BENNETT VS JAKUBOWSKI Et Al.

AUSTIN BENNETT
8013 MARSANNAY WAY

SACRAMENTO CA, 95829
Tel: (916) 599-5142
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In Pro Per
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SUPERIOR COURT OF THE STATE OF CALIFORNIA

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COUNTY OF SACRAMENTO
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UNLIMITED JURISDICTION
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AUSTIN BENNETT, Case No.:

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Plaintiff, BENNETT VS JAKUBOWSKI et al.

11
vs.
12
Marine Jakubowski, an individual; Dr. J &
13 Associates Psychological Services PC; The
Superior Court of California, County of
14) Sacramento; Sacramento County; City of
Sacramento; State of California
15. and DOES | to 100,
755 Defendants.
17
18
Dated: August 3, 2023
19
20
21 By:
AUSTIN BENNETT
2Z
23
24
25
STIN BENNETT DE SAT BY ON I
26
27
28
1
BENNETT VS JAKUBOWSKI et al.
WN TABLE OF CONTENTS
INTRODUCTION. ...............cccccccccccccecccccsssssssscevasecessceuceccecseeutecerevenseeee 1
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II. THE PARTIES. ............cccccccccccscscccccccccceccccenccesscesncceeseetcececceeccecesecesens 3-4

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A. The Plaintiff
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B. The Defendants
C. The Doe Defendants
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11 Il. STATEMENT OF FACES .,..n.ccssesssasnsnssnsess

spenesnosns sneancononsastesygaventessanees ses 4
12
13 CLAIMS FOR RELIEP.................cccccccecesceecnscecceeesccsceeseeceseeceseceeeass 15

14 Count I: (Medical Malpractice)............ccccesesceecscceceececeeeeeeceececeecnceeeesseeesuess 15
oe 15-
Count II: (Attempted Medical Battery)...............sccececsesececsceecscncnsceveeseenen
sees 16
_ 16 Count III: (Attempted False Imprisonment)..............::cccsscesesessseceecceceuseeceseesess 17
17 Count IV: (Psychotherapist Malpractice).............:cccecsececseceececccecescecescseesenens 18
18 Count V: (Intentional infliction of Emotional Distress)..............cccecceeceeceeseessseees 19
19 Count VI: (Negligent Infliction of Emotional Distress)................ccccesceesceescesseee 20
20 Count Vil; (A pice Of Proce is esses sa « cesmmadonasesdbsrunvann)i4ss0ieysbevrenceseannwness 22
21 Count VIII: (Fraud & Intentional Deceit).......0.......cccceccsecceeececeeeceecceescsseceensce 22
22 Count IX: (Constructive Fraud).........ccc.csscecssccssseceececescescceceeseeseuceesssarse
senses 23
23 Count X: (Negligent Misrepresentation).................cccsceecseccecsscccecececeecececsnscees 25
24 Count XI: (Defamation Per Se)............cccccceceececececeucececccsecescscececsceseeeceeeuces 26
an OUR A ULE POPE) cresnnconsewnas vomguvxannngsssanadamisaacteons

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26 OMG) EBTIOT chins snrcrmsdinencns sacoreeenmiian aemmanionens nen siannesSabeiperosormreswxcesese 29

27 Count XIV: (False Light)..............ccecsscceccecccssseeceecseeeceecescesceceuseuceusreeceres 30
28 Count XV: (Personal Injury)...............cssccsscccescceeccseaceeeceeeeeesesseccussenssseee
sens 31
2
1 Count XVI: (Negligent Undertaking)....0...........cccecesececececececececsssseeeseecsecesens 33
2 Count XVII: (Negligent Selection of a Contractor)..............cccccececececececeseesessees 34
3 Count XVIII: igent Hiring, Retention & S USION).........sccceceecececseceeceees

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4 Count XIX: (Public Entity: Failure To Discharge Mandatory Duty).....................36

5 Count XX: (Public Entity: Acts & Commissions of Employees)..............sssceeeeee 37
. Count XXI: (Negligence)........c.sscessssessessssesssssssssucseesesseeeeseeneeeeeeaeenmees 39

7 Count XXII: (Loss of Consortium).............:cccccccceccccccecccccccccecceesencecessseecce 39
8 Count XXIII: (Intentional Misrepresentation)................ccscceeseceseseeececcssssscseces 40

9
10 | 'V. NON-PUNITIVE DAMAGES. ...........scscssessessseessesseeeseeeunesenessneesseessesss 41

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11
12 | VI. PUNITIVE DAMAGEG..............cccccccscccccccsccsccessccesecseccecesecesecasseecenves 42

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16 | VIET. JURY DEMANDED. ...........c00ccccccccccecccseccseeecueeceeceseecaseeeeeeceuecsseae

sense 43
17
18 Il. THE PARTIES
19
20 A. The i tiff
21
22 | 1. Austin Bennett (Kenneth Austin Bennett). Mr. Bennett is an individual whose principal
23 | residence is located in Sacramento County, CA.

24 | B. The Defendants
25
26 | 2. Marine Jakubowski is an individual with her principal place of business at 100 Howe Avenue,
27 | Sacramento, California 95825, United States South Building, Suite 210.
28
3
BENNETT VS JAKUBOWSKT et al.
3. Dr. J & Associates Psychological Services PC with it’s principal place of business at 100.
Howe Avenue, Sacramento, California 95825, United States South Building, Suite 210.
4. The Sacramento County Superior Court is a public entity.

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5. Sacramento County.
6. City of Sacramento.
7. State of California.
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C. The Doe Defendants

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10 6. Plaintiffs allege at all times mentioned herein, the true names or capacities, whether
11 individual, corporate, associate, or otherwise, of defendants DOES 1 through 100, inclusive, are
12 unknown to Plaintiffs and therefore Plaintiffs sue these DOE defendants by such fictitious
13 names.
14
ve 15-
7. DOES 1 through 100. Plaintiffs will amend this Complaint to allege their true names and
_ 16 capacities when ascertained. Plaintiffs are informed and believe and based thereon allege that
17 each of these fictitiously-named defendants is responsible in some manner for the occurrences
18 herein alleged, and that Plaintiffs' damages as herein alleged were proximately (legally) caused
19 by their conduct.
20
el D. Venue
22
23 8. Venue is properly laid in Sacramento County because the defendants all maintain an office in
24 this County where the plaintiff was harmed, the individual Defendants work and/or reside in this
Zs County, and the facts and circumstances giving rise to this lawsuit occurred in substantial part in
26 this County.
27
28 Ill. Statement of Facts
4
BENNETT VS JAKUBOWSKTI et al.
9. Mr. Bennett left broadcast news, to become an investment advisor.
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10. Mr. Bennett earned his Bachelor of Science in Business Administration with an emphasis in
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finance.
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11. Mr. Bennett passed multiple exams to obtain his insurance and security licenses, in order to
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trade stocks and bonds, and also to sell insurance vehicles including life, disability and heath
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policies.
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12. Mr. Bennett also earned the Chartered Financial Consultant designation as well as the
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10 Chartered Life Underwriter designation.

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11 13. Mr. Bennett was sponsored by ING to attend UCLA which collaborated with The Retirement
12 Advisor University.
13 14. In order to attend The Retirement Advisor University a candidate must demonstrate a high
14" level acumen for pension planning, with a minimum of $20 million under management.
@ BENNETTvsSAC
15.
15. Mr. Bennett’s firm, Bennett Financial Strategies, later became a Registered Investment
16
Advisor through the State of California.
17
18 16. Less than half of one percent of all investment advisors in the nation qualify as a Registered
19 Investment Advisor.
20 17. Mr. Bennett audited a local grocery chain in Sacramento, with assets of more than $400
21 million.
22
23 18. Mr. Bennett’s firm was recognized in the Sacramento Magazine as a top wealth manager.
24
19. Mr. Bennett built a reputation as a top financial advisor.
25
20. Mr. Bennett received referrals from national financial institutions because of his reputation.
26
27 21. Mr. Bennett’s firm Bennett Financial Strategies was growing and receiving more and more
28 referrals.
5
22. On September 19, 2022 Dr. Jakubowski filed for chapter 7 bankruptcy in United States
Bankruptcy Court.
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23. Mr. Bennett was accused of 1 count of misdemeanor simple battery because he was accused
of pushing someone.
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24. Mr. Bennett was in court on 1 single misdemeanor charge and no felony charges.
25. Mr. Bennett wanted to exercise his right to a jury trial to determine his innocence or guilt.
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11 26. Mr. Bennett could have presented affirmative defenses at a jury trial.
12
13 27. Mr. Bennett wanted to exercise right to question his accuser.

14,
> 15. 28. These rights are guaranteed by the Constitution of the United States.
16
17 29. These rights are guaranteed by the Constitution of the State of California.
18
19 30. The maximum penalty for 1 count of misdemeanor battery is 6 months in jail.
20
21 31. The penalty does not include having your business or reputation destroyed.
22
23 32. The public defenders representing Mr. Bennett instigated competency proceedings against
24 Mr. Bennett without any legal basis.
25
26 33. The public defenders got Judge Southworth of the Sacramento County Superior court to
a7 declare a doubt about Mr. Bennett’s competency to stand trial.
28
6
34. Mr. Bennett did not want to plead anything related to incompetency or be found incompetent
because it would ruin his reputation and destroy his business.
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35. Around June 21, 2022 Dr. Jakubowski a licensed psychologist was hired to perform a
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competency evaluation on Mr. Bennett.

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36. During Mr. Bennett ’s evaluation Dr. Jakubowski forensic clinical psychologist owed a duty
to Mr. Bennett to perform her evaluation within an acceptable standard of care within the
psychology community.
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11 37. Dr. Jakubowski breached this standard of care by including false facts in her report.
12
13 38. At the time of the evaluation that Dr. Jakubowski was hired to perform she was short of
14, money.
7 15-
16 39. Mr Bennett refused to cooperate with the competency evaluation and was held in the
17 Sacramento County jail in order to force him to cooperate with the competency evaluation.
18
19 40. When Dr. Jakubowski performed her first attempt at a competency evaluation, Mr. Bennett
20 just stated that he did not consent and was led back to his cell by the guard.
21
22 41. If a competency evaluation is considered unsuccessful Dr. Jakubowski would have had to
23 return to the jail 2 more times to try and successfully complete a competency exam.
24
2 42. If after a total of 3 unsuccessful attempts were made Dr. Jakubowski would have gotten paid
26 $250 instead of $600 for her work.
27
28 43. Dr. Jakubowski never returned to make a second or third attempt at evaluating Mr. Bennett.
7
44. Dr. Jakubowski wanted to get paid $600 instead of $250.
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45. Dr. Jakubowski wanted to get paid $600 for 1 visit instead of $250 for 3 visits.
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46. Dr. Jakubowski wanted to get paid $600 for 1 visit instead of $250 for 3 visits, even if it
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involved writing a fraudulent report.
47. Instead of returning an additional 2 times to evaluate Mr. Bennett and receiving $250 Dr.
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10 Jakubowski made up a competency examination that was a work of fiction.

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11
12 48. In Dr. Jakubowski's report she stated that Mr. Bennett was facing a felony battery charge.
13
14 49. This was false.

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15.
16 50. Mr. Bennett was facing a misdemeanor charge.
17
18 51. In Dr. Jakubowski's report she stated that Mr. Bennett had 3 siblings who he did not maintain
19 a relationship with.
20
ai 52. This was false.
23 53. Mr Bennett maintained a relationship with his two siblings.

24
2 54. In Dr. Jakubowski's report she stated that Mr. Bennett had a history of childhood trauma.
26
2! 55. This was false.
28
8
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57. In Dr. Jakubowski's report she stated that Mr. Bennett was transient since his girlfriend broke
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up with him.
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58. This was false.

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59. Mr. Bennett lives with his wife and children and owns his own home. Mr. Bennett has never
been transient or had a relationship with anyone else while he was married to his wife.
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11 60. In Dr. Jakubowski's report she stated that Mr. Bennett began attending nursing school and
12 dropped.
13
14 61. This was false.
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16 62. Mr. Bennett earned his Bachelor of Science in Business Administration with an emphasis in
17 finance.
18 63. Mr. Bennett also passed multiple exams to obtain his insurance and security licenses, in
19 order to trade stocks and bonds, and also to sell insurance vehicles including life, disability and
20 heath policies.
21
64. Mr. Bennett also earned the Chartered Financial Consultant designation as well as the
22
Chartered Life Underwriter designation.
23
24 65. In Dr. Jakubowski's report she stated that Mr. Bennett was unmarried without children.
25
66. This is false.
26
27
28 67. Mr. Bennett is married to his wife Caryn Bennett and has children.
9
BENNETT VS JAKUBOWSKIT et al.
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68. Mr. Bennett’s wife Caryn was in the court room during the proceedings.
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69. In Dr. Jakubowski's report she stated that Mr. Bennett worked as a customer service
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representative and was frequently fired.

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70. This was false.

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71. Mr. Bennett is a financial advisor who owns his own business and has long lasting
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relationships with his clients.

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72. In Dr. Jakubowski's report she stated that “Mr. Bennett reported that he began to experience
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paranoia around age 18 or 19 secondary to marijuana use, and depression around age 23 or 25”
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73. This was false.

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74. Mr Bennett eves experienced paranoia.
75. Mr. Bennett does not use marijuana.

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76. Mr. Bennett did not have depression around age 23 or 25.
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77. In Dr. Jakubowski's report she stated that Mr. Bennett would not shower unless offered
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candy.
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78. This was false.
79, Mr. Bennett was never paid in candy to shower.
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80. The Sacramento County Jail does not give prisoners candy to shower.
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81. In Dr. Jakubowski's report she stated that Mr. Bennett received mental health treatment and
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used stimulants.
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82. This was false.

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83. Mr. Bennett did not use stimulants or receive mental health treatment.
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84. Dr. Jakubowski further went on to say that Mr. Bennett reported that people would call the
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police on him for no reason, had auditory hallucinations, was psychiatrically hospitalized, took
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psychotropic medication while in custody, but did not take it when he was released and uses
methamphetamine to mediate his symptoms.
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85. This was false.

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86. Mr. Bennett never reported that people would call the police on him.
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87. Mr. Bennett never had auditory hallucinations or reported them.

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88. Mr. Bennett never took psychotropic medication.

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89. Mr. Bennett was never in a psychiatric hospital.

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90. Mr. Bennett never had any of these symptoms.

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91. Mr. Bennett never used methamphetamine.

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92. Dr. Jakubowski made additional false statements in her report.
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93. Based on these made up symptoms Dr. Jakubowski diagnosed Mr. Bennett with
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schizophrenia spectrum disorder that remit while in a controlled environment and worsen with
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methamphetamine use.
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94. Based on these made up symptoms Dr. Jakubowski found Mr. Bennett incompetent to stand
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trial.
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95. The report that Dr. Jakubowski made up painted Mr. Bennett in the worst possible light.
96. The report that Dr. Jakubowski made up made Mr. Bennett look like he was a crazy person
who needed to be forcibly institutionalized for mental disease.
97. Dr. Jakubowski fabricated past symptoms as well as present symptoms.
98. Dr. Jakubowski report made Mr. Bennett look like he was insane.
99. Dr. Jakubowski's report put Mr. Bennett at risk for being forcibly confined in a psychiatric
hospital.
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100. Dr. Jakubowski's report put Mr. Bennett at risk for being forcibly medicated.
101. Dr. Jakubowski's report put Mr. Bennett at risk for having his assets taken under a
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receivership.
102. Dr. Jukubowski made a diagnosis of schizophrenia spectrum disorder.
12
103. Dr. Jukubowski was only hired to evaluate competency.
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104. Dr. Jukubowski went outside of the scope of what she was hired to do.
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105. Dr. Jukubowski made up was submitted to Judge Southworth of the Sacrament County
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Superior court under penalty of perjury.
106. Judge peter Southworth relied on Dr. Jakubowski's report to find Mr. Bennett incompetent
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10 to stand trial.
11
12 107. Judge Peter Southworth should have known that this report was false because the report
13 claimed that Mr. Bennett was charged with a felony when he was only charged with a
avn misdemeanor.
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16 108. Judge Peter Southworth should have known that this report was false because the report
17 claimed that Mr. Bennett was not married but Mr. Bennett’s wife was in the court room.
18
19 109. Because Mr. Bennett was found incompetent he was denied his right to a jury trial
20
21 110. Because Mr. Bennett was found incompetent he was denied his right to cross examine
Zz witnesses against him.
23
24 111. Because Mr. Bennett was fond incompetent Mr. Bennett was denied his right to assert
25 affirmative defenses such as self defense.
26
2 112. Because Mr. Bennett was found incompetent he believed that he was going to be locked in
28 a mental health institution against his will.
13
113. Because Mr. Bennett believed that he would be forcibly institutionalized for mental health
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he suffered extreme emotional distress.

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114. Most people who know that they are sane would suffer extreme emotional distress if they
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believed that they would be institutionalized for mental health.

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115. Being found mentally incompetent was humiliating for Mr. Bennett.
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10 116. After being found incompetent Mr. Bennett stopped receiving referrals from financial
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11 institutions.
12
13 117. After being found incompetent Mr. Bennett lost clients.

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“15° 118. Most people would not want a financial planner who has been incompetent to stand trial.
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16
17 119. Being found incompetent made it extremely difficult for Mr. Bennett to get new clients.
18
19 120. After being found incompetent Mr. Bennett’s business BennettFS stopped growing and
20 started to shrink.
21
22 121. Mr. Bennett as well as BennettF'S have suffered irreparable harm from being found
23 incompetent.
24
25 122. Being found incompetent put a strain on Mr. Bennett’s marriage and traumatized his wife
26 and children.
27
28
14
123. Mr. Bennett was haunted that he would be committed to a mental institution based on Dr.
Jakubowski's false report.

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124. People started creating social media posts depicting Austin Bennett as crazy.
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125. The damage done to Mr. Bennett’s reputation in the community and the damage done to
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Bennett FS is extremely difficult to undo.

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126. Dr. Jakubowski's false report destroyed the most profitable years of Mr. Bennett’s career.
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11 127. In the financial planning business the most lucrative years are at the end when the business
12 has built a solid reputation and customer base.
13
14 128. Dr. Jakubowski's false report prevented Mr. Bennett from enjoying the fruit of his labors
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* 19" that he worked on since 1999.

16
17 IV. CLAIMS FOR RELIEF
18
19
CoO I; MEDI MALPRACTICE
20
21
129. Plaintiff re-alleges the allegations set forth in in the statement of facts and incorporates
22
same herein by reference.
23
24
130. Dr. Jakubowski was hired to evaluate Mr. Bennett and did indeed complete an evaluation of
25
Mr. Bennett.
26
27
28
15
131. Dr. Jakubowski breached the duty of care through negligence, recklessness, or
incompetence by including facts that were false in her report.
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132. Because of the false facts in Dr. Jakubowski’s report judge Peter Southworth declared Mr.
Bennett incompetent to stand trial.
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133. Mr. Bennett suffered extreme emotional distress and humiliation from being declared
incompetent to stand trial.
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10 134. Mr. Bennett suffered extreme emotional distress and believed that he would be
11 institutionalized for many years after seeing people in jail go to the psychiatric section of the jail
12 and come back almost comatose.
13
14 135. The extreme emotional distress that Mr. Bennett suffered made was worse because Mr.
> 15- Bennett had bad reactions to medical procedures and pharmaceutical drugs in the past and was in
16 fear that this was going to happen again because he would be forcibly drugged in a mental
17 institution.
18
19 COUNT Il: ATTEMPTED MEDICAL BATTERY

20
21 136. Plaintiff re-alleges the allegations set forth in in the statement of facts and incorporates
22 same herein by reference.
23
24 137. Dr. Jakubowski was hired to evaluate Mr. Bennett and did indeed complete an evaluation of
PA] Mr. Bennett.
26
27 138. Dr. Jakubowski wrote a fraudulent report which was intended to get Mr. Bennett committed
28 to a psychiatric hospital.
16
139. Dr. Jakubowski did this up by fabricating symptoms and saying that these symptoms
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remitted in a controlled environment.

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140. Dr. Jakubowski wrote a fraudulent report which was intended to get Mr. Bennett forcibly
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drugged.
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141. Dr. Jakubowski wrongly diagnosed Mr. Bennett with schizophrenia spectrum disorder.
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142. Patients who have experience coerced medication tend to be aged in their 30s, with a
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10 diagnosis of schizophrenia, bipolar or other psychotic disorders, and are often involuntarily
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11 admitted. [https://pubmed.ncbi.nlm.nih.gov/19120567/]
12
13 143. Dr. Jakubowski did this up by fabricating symptoms and saying that these symptoms
“14: remitted when on psychiatric medication.
15”
16 144. Being forcibly drugged with psychiatric drugs can have severe consequences.
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18 COUNT IIT: ATTEMPTED FALSE IMPRISONMENT
19
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24 Mr. Bennett.
25
26 147. Dr. Jakubowski wrote a fraudulent report which was intended to get Mr. Bennett committed
27 to a psychiatric hospital.
28
17
148. Dr. Jakubowski did this up by fabricating symptoms and saying that these symptoms
remitted in a controlled environment.
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149. If Mr. Bennett were wrongly committed to a psychiatric institution his movements would
be limited to a physical area.
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150. Dr. Jakubowski wrongly diagnosed Mr. Bennett with schizophrenia spectrum disorder.
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151. Patients who have experience coerced medication tend to be aged in their 30s, with a
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10 diagnosis of schizophrenia, bipolar or other psychotic disorders, and are often involuntarily
11 admitted. [https://pubmed.ncbi.nlm.nih.gov/19120567/]
12
13 CoO IV: PSYCH RAPIST PRACTICE

214;
“17
19 Mr. Bennett.
20
21 154. Dr. Jakubowski breached the duty of care through negligence, recklessness, or
22 incompetence by including facts that were false in her report.
23
24 155. Because of the false facts in Dr. Jakubowski’s report judge Peter Southworth declared Mr.
25 Bennett incompetent to stand trial.
26
27 156. Mr. Bennett suffered extreme emotional distress and humiliation from being declared
28 incompetent to stand trial.
18
157. Mr. Bennett suffered extreme emotional distress and believed that he would be
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institutionalized for many years after seeing people in jail go to the psychiatric section of the jail
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and come back almost comatose.

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158. The extreme emotional distress that Mr. Bennett suffered made was worse because Mr.
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Bennett had bad reactions to medical procedures and pharmaceutical drugs in the past and was in
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fear that this was going to happen again because he would be forcibly drugged in a mental
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institution.
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COUNT V: INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS
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160. Dr. Jakubowski included facts in her report that she submitted to the Sacramento County
superior court that were outrageous and false, including putting in her report that Mr. Bennett
was accused of a felony when he was accused of a misdemeanor, stating that Mr. Bennett was a
transient and unmarried when he had a house, a business, a wife and children, stating in her
report that Mr. Bennett had previously diagnosed psychiatric problems when he had never been
F&F
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diagnosed with any psychiatric problems and other things that were false.
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161. Dr. Jakubowski acted with reckless disregard of the probability that Mr. Bennett would
NO
suffer emotional distress, knowing her conduct was directed at Mr. Bennett.
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162. Because of the false facts in Dr. Jakubowski’s report Judge Peter Southworth declared Mr.
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19
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165. The extreme emotional distress that Mr. Bennett suffered made was worse because Mr.
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Bennett had bad reactions to medical procedures and pharmaceutical drugs in the past and was in
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fear that this was going to happen again because he would be forcibly drugged in a mental
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institution.
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OUNT VI: NE T INFLICTION OF EMOTIONAL D Ss

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superior court, which were outrageous and false, including putting in her report Mr. Bennett was
accused of a felony when he was accused of a misdemeanor, stating Mr. Bennett was a transient,
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never married and had no children, when he had a house, a business, a wife and five children;
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stating in her report Mr. Bennett had previously been diagnosed with psychiatric problems when
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he had never been diagnosed with any psychiatric problem, including other things that were
spurious and untrue.
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168. Dr. Jakubowski acted negligently because she put false facts in her report that she would
easily be able to know that were false.
20
= 169. Because of the false facts in Dr. Jakubowski’s report judge Peter Southworth declared Mr.
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172. A guard confirmed to Mr. Bennett the medication given to prisoners in the mental ward
“turns them into zombies.”
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173. A cellmate who was being released from jail, where Austin was sent to force him to meet
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with Dr. Jakubowski, told Austin the same thing. Once prisoners go and come out of the mental
ward, they are never the same.
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174. The extreme emotional distress that Mr. Bennett suffered made was made worse, because
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Mr. Bennett had bad reactions to medical procedures and pharmaceutical drugs in the past, and
was in fear that this was going to happen again since he would forcibly be drugged in a mental
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institution.
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COUNT VII: ABUSE OF PROCESS

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176. On January 1, 2018 Dr. Jakubowski declared bankruptcy.

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21
177. Because of lack of funds Dr. Jakubowski decided to make a false report to the Sacramento
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County Superior court in order to have Mr. Bennett declared incompetent.

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178. Judge Peter Southworth of the Sacramento County Superior Court relied on these
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representations and found Mr. Bennett incompetent to stand trial based on these representations.
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179. By having Mr. Bennett declared incompetent Dr. Jakubowski had the opportunity to make
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more money by providing treatment to Mr. Bennett in addition to just an evaluation.

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11
12 180. Mr. Bennett suffered extreme emotional distress, was denied his right to face his accuser,
13 denied his right to a jury trial, lost clients and was humiliated because of these representations.
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a Sy 181. These representations were the main reason why Judge Peter Southworth found Mr. Bennett
16 incompetent to stand trial. No other evaluations were used.
17
18 COUNT VIII: FRAUD & INTENTIONAL DECEIT

19
22
23 183. Dr. Jakubowski included facts in her report that she submitted to the Sacramento County
24 superior court, which were outrageous and false, including putting in her report Mr. Bennett was
25 accused of a felony when he was accused of amisdemeanor, stating Mr. Bennett was a transient,
26 never married and had no children, when he had a house, a business, a wife and five children;
27 stating in her report Mr. Bennett had previously been diagnosed with psychiatric problems when
28
22
NY
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184, Judge Peter Southworth of the Sacramento County Superior Court relied on these
FP
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185. By having Mr. Bennett declared incompetent Dr. Jakubowski had the opportunity to make
KY
more money by providing treatment to Mr. Bennett in addition to just an evaluation.

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186. These representations were the main reason why Judge Peter Southworth found Mr. Bennett
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et
incompetent to stand trial. No other evaluations were used.

i
187. Mr. Bennett suffered extreme emotional distress, was denied his right to face his accuser,
me
denied his right to a jury trial, lost clients and was humiliated because of these representations.
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188. Dr. Jakubowski knew that these representations were false.
COUNT IX: CONSTRUCTIVE FRAUD
HNO

HN
NO
190. Dr. Jakubowski is a psychotherapist that was evaluating Mr. Bennett to determine
NO
competency.
NO
NO
191. This evaluation was ordered by the Sacramento County Superior Court.
23
192. Dr. Jakubowski had a duty to provide a true and accurate report to the Sacramento County
Superior Court.
N
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accused of a felony when he was accused of a misdemeanor, stating Mr, Bennett was a transient,
DH
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10 spurious and untrue.

11
12
13 194, Judge Peter Southworth of the Sacramento County Superior Court relied on these
- 14, representations and found Mr. Bennett incompetent to stand trial based on these representations.
; 15
16 195. These representations were the main reason why Judge Peter Southworth found Mr. Bennett
“47 incompetent to stand trial. No other evaluations were used.
18
21
22 197. Dr. Jakubowski knew that these representations were false.
23
24 COUNT X: NEGLIGENT MISREPRESENTATION
25
28
24
competency.
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&-
Aun
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on
Superior Court.
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11 accused of a felony when he was accused of a misdemeanor, stating Mr. Bennett was a transient,
Br stating in her report Mr. Bennett had previously been diagnosed with psychiatric problems when
14 he had never been diagnosed with any psychiatric problem, including other things that were
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16
17 203. Dr. Jakubowski had no reasonable grounds to believe that these representations were true.
18
19 204. Judge Peter Southworth of the Sacramento County Superior Court relied on these
20 representations and found Mr. Bennett incompetent to stand trial based on these representations.
21
24
27
28 207. Dr. Jakubowski knew that these representations were false.
25
=
COUNT XI: DEFAMATION PER SE

NH
WY
FSF

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NY
competency.
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Superior Court.
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-| 212. Dr. Jakubowski included facts in her report that she submitted to the Sacramento County
RO
RO
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213. Dr. Jakubowski had no reasonable grounds to believe that these representations were true.
DB
26
NLD
WD
SF
HW
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217. The representations were made in a court of record and became public record.
oN
218. The representations were put on social media and reported and broadcast by Joshua
CoCo
Coleman, a journalist who had the court’s permission to record Austin’s hearings; the
@ BENNETT vsSACRAMENTO.com
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S&S
representations caused a large amount of damage to Mr. Bennett 's business and reputation,
—§|§
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which took more than 20 years to grow and difficult to ascertain, in addition to the above
NO
damages.
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COUNT XII: LIBEL PER SE
=
A

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competency.
NV
XRBRBRR
NY
NY NY
NY
Superior Court.
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27
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10
13
14- 226. These representations were the main reason why Judge Peter Southworth found Mr. Bennett
15. incompetent to stand trial. No other evaluations were used.
16
19
20 228. The representations were maid in a court of record and became public record.
21
22 229. The representations were put on social media and reported and broadcast by Joshua
23 Coleman, who had the court’s permission to record Austin’s hearings; the representations caused
24 a large amount of damage to Mr. Bennett 's business and reputation, which took more than 20
25 years to grow and difficult to ascertain, in addition to the above damages.

26
27 COUNT XII: SLANDER

28
28
230, Plaintiff re-alleges the allegations set forth in in the statement of facts and incorporates
competency.
NN
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10 Superior Court.
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11
12 234. Dr. Jakubowski made material misrepresentations in her oral court testimony including the
13 fact that the defendant was incompetent to stand trial.
14
15° 235. Dr. Jakubowski had no reasonable grounds to believe that these representations were true.
@ BENNETTvsSA
16
19
22
25
26 239. The representations were maid in a court of record and became public record.
27
28
29
NY
WY
FSF
damages.
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COUNT XIV: FALSE LIGHT

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12
13 242. Dr. Jakubowski is a psychotherapist that was evaluating Mr. Bennett to determine
14 competency.
i>
. 16 243. This evaluation was ordered by the Sacramento County Superior Court.
17
18 244. Dr. Jakubowski had a duty to provide a true and accurate report to the Sacramento County
19 Superior Court.
20
21 245. Dr. Jakubowski included facts in her report that she submitted to the Sacramento County
23 accused of a felony when he was accused of a misdemeanor, stating Mr. Bennett was a transient,
25 stating in her report Mr. Bennett had previously been diagnosed with psychiatric problems when
26 he had never been diagnosed with any psychiatric problem, including other things that were
27 spurious and untrue.
28
30
= 246. Dr. Jakubowski portrayed Mr. Bennett as a mentally incompetent transient who had been
accused of a felony, who was unmarried and had psychiatric problems.
NYO
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247. The portrayal was false.

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250. These representations were the main reason why Judge Peter Southworth found Mr. Bennett!
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252. The representations were maid in a court of record and became public record.
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NY
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NY
damages.
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NY
Fe
NY
¢ : PERSONAL INJURY
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NY NY
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31

NY
WY
255. Dr. Jakubowski is a psychotherapist who was evaluating Mr. Bennett to determine
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competency.
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Co
Superior Court.
258. Dr. Jakubowski made material misrepresentations in her oral court testimony including the
fact that the defendant was incompetent to stand trial.

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‘| 259. Dr. Jakubowski had no reasonable grounds to believe that these representations were true.
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NO
KN
NO
NO
263. The representations were maid in a court of record and became public record.
32
NY
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damages.
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UNT XVI: NEGLIGENT UNDERT. G

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266. Dr. Jakubowski offered Mr. Bennett the opportunity to undergo a psychological evaluation.
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-| 267. Mr. Bennett refused to participate in the psychological evaluation.
268. Dr. Jakubowski decided to advance the theory that Mr. Bennett was incompetent to stand
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trial.
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269. The court relied on the representation in order to find Mr. Bennett incompetent to stand
B&B
HNO
trial.
HN
BRR
NO
270. These representations caused Mr. Bennett to ultimately be found incompetent.

HNO
NHN
QeRBaR
NO
NO
272. There was no basis for these representations.

2
33
273. Dr. Jakubowski decided to make these representations on her own.
WN
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COUNT XVII: NEGLIGENT SELECTION OF A CONTRACTOR

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275. The Sacramento County Superior court hired and retained Dr. Jakubowski to perform
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10 mental evaluations.
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11
12 276. Dr. Jakubowski provided a false report to the court and wrote false information in her
13 report.
14
15:
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277. Dr. Jakubowski found Mr. Bennett incompetent to stand trial with no basis.
16
17 278. The Sacramento County Superior Court should have known that the work that Dr.
18 Jakubowski did was substandard and false, because the report that Dr. Jakubowski wrote said
19 that Mr. Bennett was accused of a felony when he was not.
20
21 279. The Sacramento County Superior Court should have know that the work that Dr.
22 Jakubowski did was substandard and false because the report Dr. Jakubowski wrote said that Mr.
23 Bennett was unmarried when Mr. Bennett ’s wife was in the court room.
24
25 280. Dr. Jakubowski’s unfitness harmed Mr. Bennett by causing Mr. Bennett to be found
26 incompetent to stand trial, causing Mr. Bennett to lose his right to a trial by jury and question his
27 accusers.
28
34
281. Dr. Jakubowski’s unfitness harmed Mr. Bennett because Mr. Bennett suffered a loss of
reputation in the community, lost clients and stopped receiving referrals to his financial planning
N
business by large financial institutions, which regularly did.

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282. The Sacramento County Superior court’s hiring of Dr. Jakubowski was a substantial factor
an
in causing Mr. Bennett these harms.

NH
IN
283. If the Sacrament County Superior court would have hired an honest psychologist, Mr.
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Bennett would not have been found incompetent and suffered any of the above.
Co
10
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11 CoO XVIII: NEGLIGENT HIRING, RETENTION & SUPERVISION

12
-14- same herein by reference.
1S”
@ BENNETTvsSA
16 285. The Sacramento County Superior court hired and retained Dr. Jakubowski to perform
18
19 286. Dr. Jakubowski provided a false report to the court and wrote false information in her
20 report.
21
22 287. Dr. Jakubowski found Mr. Bennett incompetent to stand trial with no basis.
23
24 288. The Sacramento County Superior Court should have known that the work that Dr.
25 Jakubowski did was substandard and false because the report that Dr. Jakubowski wrote said that
26 Mr. Bennett was accused of a felony when he was not.
27
28
35
289. The Sacramento County Superior Court should have know that the work that Dr.
=
Jakubowski did was substandard and false because the report Dr. Jakubowski wrote said that Mr.
NY
Bennett was unmarried when Mr. Bennett ’s wife was in the court room.
WY
FP
290. Dr. Jakubowski’s unfitness harmed Mr. Bennett by causing Mr. Bennett to be found
eH
incompetent to stand trial, causing Mr. Bennett to lose his right to a trial by jury and question his
Hn
accusers.
ony
291. Dr. Jakubowski’s unfitness harmed Mr. Bennett, because Mr. Bennett suffered a loss of
oOo
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business.
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COUNT XIX: PUBLIC ENTITY: FAILURE TO DISCHARGE A MANDATORY DUTY

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NO
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295. The California Constitution Article 1 Section 7 States: A person may not be deprived of
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life, liberty, or property without due process of law or denied equal protection of the laws.
WN
N
nN
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296. Section 16 States: Trial by jury is an inviolate right and shall be secured to all.
N
~_
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36
297. The job of the Superior Court is to conduct trials in a way where the rights stated above are
not violated.
WN
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298. Mr. Bennett ’s rights as stated above were violated.

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299. Mr. Bennett was denied his right to a trial by jury.

NN
on
300. Mr. Bennett has a property interest in his reputation.

oOo
10 301. When the Sacramento County Superior court failed to discharge the duty of carrying out a
11 trial by jury and a proper competency trial Mr. Bennett ’s property interest in his reputation was
12 harmed.
13
14 302. If the Sacramento County Superior court would have discharged their duty according to
"15° California law Mr. Bennett ’s property interest in his reputation would not have been harmed.
16
17 COUNT XX: PUBLIC ENTITY: ACTS AND OMISSIONS OF EMPLOYEES
18
21
22 304. California government code section 815.4 states “815.4. A public entity is liable for injury
23 proximately caused by a tortuous act or omission of an independent contractor of the public
24 entity to the same extent that the public entity would be subject to such liability if it were a
25 private person.
26
27 305. The Sacramento County Superior court hired and retained Dr. Jakubowski to perform
37
306. Dr. Jakubowski provided a false report to the court and wrote false information in her
NY
report.
BY
Se
307. Dr. Jakubowski found Mr. Bennett incompetent to stand trial with no basis.
HW
DBD
308. The Sacramento County Superior Court should have known that the work that Dr.
Nt
Jakubowski did was substandard and false because the report that Dr. Jakubowski wrote said that
fo
Mr. Bennett was accused of a felony when he was not.

Co
com
—_
309. The Sacramento County Superior Court should have know that the work that Dr.
—
Jakubowski did was substandard and false because the report Dr. Jakubowski wrote said that Mr.
—_
Bennett was unmarried when Mr. Bennett ’s wife was in the court room.
_
‘
—
@ BENNETTvsSAC
"| 310. Dr. Jakubowski’s unfitness harmed Mr. Bennett by causing Mr. Bennett to be found
—_
incompetent to stand trial, causing Mr. Bennett to lose his right to a trial by jury and question his
_
accusers.
_
—
311. Dr. Jakubowski’s unfitness harmed Mr. Bennett because Mr. Bennett suffered a loss of
—_
N
business.
No
N
N

N
38
WN COUNT XXI: NEGLIGENCE
>wo

NON
315. Dr. Jakubowski did not do what a reasonable, ordinary psychotherapist would do evaluating
Mr. Bennett . Her conduct deviated from the appropriate standard of care because she included
Nt
false facts in her report. Because of this, Plaintiff's reputation was ruined, Mr. Bennett’s
Oo
business was harmed and Mr. Bennett lost the opportunity to exercise his right to a trial by jury.
uo
10
11 COUNT XXII: LOSS OF CONSORTIUM

12
7 ga
16 317. Dr. Jakubowski represented to Sacramento County Superior Court under penalty of perjury
17 false facts as described above.
18
19 318. Dr. Jakubowski made these representations recklessly and without regard for the truth of
20 these representations.
21
22 319. Judge Peter Southworth of the Sacramento County Superior Court intended to rely on these
23 representations to determine Mr. Bennett 's competency to stand trial.
24
27
28
39
321. Austin Bennett and Caryn Bennett are married to each other and have been married since
January 28, 1997

NO
WD
322. Caryn Bennett suffered extreme emotional distress and embarrassment, believing that her
FP
husband Austin may be institutionalized and was found incompetent to stand trial.
DH
DN
323. This put a strain on the relationship between Caryn Bennett and Austin Bennett .
NA
fo
324. This caused Caryn Bennett and Austin Bennett o become further apart and spend less time
oo
together because of this.

—_
iy
325. The strain on the relationship between Caryn Bennett and Austin Bennett would not have
—
happened if Dr. Jakubowski would not have made false representations in her report.
—
_—
COUNT XXIII: INTENTIONAL MISREPRESENTATION

ind
—
—

—
—
327. Dr. Jakubowski represented to Sacramento County Superior Court under penalty of perjury
N
false facts as described above.

nN
328. Dr. Jakubowski made these representations recklessly and without regard for the truth of
these representations.
329. Judge Peter Southworth of the Sacramento County Superior Court intended to rely on these
representations to determine Mr. Bennett 's competency to stand trial.
40
N
ww
>_>
MN
ND
oe
Co
10 333. Mr. Bennett contacted Dr. Jakubowski and Dr. Jakubowski apologized for her actions but
11 did not inform Sacramento County Superior Court that what she put in her report was false.
12
13 334. “False representations made recklessly and without regard for their truth in order to induce
14 action by another are the equivalent of misrepresentations knowingly and intentionally uttered.”
15° (Engalla, supra, 15 Cal.4th at p. 974, quoting Yellow Creek Logging Corp. v. Dare (1963) 216
16 Cal. App.2d 50, 55 [30 Cal. Rptr. 629]
17
18 Non-Punitive Damages
19
20 Mr. Bennett is asking for $31,328,177. This includes damages for pain and suffering, emotional
21 distress, loss of reputation, loss of earning capacity, loss of clients and the destruction done to
22 Mr. Bennett’s business. If Dr. Jakubowski did not write her fraudulent report Mr. Bennett would
23 have been enjoying the most fruitful years of his career and a successful business. At 57 years
24 old (at the time Dr. Jakubowski fabricated her report) As a money manager the destruction of
25 Mr. Bennett’s reputation is equivalent to the destruction of his business. Nobody would want
26 someone, who even has a chance of being crazy managing their money. Mr. Bennett had 13-15
27 of the most profitable years remaining in his business. Additionally at retirement Mr. Bennett
28 could have sold his Investment Firm Bennett FS for a multiple of the income. The amount of
41
= $31,328,177 is justifiable considering a loss of earnings for 13-15 years, the loss of what Mr.
Bennett would have been able to sell his Investment firm for as well as all the other damages.
NH
WY
FSF
UH
Punitive damages should be awarded because this is a clear case of fraud, oppression and malice.
DH
A corrupt psychologist wielded the court system as a weapon to destroy Mr. Bennett’s
NY
reputation, career without regard to the harm that this would do to Mr. Bennett. A psychologist
feo
trusted by the court to do a competency evaluation is trusted to present the truth to the court.
Co
Instead of presenting the truth, Dr. Jakubowski created a work of fiction, destroying Mr.
a
Bennett’s reputation, harming Mr. Bennett’s family relationships and making it difficult for Mr.
wee
Bennett to provide for his family. Per California Code Civ. Proc. § 425.13 Mr. Bennett is asking
_—
for punitive for all causes of action not related to professional negligence at this time.
_—
’
—
‘| Prayer For Relief

ms"
—
nt
Wherefore, Plaintiffs pray that this Court enter Judgment against Defendants, and each of them,
—
as follows:
root
A. For compensatory damages for the acts complained of herein, in an amount to be proven at
nN
trial;
N
B. For special damages as permitted by law;

N
C. For punitive damages as permitted by law.

N
D. For such pre- and post-judgment interest as permitted by law; and

E. For the finding of incompetence against Mr. Bennett to be found invalid and vacated
F. Recommendation of sanctions by the psychological board against Dr. Jakubowski
G. Referral to law enforcement for criminal charges against Dr. Jakubowski
H. For such other and further relief as the Court deems necessary or proper.
42
JURY DEMAND
WN
>wo
Austin Bennett demands a trial by jury on all issues.

GN
HN
IN
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10
11
12
13
14
15°
16
17
18
19
20
21
23
24
25
26
27
28
43

BENNETT VS JAKUBOWSKI Et Al.

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BENNETT VS JAKUBOWSKI Et Al.

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AUSTIN BENNETT

8013 MARSANNAY WAY

SUPERIOR COURT OF THE STATE OF CALIFORNIA

AUSTIN BENNETT, Case No.:

Plaintiff, BENNETT VS JAKUBOWSKI et al.

II. THE PARTIES. ............cccccccccccscscccccccccceccccenccesscesncceeseetcececceeccecesecesens 3-4

C. The Doe Defendants

11 Il. STATEMENT OF FACES .,..n.ccssesssasnsnssnsess

13 CLAIMS FOR RELIEP.................cccccccecesceecnscecceeesccsceeseeceseeceseceeeass 15

an OUR A ULE POPE) cresnnconsewnas vomguvxannngsssanadamisaacteons

26 OMG) EBTIOT chins snrcrmsdinencns sacoreeenmiian aemmanionens nen siannesSabeiperosormreswxcesese 29

2 Count XVII: (Negligent Selection of a Contractor)..............cccccececececececeseesessees 34

3 Count XVIII: igent Hiring, Retention & S USION).........sccceceecececseceeceees

4 Count XIX: (Public Entity: Failure To Discharge Mandatory Duty).....................36

. Count XXI: (Negligence)........c.sscessssessessssesssssssssucseesesseeeeseeneeeeeeaeenmees 39

8 Count XXIII: (Intentional Misrepresentation)................ccscceeseceseseeececcssssscseces 40

10 | 'V. NON-PUNITIVE DAMAGES. ...........scscssessessseessesseeeseeeunesenessneesseessesss 41

12 | VI. PUNITIVE DAMAGEG..............cccccccscccccccsccsccessccesecseccecesecesecasseecenves 42

: (a, | Wake © IRR Beet ie FREED prcseenavagesoccecdiovsinenes

16 | VIET. JURY DEMANDED. ...........c00ccccccccccecccseccseeecueeceeceseecaseeeeeeceuecsseae

18 Il. THE PARTIES

23 | residence is located in Sacramento County, CA.

27 | Sacramento, California 95825, United States South Building, Suite 210.

4. The Sacramento County Superior Court is a public entity.

C. The Doe Defendants

28 Ill. Statement of Facts

10 Chartered Life Underwriter designation.

13 27. Mr. Bennett wanted to exercise right to question his accuser.

competency evaluation on Mr. Bennett.

involved writing a fraudulent report.

10 Jakubowski made up a competency examination that was a work of fiction.

14 49. This was false.

ai 52. This was false.

23 53. Mr Bennett maintained a relationship with his two siblings.

2! 55. This was false.

58. This was false.

14 61. This was false.

representative and was frequently fired.

70. This was false.

relationships with his clients.

73. This was false.

74. Mr Bennett eves experienced paranoia.

75. Mr. Bennett does not use marijuana.

78. This was false.

79, Mr. Bennett was never paid in candy to shower.

82. This was false.

85. This was false.

87. Mr. Bennett never had auditory hallucinations or reported them.

88. Mr. Bennett never took psychotropic medication.

89. Mr. Bennett was never in a psychiatric hospital.

90. Mr. Bennett never had any of these symptoms.

91. Mr. Bennett never used methamphetamine.

97. Dr. Jakubowski fabricated past symptoms as well as present symptoms.

102. Dr. Jukubowski made a diagnosis of schizophrenia spectrum disorder.

Superior court under penalty of perjury.

25 affirmative defenses such as self defense.

he suffered extreme emotional distress.

believed that they would be institutionalized for mental health.

13 117. After being found incompetent Mr. Bennett lost clients.

Jakubowski's false report.

Bennett FS is extremely difficult to undo.

12 has built a solid reputation and customer base.

* 19" that he worked on since 1999.