-10: Carolyn’s Cookies at Chamber of Commerce Mason County May 2001
24
60) 61 p. 15: USCG Shipboard LIMITED DUTY MEDICAL BOARD REPORT
25
61) 30 pp. 263-267: IDENTIFIED DAMAGING EFFECTS OF A FRONTAL CHEMICAL
26 LOBOTOMY. CSX was Chemically Lobotomized in 2001
27

PAGE - 3
62) 30 pp. 316-328: DRUG SIDE EFFECTS

1
2 63) 114-1 pp. 1-7: PROVIDENCE “RECOPIED” DRUG RECORDS
3 64) 114-2 pp. 1-32: Providence No Right to Refuse

4 65) 68 pp. 1-130: Medical Experts Research and Affidavits
5
66) 56 pp. 56-79: Drug Interactions Report Providence
6
67) 67 pp. 2-4: My Heart
7
68) 91 p. 21: Part of the Process
8
69) 142 p. 1: NOTICE Brain impairment cognitive processing 2015
9
10 70) 67 p. 19: Cognitive dysfunction–brain damage
11 71) 95 pp. 8-9 (not 5-6): Restoration of Rights Case No. 19-2-04117-34, and seen in Case
12 No. 3:20-06112-BHS dkt 50-35 pp. 92-93
13
72) 180 p. 1: NOTICE Filings/misfiling’s of Plaintiff
14
73) 118 p. 1: Filings/misfiling’s coversheet return receipt proof of service
15
74) 201 p. 1-2: NOTICE Certified Mail Return Receipts + Documentation of Paper/
16 Physical Material filed with the Clerk
17
75) 116 pp. 15-20: MORPHINE PROOF OF SERVICE (p. 15 not in physical Binder)
18
76) 118 pp. 2-3: List of Filings by Plaintiff
19
77) 2 pp. 48-51: Case 2:20-01804-JLR DRUG PACKET Partial (+matter 20-2-07852-8)
20
21 78) 2 pp. 52-55: Case 2:20-01804-JLR DRUG PACKET Partial Refilled Drugs Missing
on VA Pharma Date Records. Drug Transparency VA Puget Sound
22
79) 30 p. 293: Drug Interactions VA Puget Sound
23
80) 30 pp. 291-292; Drug Interactions Overview; major, moderate, minor, therap. duplicate
24
25 81) 213 p. 1: www.drugs.com Username: 984980 with pw: betterthinking984980
26 82) 59: NOTICE Original Affidavit for MORPHINE, packaging, distribution evidence
27

PAGE - 4
83) 57 and 59: See Notice photo evidence of liquid-morphine unopened, Flash Drive
1
2 84) 69: pp. 1-51: DRUG TRANSPARENCY Part 1
3 85) 30 pp.. 24-29: DRUG REGIMEN: USCG + DEPT OF VETERANS

4 86) 71 pp. 298-302: Paxil, DRUG TRANSPARENCY Exh 69 pt3
5
87) 71 pp. 246-249: Clonazepam aka Klonopin, DRUG TRANSPARENCY Exh 69 pt3
6
88) 71 pp. 238-239; Celebrex, DRUG TRANSPARENCY Exh 69 pt3
7
89) 71 pp. 270-271: Gabapentin aka Neurontin, DRUG TRANSPARENCY Exh 69 pt3
8
90) 71 p. 231: Lorazepam aka Ativan, DRUG TRANSPARENCY Exh 69 pt3
9
10 91) 71 p. 285: Methocarbamol aka Robaxin, DRUG TRANSPARENCY Exh 69 pt3
11 92) 57: Methocarbamol photo proof of refill 8 of 12. 8 refills not on pharma record, NOTICE
Flash drive
12
13 93) 57: Methocarbamol photo proof of refill 4 of 12...., NOTICE Flash drive
14 94) 61 p. 161: Solvents and Fuels, in particular Toluene
15 95) 64 p. 6: USCG Limited Duty Medical Board Report

16 96) 61 pp. 108-109: Yvonne Fee Letter from DISTRICT 13, hostile medical care
17 and seen in 64 pp. 9-10
18 97) 147: NOTICE Original Letter by Yvonne Fee
19 98) 84 pp. 3-4: Dr. Charlie Paxon, “This has never been treated directly...” (referenced in
Binder as matter 3:20-06112-BHS dkt 50-24 pp. 3-4)
20
21 99) This Dkt. #: “...awfully doped up” that she was usually more animated. “I can’t understand why
my underwear is an issue.” See Dkt. #84 p. 4.
22
100) 93 p. 239: From Appendix A: Drug Regimen in book LOCKED (referenced in Binder
23 as matter 2:20-01804-JLR dkt 17-6 p. 10)
24
101) 30 pp. 298-304: How Long it Took
25
///
26
///
27

PAGE - 5
102) 73 p. 3: 306th Bombardment Group Historical Association Directory – Sept Cover

1
2 103) 73 p. 11: Mr. David E. Nye World War II Veteran

Jr. csx
3 104) 73 pp. 4, 7-8: Injury, causation drugs
4 105) 73 p. 12: Mr. Tom Slee Korea & Vietnam Wars Veteran
5
106) 73 p. 14-15: Neglected in assisted living
6
107) 73 p. 18: Mr. Kenny Campbell and Carolyn photo
7
108) 73 p. 17: Mr. Kenny Campbell Veteran Drug Interactions; 4-major, 61-moderate
8 Vietnam War Veteran. csx
109) 73 p. 19: Kenny Campbell text message May 4, 2018 @ 13:30 about how often he’s
9
taking his drugs prescribed by Dept of Veterans. This msg includes a reply from
10 Carolyn @ 2:26 pm with a Cutler post. Mr. Boone Cutler an Iraq War Veteran.
See Dkt. #72 for his drug interactions as well as other Veterans.
11
12 110) 73 p. 2: Mr. Perry Hopman Iraq War Veteran, photo Nat’l Geographic 2015
13 111) 73 p. 1: Mr. Chris McNair Afghanistan War Veteran, photo Nat’l Geographic 2015
14
112) 65 p. 165 Carolyn Green who no longer claims Veteran status
15
113) 73 p. 26, Id
16
114) 30 pp. 196-234 INJUNCTIVE AND DECLARATORY RELIEF AND DAMAGES
17
115) 30 pp. 353-357: Citation references
18
19 116) 65 p. 157: Carolyn Green photo followed by references (random selection as I did not
make a copy of this section for my Binder), from Dkt #103. csx
20
21
22
RESPECTFULLY SUBMITTED this 21st day of October 2022.
23
s/ Carolyn Sioux Green
24 s/ CANDIDCAROLYN®
CAROLYN SIOUX GREEN
25 PO Box 38097, Phoenix, Arizona 85069
26 (253) 588-8100, candidCarolyn@gmail.com
Plaintiff Self-represented
27

PAGE - 6

Motion For Reconsideration in The U.S. DISTRICT COURT Washington State

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Motion For Reconsideration in The U.S. DISTRICT COURT Washington State

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Case 2:21-cv-01276-RAJ Document 258 Filed 10/21/22 Page 1 of 20

Hon. District Judge Richard A. Jones

11 Plaintiff, PLAINTIFF CAROLYN SIOUX GREEN’S

28 PLAINTIFF CSX MOTIONS FOR RECONSIDERATION

14 I. THE COURT OVERLOOKED OR MISAPPREHENDED

28 PLAINTIFF CSX MOTIONS FOR RECONSIDERATION

21 excessive medication (drugs).” emphasized.

23 C. Drug Interactions of CSX 2003-2014: 7 major, 10 moderate

28 PLAINTIFF CSX MOTIONS FOR RECONSIDERATION

including death,” and “may have opioid hyperallergic.” SIX-YEARS on morphine

2 and methadone simultaneously with a benzodiazepine.

3 (3) Drug Interactions by Dept of Veterans in 2001: 6 major, 16 moderate

18 mostly verified drug interactions as well as those of other Veterans.

28 PLAINTIFF CSX MOTIONS FOR RECONSIDERATION

15 Drugs not recorded on the pharmacy dispensary record. A few examples,

16 a) 8 of 12 refills yet the initial 8 prescriptions of Methacarbomol are missing on the

28 PLAINTIFF CSX MOTIONS FOR RECONSIDERATION

2 excessive drugs prescribed 1996-2017 with evidence provided to the Court.

18 similar recommendation regarding the Department of Defense (DoD) Commands authority

26 members on American soil. My case was entirely preventable.

28 PLAINTIFF CSX MOTIONS FOR RECONSIDERATION

EXCESSIVE DRUGS PRESCRIBED TO MASK-TREAT MY PHYSICAL INJURY

28 PLAINTIFF CSX MOTIONS FOR RECONSIDERATION

19 designed to set you up for failure,” stated in 2017. (emphasized).

26 through p. 158 to line 12, p. 164 at 21-22, p. 165, p. 221-225.

28 PLAINTIFF CSX MOTIONS FOR RECONSIDERATION

28 PLAINTIFF CSX MOTIONS FOR RECONSIDERATION

10 physical or emotional disorders or disabilities in the least restrictive environment necessary

25 wait-times in 2014. In March 2021, Dept of Veterans is plagued with unacceptable

28 PLAINTIFF CSX MOTIONS FOR RECONSIDERATION

13. BAD FAITH, & GROSS NEGLIGENCE, 2001

2 a) The SAME PERSON initialed in three-different legal capacities = criminal impersonation. As

10 f) No danger to myself or others. Dangerous standard not met.

11 g) No due process seriously abridged.

17 l) No family psychiatric history. (Dkt. #52-2 p. 241; CP-540).

18 m) No previous hospitalization. (Dkt. #52-2 p. 241; CP-540).

25 s) No legal counsel. (Dkt ##229, 229-1, 230, 230-1).

26 (See DIGITAL GREEN BINDER / Hon. Judge Jones Bench Copy).

28 PLAINTIFF CSX MOTIONS FOR RECONSIDERATION

19 II. NEW MATTERS APPLY TO EQUITABLE TOLLING

28 PLAINTIFF CSX MOTIONS FOR RECONSIDERATION

25 An Oral Argument is requested to help me verbally express my case instead of only in

28 PLAINTIFF CSX MOTIONS FOR RECONSIDERATION

11 am competent to testify to the matters set forth herein.

13 RESPECTFULLY SUBMITTED this 21st day of October 2022.

14 s/ Carolyn Sioux Green

28 PLAINTIFF CSX MOTIONS FOR RECONSIDERATION

Hon. District Judge Richard A. Jones

13 5) 98 pp. 2-10: DRUG TRANSPARENCY 1994-2017 Excel sheets

15 7) 65 p. 166: Carolyn Green photo comparison 1996 & 1998

21 12) 67 p. 23: Carolyn Green photo comparison 1999, 2009, 2019

22 13) 65 p. 184: Carolyn Green photo comparison 2001 & 2019

23 14) 95 p. 107: DRUGS and criminal mistreatment First 24 hours at Providence

28 DRUGS-1 DIGITAL BINDER FILE: 2:21-CV-01276-RAJ

18) 114-14 p. 8: Visual of restraints and DRUG combination

10 26) 74 p. 49 and seen in 65 p. 12: Illegally Forced Injected Haldol

18 This Dkt. # Haldol neg drug effects reported

25 38) 111 p. 45: Court venue change Providence to Dept of Veterans

28 DRUGS-1 DIGITAL BINDER FILE: 2:21-CV-01276-RAJ

3 42) 62 p. 51: DEPT OF VETERANS1 ILLEGAL FORCED DRUGGING

13 50) 62 p. 19: WESTERN ILLEGAL FORCED DRUGGING

14 51) 74 p. 98, and seen in 62 p. 18: WESTERN ILLEGAL FORCED DRUGGING

15 52) 62 p. 46: “COMPETENT”