BENNETT VS SACRAMENTO COUNTY JAIL Et Al.

Filed
' Superior Court of California,

Sacramento
AUSTIN BENNETT 3
8013 MARSANNAY WAY OTauizn23
SACRAMENTO CA, 95829 zeyaadn
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Tel: (916) 599-5142 By , Deputy

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In Pro Per 230 VG05472

ON
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.:

10
Plaintiff, BENNETT VS SACRAMENTO
11 COUNTY JAIL et al.
vs.
12
13 Sacramento County Jail;

Sacramento County;
14 Sacramento County Sheriff;
Sheriff Jim Cooper, an individual and in his
15 official capacity;
16 DOES 1 through 100;
17
Defendants.
18
19
20 Dated: July 20, 2023

21
22
23 AUSTIN BENNETT
24
25
26
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28
1
BENNETT VS SACRAMENTO COUNTY JAIL et al.
epsse RI& OU) ©
SUPE CALOIRF
F eh y
VENUE
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Venue is properly laid in Sacramento County because the defendants all maintain an office in
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this County where the plaintiff was harmed, the individual Defendants work and/or reside in this
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County, and the facts and circumstances giving rise to this lawsuit occurred in substantial part in
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this County.
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PARTIES
Plaintiff
10 Austin Bennett
11
Defendants
12
13 Sacramento County Jail
14 Sacramento County
15
Sacramento County Sheriff
16
Sheriff Jim Cooper, an individual and in his official capacity;
17
18 DOES 1 through 100. Plaintiffs allege at all times mentioned herein, the true names or
19 capacities, whether individual, corporate, associate, county or otherwise, of defendants DOES 1
20 through 100, inclusive, are unknown to Plaintiffs and therefore Plaintiffs sue these DOE
21 defendants by such fictitious names. Plaintiffs will amend this Complaint to allege their true
22 names and capacities when ascertained. Plaintiffs are informed and believe and based thereon
23 allege that each of these fictitiously-named defendants is responsible in some manner for the
24 occurrences herein alleged, and that Plaintiffs' damages as herein alleged were proximately
25 (legally) caused by their conduct.
26
27
28
2
Austin Bennett was taken to the Sacramento County Jail
Mr. Bennett was arrested by four officer on July 21, 2022, in the court room and taken to the
cage. From there he was remanded to the Sacramento County Jail.

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Mr. Bennett was placed in a room for many hours, with about a dozens other prisoners.
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One prisoner kept begging the guards to look up his wife’s number on his phone, because he did
10
not have it memorized.
11
12
13 He refused to leave when the guards ordered the group out. The guards were instructed to leave,
14 while the weeping man stayed behind.
15
16
The man pleaded with the guards, telling them his wife was homeless and she would be worried
17
sick if she did not know where he was. He said she was at risk.
18
19
20 The next day when Mr. Bennett was in his cell, he could see the man wheeled in in a wheelchair,
21 holding both hands up which looked visibly swollen. Apparently he could not walk.
22
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Upon arrival, Mr. Bennett was stripped naked and left to stand naked where the guard was
24
pointing at Mr. Bennett’s ileal pouch, and looking over to get the attention of other guards.
2
26
27
28
3
Mr. Bennett developed Crohn's Disease when he was in college in his 20s. Eventually at 29, he
had to have his colon removed.

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The guard was trying to embarrass and humiliate Mr. Bennett

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Mr. Bennett felt humiliated and upset.

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After humiliating Mr. Bennett the guard gave Mr. Bennett shoes that were 3 sizes too big.
10
11
12 Wearing shoes that are way too big creates a hazard for someone to trip and fall, especially in an
13 environment that regularly gets violent.
14
15
Mr. Bennett felt that they were trying to make him look like a clown, by giving him shoes that
16
were way too big after being humiliated.
17
18
19 Mr. Bennett who was a low risk inmate was housed in a cell with an inmate who was facing a
20 sentence of around 40 years, and a lifetime felon.
21
22
The inmate that Mr. Bennett was housed with was dealing with methamphetamine withdrawals.
23
24
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Mr. Bennett’s life and safety was put in danger because of being housed with this inmate.
26
27
The inmate told Mr. Bennett that he would get stabbed.
28
4
Mr Bennett was not given any pillow or sheet.
Mr. Bennett was given a blanket which was very coarse that poked and made him itchy.
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Mr. Bennett was locked down 24 hours per day, every day for the duration of his imprisonment,
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except for 25 minute breaks which were usually early morning.

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10
11 Mr. Bennett felt they buzzed him early in the morning, because most people would be sleeping
12 and not think Austin would be calling so early.
13
14
Mr. Bennett began to think he was being singled out to abuse.
15
16
17 Mr. Bennett thought Sheriff Jim Cooper may have given an order to mistreat Mr. Bennett.
18
19
When Mr. Bennett ran for the state senate and was a keynote speaker at an event at the Capitol,
20
Mr. Bennett stepped down when he learned Sheriff Cooper would be speaking.
21
22
Sheriff Cooper was assemblyman at the time.
23
24
25 When another speaker, a producer from Beverly Hills working on a documentary heard Mr.
26 Bennett stepped down and why, she also stepped down and the event was canceled.
27
28
5
> WW Mr. Bennett’s food tray was put on the floor for every single meal.
Mr. Bennett was accosted by inmate trustees when receiving his food and shouted out with
obscenities by not coming out of his door when the door was buzzed.
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Trays with what looks like slop, is put on the front of the doors and then the door buzzes and
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inmates are expected to push open the door, scurry for their tray and scamper back in.
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10
No one explained the rules to Mr. Bennett, which he politely explained to the trustee yelling at
11
Mr. Bennett.
12
13
14 The trustee told Mr. Bennett he was told expletives and the door slammed in his face.
15
16
Mr. Bennett would not feed the food he received to his dogs. It was usually liquidity and
17
sometimes Mr. Bennett could not recognize what he was eating and when he did, it didn’t taste
18
like the food he was eating.
19
20
21 Mr. Bennett could hear inmates in the mental ward screaming out in anguish.
22
23
Mr. Bennett asked for a replacement ileal pouches.
24
25
26 Mr. Bennett had to had stop eating after 2 days and was only drinking water because he was
27
concerned the guards were not responding and getting him needed medical supplies.
28
6
Mr. Bennett needed to replace his ileal pouch, and also needed barrier wipes, otherwise the
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digestive acidic output burns around the stoma with otherwise causes burn and bleeding, but the
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jail never provided him one.

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Mr. Bennett requires B12 everyday, and a change of ileal supply every two to three days. Mr.
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Bennett asked the guard every time when they made their rounds, but was promised without any
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result.
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10 Mrs. Bennett, who is a physical therapist, frantically called and emailed the jail multiple times,
11 but received no call back or email reply.
12
13
Mrs. Bennett sent a supply of vitamin B-12 and a Bible, because the jail refused to give Mr.
14
Bennett when he asked, but he received nothing.
15
16
17 The order came from Amazon, because that’s what was instructed.
18
19
Mr. Bennett asked for a Bible when he arrived, but was refused one.
20
21
22 Mr. Bennett heard another prisoner ask for a Bible, and he heard the trustee voice loudly say,
23 “You don’t need that fuckin book, you already have god in your heart!” The prisoner asked
24 again, but the voice responded the same way, “Believe me, you don’t need no damn book!”
25
26
The trustee offered the young man an alternative to the Bible, because the trustee had not
a
intention of getting him a Bible.
28
7
Mr. Bennett was finally given a book, but never given the Bible he asked for.
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Mr. Bennett had to settle for a fiction, to help keep his mind off the sense of torment he was
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enduring, wondering when his ileal pouch was going to come off. At the time, the barrier wears
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off and started to burn his skin. The digestive acids burn the skin to the point of bleeding, if the
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wafer is not replaced by two or three days. There was nothing Mr. Bennett could do, but pray it
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someone would bring him a supply.
10
11
Finally, when Mr. Bennett pushed the button, the guard who answered was extremely angry and
12
rude.
13
14
15 Mr. Bennett explained the situation to him, that he desperately need a change of colileal pouch
16 supplied vitamin B-12 and the guard kept saying he did not know what Mr. Bennett was talking
17 about. Finally the guard said, “You need a shit bag!” Why didn’t you tell me you needed a shit
18 bag!” 1”
How am I supposed to understand what you are saying?” “It’s called a shit bag!”
19
20
Mr. Bennett felt humiliated, degraded and was starting to feel weak. His body did not feel right
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anymore, which is the affects when he does not get enough vitamin B-12.
22
23
24
Mr. Bennett pleaded with the guard to get him supplies right away. The guard told Mr. Bennett
25
to take off his “shit bag” and he would get a supply.
26
27
28
8
Nobody ever came. Had Mr. Bennett listened to the guard, he would have suffered even more
distress, humiliation and torture.

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Mr. Bennett’s cellmate became so concerned for Mr. Bennett, he started banging on the door and
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kicking it.
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A guard came to the door, he explained to him what was going on. The guard said he would get
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someone right away, and again nobody showed up.

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10
11 Vitamin B-12, which plays an essential role in red blood cell formation, cell metabolism, nerve
12 function and the production of DNA.
13
14 Mr. Bennett’s physician prescribed and recommends Mr. Bennett to take it in the form of
15 injections.
16
17 Mr. Bennett’s started to feel sick, since his body needed vitamin B-12 desperately. His cellmate
18 kept calling out on Austin’s behalf.
19
20
21 Finally, Mr. Bennett was walked by a guard, around the fifth day to the nurses.
22
23
Mr. Bennett approached the counter, Mr. Bennett did so and while he spoke to the nurse, a guard
24
grabbed Mr. Bennett by the arm and yanked him back. Mr. Bennett did not see him coming.
25
26
27 The guard told Mr. Bennett, as he pulled him away like a child, that he was not to approach the
28 counter. However, Mr. Bennett had done as he was told.
9
He explained he desperately needed supplies, but even after that he still did not get them.
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Finally Mr. Bennett pushed the button he is warned not to, unless you are dying he was told, in
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order to let the guard he was in urgent need.

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Mr. Bennett was feeling so depleted and concerned he was not getting any change of his colileal
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10 supply and medical need, he felt like passing out.
11
12 Mr. Bennett was diagnosed with Crohn's disease, an inflammatory bowel disease, when he was
13 21 years old.
14
15
16 His mother was diagnosed with an inflammatory bowel disease and presently Mr. Bennett’s
17 daughter suffers from a form of Crohn's disease as well.
18
19
20 At 29 years of age, Mr. Bennett was required to have surgery to remove his colon.
21
22
23 Mr. Bennett’s primary physician, who was a part of Mr. Bennett’s surgery, who will also testify
24 on Mr. Bennett’s behalf, is aware of Mr. Bennett’s serious condition and medical requirements,
25 which were deprived of Mr. Bennett at the Sacramento County jail.
26
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28
10
Mr. Bennett did not receive an acceptable standard for the use of a toilet, due to depriving him of
his handicap and essential requirement for an alternate way to store and pass stool by refusing to
provide an ileal pouch for Mr. Bennett.

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There is little difference than a person in a wheel chair trying to go up stairs and though not
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impossible, essentially he can crawl up the stairs, the intent of the law was violated by the
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Sacramento County Jail.

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Mr. Bennett needed to replace his ileal pouch, and also needed barrier wipes, otherwise the
10
digestive acidic output burns around the skin with otherwise causes burn and bleeding, but the
11
jail never provided him one.
12
13
14 It was not until the sixth day, after Mr. Bennett came back from his hearing and was told he
1S would be released, the jail gave him a pouch, that did not fit.
16
17
Mr. Bennett told the nurse it would not fit, but she insisted that it would; however, it did not.
18
19
20
ZA The guards promised Mr. Bennett a new ileal pouch but Mr. Bennett never received a new ileal
22 pouch for the entire time he was in jail.
23
24
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Mr. Bennett explained that he need extra vitamins because of his surgery, because his body did
26
not produce those vitamins.
27
28
11
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Ww Mr. Bennett started to feel sick and weak and wanted to pray.
Mr. Bennett was not allowed to receive a bible, but was allowed to receive any other book.
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Inmates were only allowed to leave their cell 15 minutes each day.
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This prevented Mr. Bennett from contacting his family or calling attorneys.
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10
11 For the rest of the day Mr. Bennett was locked down in his cell unable to contact friends, his
12 family or find an attorney.
13
14
Mr. Bennett started to experiencing symptoms from being low in magnesium and vitamin B-12
15
16
17 Mr. Bennett was leaning against the wall bent over because he was feeling so sick.
18
19
Mr. Bennett was feeling so bad that his cellmate started yelling for help for Mr. Bennett.
20
21
22 Mr. Bennett was told that if he pushed the emergency button the television would be turned off
23 and the guard would announce who turned off the television and would have face reprisals from
24 other inmates.
25
26
The television left on for approximately 12 hours (Mr. Bennett did not have a clock so there was
27
28 no way to tell exactly and was not able to tell what time it was)
12
The volume of the television was causing irritation for Mr. Bennett's
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Mr. Bennett experienced headaches, migraines and cramps.

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NHN
The loud television was causing Mr. Bennett pain.

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10 Mr. Bennett was feeling so bad that he pushed the emergency button to get an ileal pouch and
11 the guard started lauging and making fun of Mr. Bennett and repeating and mocking Mr. Bennett
12 that he needed a “shit bag”
13
14
The guard told Mr. Bennett to take off his existing ileal pouch and that a new ileal pouchwould
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be on the way.
16
17
18 Mr. Bennett never received a new ileal pouch any time in the jail.
19
20
Tleal pouch are not designed to last for the time that Mr. Bennett was in jail.
21
22
23 Mr. Bennett got buzzed for a hearing around 7:30 in the morning.
24
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Mr. Bennett waited for his court hearing and nobody showed up.
26
28
13
Mr. Bennett pushed the emergency button because he was not being taken to his hearing and
nobody responded.
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Around 10 am someone to get Mr. Bennett arrived at court at 10:30 for his competency hearing.
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The bailiff announced that Mr. Bennett refused to come to his hearing.
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This made Mr. Bennett appear incompetent and insane.

10
11
12 Mr. Bennett was leaving that day, so he endured the trauma, hoping he would be released within
13 the hour.
14
15
However, it was not until late at night was Mr. Bennett released and picked up by his wife, who
16
brought supplies with her.
17
18
19
20 COUNT IV: INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS
21
22
Plaintiff re-alleges the allegations set forth in statements of facts - above and incorporates same
23
herein by reference.
24
25
26
27 When Mr. Bennett was held in the Sacramento County Jail he was subject to cruel
28 treatment that no one should have to endure.
14
A strip search in a jail is meant for security and not to shame or humiliate.
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FF
The guards in the jail started laughing and pointing at Mr. Bennett’s ileal pouch stoma
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while Mr. Bennett was naked as well as signaling for other guards to come and do the same.
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During Mr. Bennett’s stay another guard yelled “oh so you need a shit bag” at Mr.
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Bennett
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Mr Bennett was denied an ileal pouch for 6 days as well as necessary vitamins including
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Magnesium and B-12 Vitamin.

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Mr. Bennett suffered headaches, cramps and nausea because of this.

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Mr. Bennett was forced to stop eating after 2 days to prevent caustic gastric secretions
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from causing damage and bleeding to his stoma.

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NO
Because Mr. Bennett could not produce the normal vitamins from digestion and the fact
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that he was unable to eat Mr. Bennett also suffered symptoms of malnutrition.
NO
NO
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When a person is under extreme stress additional B vitamins are necessary making things
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worse.
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NO
2
15
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ileal pouches are only designed to last 2 days.
When they are constantly exposed to caustic gastric secretions and not changed the
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gastric secretions can cause the breakdown of the ileal pouch causing chemicals to enter Mr.
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Bennett’s system.
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This is made worse by the lack of B vitimins necessary to detox these chemicals.
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10
Mr. Bennett Suffered extreme emotional distress because of this.
11
12
13 The guards conduct at the Sacrament County jail was the only factor that caused this.
14
15
16
17 COUNT V: NEGLIGENT INFLICTION OF EMOTIONAL DISTRESS
18
19
Plaintiff re-alleges the allegations set forth in statements of facts - above and incorporates
20
same herein by reference.
21
22
When Mr. Bennett was held in the Sacramento County Jail he was subject to cruel treatment that
23
no one should have to endure.
24
25
26 A strip search in a jail is meant for security and not to shame or humiliate.
27
28
16
The guards in the jail started laughing and pointing at Mr. Bennett’s ileal pouch stoma
while Mr. Bennett was naked as well as signaling for other guards to come and do the same.
WN
Ww
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During Mr. Bennett’s stay another guard yelled “oh so you need a shit bag” at Mr.
WN
Bennett
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Mr Bennett was denied ileal pouches for 6 days as well as necessary vitamins including
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Magnesium and B-12 Vitamins.

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10
11
Mr. Bennett suffered headaches, cramps and nausea because of this.
[2
13
14 Mr. Bennett was forced to stop eating after 2 days to prevent caustic gastric secretions
15 from causing damage and bleeding to his stoma.
16
17
Because Mr. Bennett could not produce the normal vitamins from digestion and the fact
18
that he was unable to eat Mr. Bennett also suffered symptoms of malnutrition.
19
20
21 When a person is under extreme stress additional B vitamins are necessary making things
22 worse.
23
24
ileal pouches are only designed to last 2 days.
25
26
27
28
17
When they are constantly exposed to caustic gastric secretions and not changed the
gastric secretions can cause the breakdown of the ileal pouch causing chemicals to enter Mr.
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Bennett’s system.
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This is made worse by the lack of B-12 vitamins necessary to Mr. Bennett’s health.
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Mr. Bennett Suffered extreme emotional distress because of this.

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10
The guards conduct at the Sacrament County jail was the only factor that caused this.
11
12
13 COUNT VI: ABUSE OF PROCESS
14
15
16
17
18
19 When the jail was supposed to take Mr. Bennett to his competency hearing instead of
20 taking Mr. Bennett, the jail left Mr. Bennett in his cell.
21
22
The jail told the court that Mr. Bennett refused to go to his competency hearing.
23
24
25 Mr. Bennett wanted to go to his competency hearing to dispute the incompetence claims.
26
27
28
18
Because Mr. Bennett was unable to go to his competency hearing he was unable to
dispute the claims of incompetence against him.

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Refusing to go to a competency hearing can make a person look more incompetent.

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HN
This contributed to Mr. Bennett being found incompetent.

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Not being able to go to a competency hearing and not having a voice was a substantial
10
factor in Mr. Bennett’s being found incompetent.
11
12
13 Being found mentally incompetent was humiliating for Mr. Bennett.

14
15
After being found incompetent Mr. Bennett stopped receiving referrals from financial
16
institutions.
17
18
19 After being found incompetent Mr. Bennett lost clients.

20
21
Most people would not want a financial planner who has been incompetent to stand trial.
22
23
24 Being found incompetent made it extremely difficult for Mr. Bennett to get new clients.
25
26
27 After being found incompetent Mr. Bennett’s business BennettFS stopped growing and started to
shrink.
28
19
Mr. Bennett as well as BennettF'S have suffered irreparable harm from being found incompetent.
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Being found incompetent put a strain on Mr. Bennett’s marriage and traumatized his wife and
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children.
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COUNT XXII: CONCEALMENT

10
11
12 Plaintiff re-alleges the allegations set forth in statements of facts - above and incorporates
13 same herein by reference.
14
15
When the jail was supposed to take Mr. Bennett to his competency hearing instead of
16
taking Mr. Bennett, the jail left Mr. Bennett in his cell.
17
18
19 The jail told the court that Mr. Bennett refused to go to his competency hearing.
20
21
The jail knew that Mr. Bennett was still in his cell.
22
23
24 The jail intentionally concealed the fact that Mr. Bennett tried to attend his competency
25 hearing and was not refusing to go to his competency hearing.
26
27
28
20
The jail intended to deceive the Sacramento County Superior Court and did in fact
deceive the court, making the court believe that Mr. Bennett was refusing to go to his
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competency hearing.
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The Sacramento County jail prevented Mr. Bennett from contacting the cour by keeping
him locked in a cell.

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If the jail would have told the court that Mr. Bennett was not refusing to go to his
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10 competency hearing the court would not have proceeded without Mr. Bennett.
11
12
Mr. Bennett wanted to go to his competency hearing to dispute the incompetence claims.
13
14
15 Because Mr. Bennett was unable to go to his competency hearing he was unable to
16 dispute the claims of incompetence against him.
17
18
19
20
21 This contributed to Mr. Bennett being found incompetent.

22
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24
factor in Mr. Bennett’s being found incompetent.
25
26
27
Being found mentally incompetent was humiliating for Mr. Bennett.
28
21
institutions.
After being found incompetent Mr. Bennett lost clients.

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10
12
13
After being found incompetent Mr. Bennett’s business BennettFS stopped growing and started to
14
shrink.
15
16
17 Mr. Bennett as well as BennettF'S have suffered irreparable harm from being found incompetent.
18
19
20
children.
21
22
23
24
COUNT VII: INTENTIONAL MISREPRESENTATION
25
26
28
22
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The jail told the court that Mr. Bennett refused to go to his competency hearing.
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DN
The jail knew that Mr. Bennett was still in his cell.
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10
11
12 Because Mr. Bennett was unable to go to his competency hearing he was unable to
13 dispute the claims of incompetence against him.
14
15
16
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18 This contributed to Mr. Bennett being found incompetent.

19
20
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factor in Mr. Bennett being found incompetent.
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23

25
26
27
institutions.
28
23
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Being found incompetent made it extremely difficult for Mr. Bennett to get new clients.
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il shrink.
12
13
14
15
16 Being found incompetent put a strain on Mr. Bennett’s marriage and traumatized his wife and
17 children.
18
19
COUNT VIII: CONSTRUCTIVE FRAUD
20
21
24 The Sacramento County Superior Court reasonably relies on what the Sacramento
25 County Jail says about prisoners in the custody of the jail.
26
27
28
24
The Sacramento County Jail has a duty to be truthful to the Sacrament County Superior
Court when asked about inmates.

WN
-WwW
The Sacramento County Jail acted on Mr. Bennett’s behalf in saying that Mr. Bennett
MN
refused to come to court.

DBD
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Mr. Bennett did not refuse to come to court.

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10
Mr. Bennett wanted to go to court.
11
12
13 The jail knew or should have known that Mr. Bennett wanted to go to court based on the
14 fact that Mr. Bennett got up and prepared to go to court.
15
16
The jail knew or should have known that Mr. Bennett wanted to go to court based on the
17
fact that Mr. Bennett pushed the Emergency Button to ask the jail why they were not taking him
18
to court.
19
20
ZA The jail should not have misrepresented the truth to the Sacrament County Superior
22 court.
23
24
Because of this misrepresentation Mr. Bennett was not able to attend his own
25
competency hearing.
26
21
28
25
Because Mr. Bennett was not able to attend his own competency hearing he was not able
to defend his competency.

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WwW
-_
Mr. Bennett was found incompetent because of this.

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HD
Being found incompetent was humiliating for Mr. Bennett's

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Being found incompetent harmed Mr. Bennett’s reputation as well as his business.
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10
11
12
13 COUNT IX: NEGLIGENT MISREPRESENTATION
14
15
16
17
18
19
20
21
22 The jail told the court that Mr. Bennett refused to go to his competency hearing.
23
24
Even if the jail believed what they were saying was true. Mr. Bennett woke up, prepared
25
to go to court and pushed the emergency button in order to call a guard to take Mr. Bennett to
26
court.
27
28
26
WN
-WY
Because Mr. Bennett was unable to go to his competency hearing he was unable to
dispute the claims of incompetence against him.

MN
NH

SN
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This contributed to Mr. Bennett being found incompetent.

10
11
12 Not being able to go to a competency hearing and not having a voice was a substantial
13 factor in Mr. Bennett being found incompetent.
14
15
16
17
18 After being found incompetent Mr. Bennett stopped receiving referrals from financial
19 institutions.
20
21
22
23
24 Most people would not want a financial planner who has been incompetent to stand trial.
25
26
27
28
27
shrink.
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children.
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COUNT X: DEFAMATION PER SE

10
11
[2 Plaintiff re-alleges the allegations set forth in statements of facts - above and incorporates
14 The Sacramento county jail told The Sacramento County Superior Court that Mr. Bennett
15 refused to come to his competency hearing.
16
17
This was false. Mr. Bennett, woke up and got ready to go to his competency hearing.
18
19
20 Mr. Bennett pushed the emergency button when he was not taken to his competency
Zi hearing to try and ask why he was not being taken to his competency hearing.
22
23
Mr. Bennett wanted to go to his competency hearing to defend his competency.
24
25
26
The Sacramento County Court relied upon the jail’s representation and proceeded
27 without Mr. Bennett.
28
28
The Sacramento County jail should not tell the court that someone refuses to go to a
hearing that the person wants to go to.
Because Mr. Bennett was unable to go to his competency hearing Mr. Bennett was
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unable to defend his competency and was found incompetent.

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fo
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10
11
12 After being found incompetent Mr. Bennett stopped receiving referrals from financial
13 institutions.
14
15
16
17
19
20
21
22
24 shrink.
25
26
27
28
29
children.
N
-Ww
WN
COUNT X: SLANDER
HN
NHN
eo
oo

10
The Sacramento County jail was responsible for making sure that Mr. Bennett could
11
attend his court hearings.
12
13
14 Mr. Bennett was scheduled for a competency hearing.
15
16
Mr. Bennett wanted to go to his Mr. competency hearing to defend his competency.
17
18
19 Instead of taking Mr. Bennett to his competency hearing the Sacrament County Jail left
20 Mr. Bennett locked in his cell.
21
22
The Sacramento County Jail told Judge Peter Southworth of the Sacramento County
23
Superior Court that Mr. Bennett refused to go to the hearing.
24
25
26 By telling the court that Mr. Bennett refused to go the jail made Mr. Bennett appear not
27 to care about the competency proceedings.
28
30
It was not true that Mr. Bennett refused to go to his competency hearing.
ND
-Ww
Mr. Bennett got ready to go and wanted to go to his competency hearing.

WN
NH
NN
Mr. Bennett wanted to defend his competency.

Oo
o
10 This false representation made Mr. Bennett look bad because the court thought that he
11 refused to go to his hearing.
12
13
The court proceeded without Mr. Bennett.
14
15
16 Mr. Bennett was found incompetent.
17
18
If Mr. Bennett was able to go to his competency hearing he would have been able to
19
defend his competency.
20
21
22 If Mr. Bennett was able to go to his competency hearing he would have appeared more
23 interested in the court process and would have appeared more respectful of the court process.
24
25
Mr. Bennett was ultimately found incompetent.
26
Zz]
31
ND
Ww
institutions.
>
WN

HN
NN
Oo
oo
10
12
13
14
shrink.
15
16
17 Mr. Bennett as well as BennettF'S have suffered irreparable harm from being found incompetent.
18
19
20
children.
21
22
23
24 COUNT XII: FALSE LIGHT

25
26
ZI Plaintiff re-alleges the allegations set forth in statements of facts - above and incorporates

28
32
The Sacramento County jail was responsible for making sure that Mr. Bennett could attend his
WN
court hearings.
>WwW
MN
Mr. Bennett was scheduled for a competency hearing.

onDH
Mr. Bennett wanted to go to his Mr. competency hearing to defend his competency.
uo
10
Instead of taking Mr. Bennett to his competency hearing the Sacrament County Jail left
11
Mr. Bennett locked in his cell.
12
13
14 The Sacramento County Jail told Judge Peter Southworth of the Sacramento County
15 Superior Court that Mr. Bennett refused to go to the hearing.

16
17
By telling the court that Mr. Bennett refused to go the jail made Mr. Bennett appear not
18
to care about the competency proceedings.
19
20
21 By telling the court that Mr. Bennett refused to go to his competency hearing the jail
22 portrayed Mr. Bennett as someone who had a lesser appreciation of the court system than Mr.
23 Bennett had.
24
25
Refusing to go to a court hearing can have sever consequences.
26
27
28
33
The jail knew that making this kind of false representation would have negative
consequences for Mr. Bennett.
N
WwW
&
It was not true that Mr. Bennett refused to go to his competency hearing.
wn
DN
Mr. Bennett got ready to go and wanted to go to his competency hearing.

sn
oo
Co
Mr. Bennett wanted to defend his competency.

10
11
12 This false representation made Mr. Bennett look bad because the court thought that he
13 refused to go to his hearing.
14
15
The court proceeded without Mr. Bennett.
16
17
18 Mr. Bennett was found incompetent.
19
20
If Mr. Bennett was able to go to his competency hearing he would have been able to
21
defend his competency.
22
23
24 If Mr. Bennett was able to go to his competency hearing he would have appeared more
25 interested in the court process and would have appeared more respectful of the court process.
26
27
Mr. Bennett was ultimately found incompetent.
28
34
WN
WwW
-_
WN
institutions.
DN
SN
Oo

Co
10
12
13
14
15
17 shrink.
18
19
Mr. Bennett as well as BennettFS have suffered irreparable harm from being found incompetent.
20
21
22 Being found incompetent put a strain on Mr. Bennett’s marriage and traumatized his wife and
23 children.
24 COUNT XIII: PERSONAL INJURY

25
26

28
35
While in the custody of the Sacramento County Jail, Mr. Bennett was prevented from
NY
receiving vitamins that he needed because of his medical condition.

WwW
-_
WN
While in the custody of the Sacramento County jail Mr. Bennett was prevented from
HN
receiving new ileal pouches.

SN
Oo
Because Mr. Bennett did not receive new ileal pouches he was unable to eat.
co
10
11
Because Mr. Bennett was unable to eat and did not receive the vitamins that he needed
12
Mr. Bennett suffered headaches, nausea, cramping and well as malnutrition.
13
14
15 Mr. Bennett’s wife tried to provide the jail with ileal pouches and Mr. Bennett’s vitamins
16 but the jail would not give Mr. Bennett his critical medical supplies.
17
18
If the jail would have provided Mr. Bennett his critical medical supplies Mr. Bennett
19
would not have suffered headache, nausea, cramping or malnutrition.
20
21
22
23 COUNT XVI: NEGLIGENT HIRING, RETENTION & SUPERVISION
24
25
26
27
28
36
The Sacramento County Jail is responsible for hiring and retaining guards and medical staff in
it’s jail.
N
Ww
&
The guards in the jail were unfit to act as jail guards because one battered Mr. Bennett
vA
while he was trying to receive medical care.

NN
The guards in the jail were unfit to act as medical guards because they humiliated Mr.
oOo
Bennett because of his medical condition.

Co
10
11
The medical staff in the jail were unfit to act as medical staff because they wanted Mr.
12
Bennett to use an ileal pouch that was too small.
13
14
15 If Mr. Bennett would have done this he would have had caustic gastric secretions burning
16 his stoma and skin.
17
18
The Sacramento county jail should know what is going on inside the jail.
19
20
21 The Sacramento county jail is responsible for making sure that prisoners receive
Ze adequate medical care.
23
24
The Sacramento County jail is responsible for making sure that guards don’t arbitrarily
25
batter prisoners for no reason.
26
27
28
37
Because of this Mr. Bennett suffered headaches, nausea, cramps, malnutrition and was
battered by a jail guard when trying to receive medical treatment.

WN
Ww
++}
If the Sacramento County Jail would not have hired unfit jail guards and medical staff
vA
Mr. Bennett would have received the medical supplies that he needed.
A
yy
If the Sacramento County Jail would not have hired unfit guards Mr. Bennett would not
oo
have been battered when trying to receive medical help.

10
11
12
13 COUNT XVIII: PUBLIC ENTITY: ACTS AND OMISSIONS OF EMPLOYEES
14
15
Plaintiff re-alleges the allegations set forth in Paragraphs 1- above and incorporates same
16
17
18
19 California government code section 815.2 states “ A public entity is liable for injury
20 proximately caused by an act or omission of an employee of the public entity within the scope of
21 his employment if the act or omission would, apart from this section, have given rise to a cause
22 of action against that employee or his personal representative.”
23
24
California government code section 815.4 states “A public entity is liable for injury
25
proximately caused by a tortuous act or omission of an independent contractor of the public
26
entity to the same extent that the public entity would be subject to such liability if it were a
27
private person.
28
38
The Sacramento County jail hired and supervised the guards and medical staff that did
woWN
not
>
provide Mr. Bennett with his critical medical supplies.

WN
DH
The Sacramento County jail hired and supervised the guard that battered Mr. Bennett.
NHN
fe
oOo
The Sacramento County Jail hired and supervised the guards that humiliated Mr. Bennett
10
for having an ileal pouch when he was naked.
11
12
13 Mr. Bennett was in fact battered, humiliated and denied critical medical supplies while in
14 the custody of the Sacramento County Jail.
15
16
Mr. Bennett suffered headaches, cramps, nausea and malnutrition because of this.
17
18
19 Mr. Bennett was humiliated because of this.

20
21
The Sacramento County Jail’s hiring of these unfit employees and/or contractors was a
22
significant factor incausing the harms that Mr. Bennett suffered.
23
24
26
2)
28 COUNT XXI: GROSS NEGLIGENCE
39
NY
WwW

-&
na
Mr. Bennett was held in the Sacramento County Jail.

NHN
NI
fo
The jail is required to provide Mr. Bennett clean ileal pouches and necessary vitamins.
Co
10
11 Mr. Bennett’s wife Caryn tried to bring ileal pouches and vitamins to Mr. Bennett.
12
13
The jail did not allow Mr. Bennett to receive his vitamins and ileal pouches.
14
15
16 Because Mr. Bennett did not have clean ileal pouches he was unable to eat for 4 out of
17 the 6 days he was in jail.
18
19
20
21
22 The jail’s negligence in not providing ileal pouches the reason why Mr. Bennett was not
23 able to eat.
24
25
The jail’s negligence in not providing ileal pouches and Mr. Bennett’s vitamins was the
26
reason Mr. Bennett suffered headaches, cramps, nausea and malnutrition.
2
28
40
Wd
>Ww This was done with deliberately.
This was done with reckless disregard for the safety of Mr. Bennett.
MN
COUNT XXI: NEGLIGENCE

DH
SIN
Oo
Co

10
11
12 Mr. Bennett was held in the Sacramento County Jail.
13
The jail is required to provide Mr. Bennett clean ileal pouches and necessary vitamins.
14
15
16 Mr. Bennett’s wife Caryn tried to bring ileal pouches and vitimins to Mr. Bennett.
17
18
The jail did not allow Mr. Bennett to receive his vitamins and ileal pouches.
19
20
21 Because Mr. Bennett did not have clean ileal pouches he was unable to eat for 4 out of
22 the 6 days he was in jail.
23
24
25
26
27 The jail’s negligence in not providing ileal pouches the reason why Mr. Bennett was not
28 able to eat.
41
The jail’s negligence in not providing ileal pouches and Mr. Bennett’s vitamins was the
NY
Ww
reason Mr. Bennett suffered headaches, cramps, nausea and malnutrition.

-_
MN
COUNT XXII: LOSS OF CONSORTIUM

HN
NIN
fo
Co
10
11
Austin Bennett and Caryn Bennett are married to each other and have been married since
12
January 28, 1997
13
14
15 Caryn Bennett suffered extreme emotional distress knowing that her husband, Austin
16 Bennett was being abused in the jail.
17
18
Caryn Bennett tried to contact the jail to give the jail Austin’s ileal pouches and vitimins.
19
20
21 Being in the Bennett and being denied phone calls by only allowing Austin out of his cell
22 extremely early and denying Austin his vitamins and ileal pouches was extremely traumatic for
23 Caryn and Mr. Bennett.
24
25
The denial of vitamins and ileal pouches harmed Mr. Bennett’s health with further
26
traumatized Caryn.
27
28
42
This put a strain on the relationship between Caryn Bennett and Austin Bennett .
N
This caused Caryn Bennett and Austin Bennett 0 become further apart and spend less
WwW
time together because of this.

-&
vA
DN
The strain on the relationship between Caryn Bennett and Austin Bennett would not have
SI
happened if the jail had not have denied Mr. Bennett ileal pouches, the vitamins that he needed
Oo
for his health and allowed Mr. Bennett outside his cell to call at a time when he could reach his
Co
family.
10
11
12 Medical Negligence
13
14
15
16
17 When Mr. Bennett was in the custody of the Sacramento County Jail, the jail had a duty
18 to provide Mr. Bennett medical care.
19
20
Mr. Bennett needed Vitamins because his body could not produce them after having an
21
ileal pouch.
22
23
24 Mr. Bennett needed clean ileal pouches.

25
26
Mr. Bennett asked the nurses and guards in the jail for clean ileal pouches and his
27
vitamins.
28
43
The guards did not give Mr. Bennett clean ileal pouches or vitamins.
N
WwW
-&
The nurses offered Mr. Bennett a clean ileal pouch that was too small and Mr. Bennett
vA
was unable to use the ileal pouches that were too small.
NN
Oo
Because of this Mr. Bennett had to stop eating in order to prevent caustic gastric
Co
secretions from burning his stoma and causing bleeding.

10
11
12 Because of this Mr. Bennett suffered nausea, cramping, headaches and malnutrition.
13
14
Because of this Mr. Bennett suffered health problems.
15
16
17 Mr. Bennett was held in the Sacramento County Jail.
18
19
Mr. Bennett had part of his colon removed due to a medical condition.
20
21
Mr. Bennett was laughed at and humiliated while naked because of his medical
22
condition.
23
24
25 Mr. Bennett was humiliated when a guard asked him if he needed a “shit bag” because of
26 his medical condition.
27
28
44
A guard though it would be funny to tell Mr. Bennett that he would receive a new ileal
pouch if he removed his existing ileal pouch, only to never give Mr. Bennett a new ileal pouch.
WN
-Ww
Mr. Bennett was battered by a guard while trying to receive help at a nurses station for
UN
his medical condition.

NHN
NTN
Mr. Bennett was denied the chance to eat while in jail or denied vitamins that he needed.
Oo
oOo
10
Mr. Bennett’s medical condition was the reason for the humiliation and shaming that Mr.
11
Bennett received at the jail.
12
13
14 The guard’s behavior show that a big motivation for this cruel treatment was Mr.
15 Bennett’s medical condition.
16
17
People with other medical conditions receive the medical care that they need while held
18
in the jail.
19
20
21 Mr. Bennett suffered headaches, cramps, nausea and malnutrition because the jail
22 discriminated against him and though that it was entertaining to deny Mr. Bennett the supplies
23 and vitamins that needed for his medical condition.
24
25
26
27 Battery
28
45
N
>
NWw
When Mr. Bennett went to the nurses station to request an ileal pouch a guard came up
HDH
and unexpectedly grabbed Mr. Bennets arm and pulled him away and told Mr. Bennett not to go
Nn
to the nurses station.

Oo
oo
10
This hurt Mr. Bennett’s arm and offended Mr. Bennett.
11
12
13 A reasonable person asking for medical help at a nurses station would be offended by a
14 guard (or security) guard grabbing them and pulling them away.
15
16
Just because a person is being held in a jail does not give the guards the right to assault
17
and better them for no reason.
18
19
20 Attempted Medical Battery
21 When Mr. Bennett was in jail the guard told Mr. Bennett to remove his ileal pouch bad
23 and that another ileal pouch was coming.
23
24
Instead of a never ileal pouch coming it never came.
25
26
27
28
46
Removing an ileal pouch for an extended period of time is a medical procedure that
causes caustic stomach secretions to leak out of the stoma of the ileal pouch and can cause,
N
bleeding scarring and disfigurement.

Ww
>_
MN
This is made worse when someone is confined to a jail cell and does not have access to
NHN
basic medical supplies.
Although the jail guards may have though that Mr. Bennett’s medical condition was a
fe
joke the consequences of what what they were trying to do was not a joke.
Co
10
11
Practicing Medicine Without A License
12
13
16
17 When held in the Sacramento County Jail the a guard tried to get Mr. Bennett to remove his ileal
18 pouch without ever providing a replacement.
19
20
Removing an ileal pouch for an extended period of time is a medical procedure that
21
causes caustic stomach secretions to leak out of the stoma of the ileal pouch and can cause,
22
bleeding scarring and disfigurement.
23
24 Telling someone to remove an ileal pouch without a replacement is something that
25 should only be done by a doctor for a valid medical reason.
26
27
28
47
Removing an ileal pouch would be as detrimental as disabling a pacemaker or similar
electronic device.
WN
WwW
>_
Removing an ileal pouch could disfigure Mr. Bennett and damage the stoma preventing
WN
digestion and could cause the stoma to dry out or get infected requiring surgery.
NHN
tN
The guard who told Mr. Bennett to remove his ileal pouch was acting as a physician and
Oo
not a jail guard.

oOo
10
11
12
13 COUNT XIV: NEGLIGENT UNDERTAKING
14
15
16
17
18
The public defender’s office offered Mr. Bennett legal representation.
19
20
21 The DEFENDANT then decided to advance the theory that Mr. Bennett was incompetent
22 to stand trial.
23
24
The court relied on the legal representation in order to find Mr. Bennett incompetent to
25
stand trial.
26
27
28
48
N
Ww These representations caused Mr. Bennett to ultimately be found incompetent.
Mr. Bennett suffered extreme emotional distress, was denied his right to face his
-»-
accuser, denied his right to a jury trial, lost clients and was humiliated because of these
un
representations.
NN
nN
The DEFENDANT was not asked by Mr. Bennett to make these representations.
Oo
Co
10
The DEFENDANT decided to make these representations on their own with no basis.
11
12
13 Violation of the Bane Act

14
15
16
17
18 The Bane Civil Rights Act (California Civil Code Section 52.1) forbids anyone from
19 interfering by force or by threat of violence with your federal or state constitutional or statutory
20 rights. The acts forbidden by these civil laws may also be criminal acts, and can expose violators
21 to criminal penalties.
ZZ
23 The Bane Act provides protection from threats, intimidation, or coercion and for attempts
to interfere with someone’s state or federal statutory or constitutional rights.
24
25
When Mr. Bennett transported from jail to his court hearing, on July 26, 2022,
26
DEFENDANT Juan Contreras took Mr. Bennett to the side room.
27
28
49
DEFENDANT Contreras, who was wearing a mask although no longer a COVID
requirement at the time, told Mr. Bennett he was his new attorney.
WN
Ww
DEFENDANT Contreras told Mr. Bennett he was the supervisor of DEFENDANT

-_-
Melody Aguilar, and would be replacing her.

NN
HN
DEFENDANT Contreras told Mr. Bennett his case would be dismissed, then threatened
Mr. Bennett.
SN
Oo
DEFENDANT Contreras warned Mr. Bennett if he pursued a jury trial trial, that instead
Co
10 of having his case dismissed, Mr. Bennett would be placed into the mental ward.
11
12 DEFENDANT Melody Aguilar threatened Mr. Bennett if he did see the doctor, he would
13 be arrested and lawfully could be taken to jail.
14
15 Since the order was not lawful, Mr. Bennett could not lawfully be arrested and taken to
jail.
16
17
DEFENDANT Amanda Massimini threatened Mr. Bennett that if he did see the doctor,
18
he would be remanded and lawfully could be taken to jail.
19
20
Since the order was not lawful, Mr. Bennett could not lawfully be arrested and taken to
Zl
jail.
22
23 DEFENDANT Massimini misrepresented the law to Mr. Bennett, to cause fear in order
24 to obey an order that was not lawful, with the threat of arrest.
25
26
27
Violation of the Ralph Civil Rights Act
28
50
WN
CIVIL CODE - CIV, DIVISION 1. PERSONS [38 — 86], PART 2. PERSONAL

WwW
RIGHTS [43 - 53.7

>_>
WN
51.7. (a) This section shall be known, and may be cited, as the Ralph Civil Rights Act of 1976.
HD
(b)(1) All persons within the jurisdiction of this state have the right to be free from any violence,
SS
or intimidation by threat of violence, committed against their persons or property because of

Oo
political affiliation, or on account of any characteristic listed or defined in subdivision (b) or (e)
So
10 of Section 51.(a) This section shall be known, and may be cited, as the Unruh Civil Rights Act.
li (e)The Legislature finds and declares that this section was enacted as part of the Ralph Civil
12 Rights Act of 1976, in Chapter 1293 of the Statutes of 1976.
13
14
15
16
17 Violation of the Unruh Civil Rights Act
18
19
20
21
Actions for damages and other relief for denial of rights; (a) Whoever denies, aids or
22
incites a denial, or makes any discrimination or distinction contrary to Section 51, 51.5, or 51 6,
23
is liable for each and every offense for the actual damages, and any amount that may be
24
determined by a jury, or a court sitting without a jury, up to a maximum of three times the
25
amount of actual damage but in no case less than four thousand dollars ($4,000), and any
26
attorney’s fees that may be determined by the court in addition thereto, suffered by any person
2]
denied the rights provided in Section 51, 51.5, or 51.6.
28
51
Section 51.(a) This section shall be known, and may be cited, as the Unruh Civil Rights Act.
N
WwW
51(b), states, “(b) All persons within the jurisdiction of this state are free and equal, and no
&-
matter what their.. medical condition... are entitled to the full and equal accommodations,
advantages, facilities, privileges, or services in all business establishments of every kind
nA
whatsoever.
NHN
nN
(i) “Medical condition” means either of the following: (2) Genetic characteristics. For purposes
Oo
of this section, “genetic characteristics” means either of the following: (A) Any scientifically or
uo
medically identifiable gene or chromosome, or combination or alteration thereof, that is known

10
to be a cause of a disease or disorder in a person or that person's offspring, or that is determined
11
to be associated with a statistically increased risk of development of a disease or disorder, and
12
that is presently not associated with any symptoms of any disease or disorder. (B) Inherited
13
characteristics that may derive from the individual or family member, that are known to be a
14
cause of a disease or disorder in a person or that person's offspring, or that are determined to be
15
associated with a statistically increased risk of development of a disease or disorder, and that are
16
presently not associated with any symptoms of any disease or disorder.
17
18
19
20 Part one of the Administrative Regulations for the Board of State and Community Corrections,
21 chapter 13, Article 1, Section 13/102 and Part two, Section 1231, Minimum Standards For Adult
Ze Facilities concerning toilets and urinals, Mr. Bennett was deprived because of his condition.
23
24
25
26
27
28 COUNT II: FALSE ARREST/ FALSE IMPRISONMENT
52
N
WD

Se
NW
The guards working at the Sacramento County Jail caused Mr. Bennett to be falsely
BODO
imprisoned in his cell when he was scheduled to go to court.

TY
eo
The Sacramento County Jail had no authority to decide that a prisoner can not go to
Co
10 court.
11
12 The Sacramento County Jail knew that not going to court would be detrimental to Mr.
13 Bennett.
14
15
California Penal Code 236 PC defines false imprisonment as the unlawful violation of the
16
personal liberty of someone else. To violate someone's person's liberty means a sustained
17
restriction of their freedom using violence, duress, fraud, deceit.
18
19
20
21 COUNT XVII: PUBLIC ENTITY: FAILURE TO DISCHARGE A MANDATORY

22 DUTY
23
24
Plaintiff re-alleges the allegations set forth in Paragraphs 1- above and incorporates same herein
25
by reference.
26
27
28
53
.
The California Constitution Article 1 Section 7 States: A person may not be deprived of
life, liberty, or property without due process of law or denied equal protection of the laws.
N
Ww
Section 16 States: Trial by jury is an inviolate right and shall be secured to all.
-&-
vA
The job of the Superior Court is to conduct trials in a way where the rights stated above
NN
on
are not violated.
Mr. Bennett ’s rights as stated above were violated.

Co
10
11 Mr. Bennett was denied his right to a trial by jury.
12
13 Mr. Bennett has a property interest in his reputation.
14
15 When the Sacramento County Superior court failed to discharge the duty of carrying out
16 a trial by jury and a proper competency trial Mr. Bennett ’s property interest in his reputation
17 was harmed.
18
19 If the Sacramento County Superior court would have discharged their duty according to
20 California law Mr. Bennett ’s property interest in his reputation would not have been harmed.
21
22 Non-Punitive Damages
23 Mr. Bennett is asking for $34,234,244. This includes damages for pain and suffering, emotional
24 distress, loss of reputation, loss of earning capacity, loss of clients and the destruction done to
25 Mr. Bennett’s business. Mr. Bennett suffered, malnutrition, headaches, cramps, and nausea.
26
27
28
54
Punitive Damages
NY
WY
Punitive damages should be awarded because this is a clear case of fraud, oppression and
SP
malice. Mr. Bennett was subject to cruel conditions and prevented from going to court which
Hh
caused Mr. Bennett to ultimately be found incompetent. No person, prisoner or otherwise should
NHN
have to suffer what Mr. Bennett went through. Punitive damages will server to detour the jail
NY
from this cruel treatment in the future.

Oo
oO
mmm met
Prayer For Relief
Wherefore, Plaintiffs pray that this Court enter Judgment against Defendants, and each of
them, as follows:
A. For compensatory damages for the acts complained of herein, in an amount to be
proven at trial;
wm
B. For special damages as permitted by law;
C. For punitive damages as permitted by law.
D. For such pre- and post-judgment interest as permitted by law; and

RO
E. For the finding of incompetence against Mr. Bennett to be found invalid and vacated
DO
NO
BN
55

BENNETT VS SACRAMENTO COUNTY JAIL Et Al.

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BENNETT VS SACRAMENTO COUNTY JAIL Et Al.

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Filed

' Superior Court of California,

Tel: (916) 599-5142 By , Deputy

In Pro Per 230 VG05472

SUPERIOR COURT OF THE STATE OF CALIFORNIA

AUSTIN BENNETT, Case No.:

13 Sacramento County Jail;

20 Dated: July 20, 2023

19 capacities, whether individual, corporate, associate, county or otherwise, of defendants DOES 1

25 (legally) caused by their conduct.

cage. From there he was remanded to the Sacramento County Jail.

had to have his colon removed.

The guard was trying to embarrass and humiliate Mr. Bennett

Mr. Bennett felt humiliated and upset.

except for 25 minute breaks which were usually early morning.

12 and not think Austin would be calling so early.

jail never provided him one.

11 but received no call back or email reply.

someone would bring him a supply.

distress, humiliation and torture.

someone right away, and again nobody showed up.

12 function and the production of DNA.

28 counter. However, Mr. Bennett had done as he was told.

order to let the guard he was in urgent need.

10 supply and medical need, he felt like passing out.

17 daughter suffers from a form of Crohn's disease as well.

25 which were deprived of Mr. Bennett at the Sacramento County jail.

provide an ileal pouch for Mr. Bennett.

Sacramento County Jail.

22 pouch for the entire time he was in jail.

Mr. Bennett experienced headaches, migraines and cramps.

The loud television was causing Mr. Bennett pain.

12 that he needed a “shit bag”

This made Mr. Bennett appear incompetent and insane.

28 treatment that no one should have to endure.

Magnesium and B-12 Vitamin.

Mr. Bennett suffered headaches, cramps and nausea because of this.

from causing damage and bleeding to his stoma.

Magnesium and B-12 Vitamins.

Mr. Bennett Suffered extreme emotional distress because of this.

dispute the claims of incompetence against him.

Refusing to go to a competency hearing can make a person look more incompetent.

This contributed to Mr. Bennett being found incompetent.

13 Being found mentally incompetent was humiliating for Mr. Bennett.

19 After being found incompetent Mr. Bennett lost clients.

COUNT XXII: CONCEALMENT

him locked in a cell.

21 This contributed to Mr. Bennett being found incompetent.

After being found incompetent Mr. Bennett lost clients.

18 This contributed to Mr. Bennett being found incompetent.

24 Being found mentally incompetent was humiliating for Mr. Bennett.

23 same herein by reference.

Court when asked about inmates.

refused to come to court.

Mr. Bennett did not refuse to come to court.

to defend his competency.

Mr. Bennett was found incompetent because of this.

Being found incompetent was humiliating for Mr. Bennett's

dispute the claims of incompetence against him.

Refusing to go to a competency hearing can make a person look more incompetent.

This contributed to Mr. Bennett being found incompetent.

COUNT X: DEFAMATION PER SE