Jones Et Al V Interim Care Foster Family Agency Oct 27 2014 PDF

CIV 141027 CIV DS 1416170 CASEEN 130002
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TH I S PAG E
Complaint and Party information entered
I I I I I IIII I I I I I I I I I I I I I I I IIII I I I I
NEW FILE
f
1
L Wallace Pate
SBN 79523
Esq
LAW OFFICES OF L WALLACE PATE
2 9903 Santa Monica Boulevard Suite 3100

3
Beverly
Hills CA 90212
Telephone
I L
SUPERIOR COUR7
Cp
310 203 2210
NTY
pF
FQ
RNARp I p
RNAF DINO ISTf ICT

Q T
1
4
5
OF SAN
Attorneys for Plaintiffs

1
d K
csi
cL
LEANDRA HENDRIX DEPUTY
7
S
9
10
SUPERIOR COURT FOR THE STATE OF CALIFORNIA
11
COUNTY OF SAN BERNADINO
12
13
CASE NO
DEANDRE JONES REANDRENE JONES
70
ISAIAH SAIS SALEENA GALVAN
14 MARK GALVAN
SURPRISE ADAMS
SHAWNA ADAMS individuals
15
SUAVE
DYSON minor by and through his Guardian

Ad Litem Robert Miller
16
1
1g
19
20
21
COMPLAINT FOR DAMACES

DEMAND FOR JURY TRIAL
Plaintiffs
DEMAND IN CONTROVERSY EXCEEDS
vs
25 000
INTERIM CARE FOSTER FAMILY
AGENCY a California Corporation

SUKHWINDER SINGH FREDDIE
WILSON AJAY MALHOTRA
BHUPINDER CHHUDU KHUSHANUD
AZARIAH JOEL DOMINGUEZ
SHAHZIA RAMNIT LISA OATES
22 NAWAB WILSON Individuals and DOES

1 50 inclusive
23
Defendants
24
25
COME NOW plaintiffs DEANDRE JONES REANDRANE JONES ISAIAH SAIS SALEENA
26
GALVAN MARK GALVAN SURPRISE ADAMS SHAWNA ADAMS individuals
SUAVE DYSON
2
28
a minor by and through his Guardian Ad Litem Robert Miller complain and allege on information and
belief as follows
1
GENERAL ALLEGATIONS
1
2
Plaintiffs DEANDRE JONES REANDRENE JONES ISAIAH SAIS SALEEN
3 GALVAN MARK GALVAN SURPRISE ADAMS SHAWNA ADAMS minor SUAVE DYSON dob
4
5 10 97
Robert Miller court appointed Guardian Ad Litem herein residents of San Bernadino County
5
are eight
former foster
children caught
in
an
illegal
abusive
violent concealed
unconscionable
kids for
cash operation from 2006 to 2013 run by defendant INTERIM CARE FOSTER FAMILY AGENCY
g
9
INTERIM
and
defendants
uncertified
LISA OATES
and
NAWAB
WILSON
At all times herein
plaintiffs suffered ongoing unrestrained terror torture corporal punishment physical and mental abuse
10
and neglect at the hands of defendants OATES WILSON covered up unchecked by defendant INTERIM
11
2
12
13
At all times herein defendant INTERIM was a California Corporation licensed and existing
under the laws of California with its principal place of business in the County of San Bernadino 10251
14 Trademark Street A Rancho Cucamonga California 91730

15
16
At all times herein between 1 1 06 and 1 1 13 defendants OATES WILSON
residents of San Bernadino County defendants INTERIM defendants board members defendant CEO
17
and defendants Administrators held out uncertified OATES WILSON and seven uncertified facilities as
18
19
20
21
22
certified by INTERIM in violation of Health and Safety Code Section 1508

4
At all times herein defendants INTERIM defendants board members defendant CEO
defendants Administrators and defendants OATES WILSON bilked hundreds of thousands of foster care
dollars from
the
U S Dept
of
Health
and
Human
Services
Title IV E
Federal Foster Care Funds
23
California Dept of Social Services DSS State Foster Funds and San Bernadino County Child Protective
24
Services Foster Care Funds for plaintiffs on pretext that defendant INTERIM certified defendants
25
26 OATES WILSON and defendants seven facilities

27
28
At all times herein defendant INTERIM defendants board members defendant CEO
and defendants Administrators knew plaintiffs foster c zildren were evicted frorrc four 4 ofthe seven
COMPLAINT
GENERAL ALLEGATIONS
1
2
Plaintiffs DEANDRE JONES REANDRENE JONES ISAIAH SAIS SALEEN
3 GALVAN MARK GALVAN SURPRISE ADAMS SHAWNA ADAMS SUAVE DYSON residents of
4
San Bernadino County are eight former foster children caught in an illegal abusive violent concealed
5
unconscionable
kids for cash operation from 2006 to 2013 run by defendant INTERIM CARE FOSTER
6
FAMILY AGENCY
INTERIM
and defendants uncertified LISA OATES and NAWAB WILSON
g At all times herein plaintiffs suffered ongoing unrestrained terrar torture corporal punishment physical
9
10
and mental abuse and neglect at the hands of defendants OATES WILSON covered up unchecked by
defendant INTERIM
11
2
At all times herein defendant INTERIM was a California Corporation licensed and existing
12
13
under the laws of California with its priricipal place of business in the County of San Bernadino 10251
14 Trademark Street A Rancho Cucamonga California 91730

15
16
At all times herein between 1 1 06 and 1 1 13 defendants OATES WILSON
residents of San Bernadino County defendants INTERIM defendants board members defendant CEO
17
and defendants Administrators held out uncertified OATES WILSON and seven uncertified facilities as
18
19
20
21
22
certified by INTERIM in violation of Health and Safety Code Section 1508

4
defendants Administrators and defendants OATES WILSON bilked hundreds of thousands of foster care
dollars from the U S Dept
of
Health
and
Human Services Title IV E
Federal Foster Care Funds
23
California Dept of Social Services DSS State Foster Funds and San Bernadino County Child Protective
24
25
Services Foster Care Funds for plaintiffs on pretext that defendant INTERIM certified defendants
26 OATES WILSON and defendants seven facilities

27
28
At all times herein defendarit INTERIM defendants board members defendant CEO
and defendants Administrators knew plaintiffs foster children were evicted from four 4 ofthe seven
COMPLAINT
1
2
3
uncertified facilities while holding said defendants and said facilities out as certified by INTERIM in
violation of
S Code Section 1508 placed more dependent children collected lucrative federal state
and county foster care funds perpetrating the kids for cash scam
6
5
and defendants Administrators knew defendants OATES WILSON and plaintiffs foster children were
6
homeless for
by
six months
INTERIM in
homeless foster
violation of
took no action held out said homeless defendants as
children
S Code Section 1508 placed more dependent children
certified
collected lucrative federal state and county foster care funds perpetrating the kids for cash scam
10
11
and defendants Administrators knew or should know plaintiffs foster children suffered ongoing
12
13
unrestrained relentless torture trauma severe mental and emotional abuse at the hands of defendants
14 OATES WILSON took no action held out said uncertified dangerous violent abusive defendants as
15 certified by INTERIM
16
Defendant SUKHWINDER SINGH defendant Interim s Chief Financial Officer and
17
Administrator 10251 Trademark Street A Rancho Cucamonga California 91730 bilked hundreds of
18
thousands of foster care dollars from the U S Dept of Health and Human Services California DSS and
19
20 San Bernadino County Child Protective Services on pretext uncertified defendants OATES WILSON and
21
22
defendants
facilities
were certified
by
INTERIM in
violation of
S Cocle Section 1508
9 Defendant FREDDY WILSON defendant Interim s director 10251 Trademark Street A
23
Rancho Cucamonga California 91730 bilked hundreds of thousands of foster care dollars from the U S
24
Dept of Health and Human Services California DSS and San Bernadino County Child Protective
25
26 Services on pretext uncertified defendants OATES WILSON and defendants facilities were certified by
27
INTERIM in
violation of
S Code Section 1508
28
COMPLAINT
At all times herein defendant AJAY MALHOTRA defendant Interim s director 10251
10
2 Trademark Street A Rancho Cucamonga California 91730 bilked hundreds ofthousands of foster care
3 dollars from the U S Dept of Health and Human Services California DSS and San Bernadino County
4
Child Protective Services on pretext uncertified defendants OATES WILSON and defendants facilities
5
were certified
by
INTERIM in
violation of
S Code Section 1508
At all times herein defendant BHUPINDER CHHUDU defendant Interim s director
11
10251 Trademark Street A Rancho Cucamonga California 91730 bilked hundreds of thousands of foster
care dollars from the U S Dept of Health and Human Services California DSS and San Bernadino
10
County Child Protective Services on pretext uncertified defendants OATES WILSON and defendants
11
facilities
were certified
by
INTERIM in
violation of
S Code Section 1508
12
12 At all times herein between 11 29 06 and 12 03 10 defendant KHUSHANUD AZARIAH
13
14 employed as defendant Interim s Administrator 10251 Trademark Street A Rancho Cucamonga

15 California 91730 bilked hundreds of thousands of foster care dollars from the U S Dept of Health and
16
Human Services California DSS and San Bernadino County Child Protective Services on pretext
17
uncertified defendants OATES WILSON and defendants facilities were certified by INTERIM in violation
18
of
S Code Section 1508
19
20
13 At all times herein between 12 03 10 and 7 22 11 defendant JOEL DOMINGUE employed as
21
defendant Interim s Administrator 10251 Trademark Street A Rancho Cucamonga California 91730
22
bilked hundreds of thousands of foster care dollars from the U S Dept of Health and Human Services
23
California DSS and San Bernadino County Child Protective Services on pretext uncertified defendants
24
OATES WILSON
and
defendants
facilities were certified
by
INTERIM in
violation of
S Code
25
26 Section 1508
27
28
RESERVED 14
17
16
At all times herein between 10 18 11 and 8 30 14 defendant SHAHZIA RAMNIT
COMPLAINT
1 employed as defendant Interim s Administrator 10251 Trademark Street A Rancho Cucamonga

2 California 91730 bilked hundreds of thousands of foster care dollars from the U S Dept of Health and
3 Human Services California DSS and San Bernadino County Child Protective Services on pretext
4
uncertified defendants OATES WILSON and defendants facilities were certified by INTERIM in violation
5
of
S Code Section 1508
6
7
FIRST CAUSE OF ACTION FOR NEGLIGENCE
g
9
pLAINTIFFS DEANDRE JONES REANDRANE JONES ISAIAH SAIS SALEENA
10
11
GALVAN MARK GALVAN SU1tPRISE ADAMS SHAWNA A AMS SUAVE
12
DYSON AGAINST DEFENDANTS INTERIM SUKHWINDER SINGH FREDDIE
13
WILSON AJAY MALHOTRA BHUPINDER CHHUDU
14
KHUSHANUD AZARIAH JOEL DOMINGUEZ SHAHZIA RAMNIT LISA OATES

15
NAWAB WILSON and DOES 1 20

16
1
18
Plaintiffs reallege pars 1 17 as though fully set forth herein
18
19
On 8 18 06 the Department sent written notification to defendants FREDDIE WILSON
19
AJAY MALHOTRA and BHUPINDER CHHUDU that defendant Interim applied for a license to operate
20
a foster farnily agency and named defendants as its board members

21
20
The Department
s notification
further
stated
It is important for you to understand that if
22
23 approved this license will be issued in the name of the corporation This means that the corporation will be
24 held accountable for the care and supervision of all clients in care
25
21
The Department
s notification
further
stated
Regular board of directors meetings is
26
essential if the board members are to ensure that the care facility is operating properly and in substantial
27
28
compliance with licensing laws and regulations In some instances board members may be held
accountable for the conduct of or damages caused by the facility corporate licensee
5
COMPLAINT
22
2
3
California Code of Regulations Title 22 Section 88063 imposed mandatory statutory
duties on defendant Interim s directors defendants FREDDIE WILSON AJAY MALHOTRA and
BHUPINDER CHHUDU
c to actively ensure accountability and perform at a minimum the following
1 establish and approve policies and procedures governing the operation of defendant
responsibilities
5
Interim
approve and monitor a
budget for defendant Interim
access and maintain the level of
funding necessary to cover the costs of operating defendant Interim

23
Title 22 Sections 80001 O 3 and 88018 d imposed mandatory statutory duties on
9 defendants directors FREDDIE WILSON AJAY MALHOTRA and BHUPINDER CHHUDU to sign a
10
r itten resolution stating the board shall operate defendant Interim in full conformity with applicable
11
licensing statutes and regulations

12
24
13
Title 22 Section 88035 imposed responsibility on defendants directors FREDDIE
14 WILSON AJAY MALHOTRA and BHUPINDER CHHUDU for dependent children placed in defendant
15 Interim s custody
16
25 Title 22 Section 88063 a imposed mandatory statutory duties on defendant Interim to
17
account for the general supervision of defendant s facility and certified family homes to establish policies
18
19
concerning operations and to ensure operations comply with applicable regulations and statutes
26
20
21
22
The U S Department of Health and Human Services under Social Security Act Title IV E
California Department of Social Services and San Bernadino Department of Social Services paid
defendant Interim millions for foster care for dependent children placed in defendant s custody including
23
plaintiffs
24
27
25
Administrator means the person designated by the board of directors to be responsible for
26 defendant Interim
27
28
s operation
California Code of Regulations Title 22 section 88001 a 2
Title 22 Sections 88001
88030 b imposed mandatory statutory duties on
28 defendants administrators KHUSHANLJD AZARIAH JOEL DOMINGUEZ and SHAHZIA RAMNIT to
6
COMPLAINT
sign Certificates of Approval on defendant Interim s family homes

29
2
3
Title 22 Section 88001 c imposed mandatory statutory duties on defendants
administrators KHUSHANUD AZARIAH JOEL DOMINGUEZ and SHAHZIA RAMNIT to issue
Certificates of Approval on defendant Interim s family homes

5
30
Under Section 88001
a certified family home means a residence certified by a
licensed FFA and issued a Certificate of Approval by the agency as meeting licensing standards a certified
g parent is an adult residing in the home certified by the FFA to provide court supervision to children placed
9 by that agency
10
31
Title 22 Section 88030 b imposed mandatory statutory duties on defendants
11
administrators KHUSHANUD AZARIAH JOEL DOMINGUEZ and SHAHZIA RAMNIT to provide

12
13
each certified family home used by defendant with a Certificate of Approval properly completed and
14 signed by the administrator or his her designee a Certificate of Approval is not transferable and is void
15
upon a change of location or certified parents
16
32
Under Section 89201
Completed Application
11
means
A the applicant has
17
submitted and the licensing agency has received all required material and B the licensing agency has
18
19
completed a site visit to the facility

33
20
21
Name
Under Section 89218
and address of
22
renting
the
applicant
T he application and supporting documents shall include 1
2 Name and address of owner of premises if applicant is leasing or
A copy of the document s that establish that the applicant has control of the property to be
23
licensed
24
34
Under Section 80001
an application for a Certificate of Approval includes a Plan of
25
26 Operation completed by the applicant

27
28
35
Under Sections 80022 and 83087 2 the Plan of Operation includes a sketch of the building
and the grounds including the dimensions of all areas used by the clients
COMPLAINT
36 Under Sections 80 022 g and 80061 changes in the Plan of Operation shall be submitted
2 For licensing agency approval and shall be reported to the Department

3
37
Under Section 89218
The application shall be filed with the licensing agency which
services the geographical area in which the home is located

5
38 Title 22 Section 89227 a imposed mandatory statutory duties on defendants

6
administrators KHUSHANUD AZARIAH JOEL DOMINGUEZ and SHAHZIA RAMNIT to ensure a

site visit to the proposed foster family home is completed as part of the application review process and a
9
determination that all of the requirements of Article 3 of this chapter have been satisfied
10
39 Title 22 Section 89231 a imposed mandatory statutory duties on defendants
11
Administrators KHUSHANUD AZARIAH JOEL DOMINGUEZ and SHAHZIA RAMNIT to issue a

12
13
license to the applicant after an application has been completed an in home visit has been made pursuant
14
to Section 89227
15
Article 3 of this chapter have been met
16
40
subsection
upon determination that all licensing requirements set forth in
and
Section 89234 imposed mandatory statutory duties on defendants OATES WILSON to
17
provide defendant Interim with reasonable notice prior to any change in the location of the home as
18
specified
in Section 89361
subsection
19
41
20
Under H
S Code section 1503 5 a facility shall be deemed an unlicensed
21 community care facility maintained and operated to provide non medical care if it is unlicensed and not
22
exempt from licensure and the facility is held out as or represented as providing care or supervision as
23
defined by this chapter or the rules and regulations adopted pursuarit to this chapter
24
42
25
26
27
28
home
that
89201 C
Under Title 22 Sections 80001
is
providing
held
out as or represented as
and
S Code section 1503 5
care and supervision
includes
A licensed
home that moves to a new location
43
S Code Section 1531 5
child abuse
states
COMPLAINT
means a situation in which a
1
2
3
child suffers
other
from any
one or more of
than accidental means
going without necessary
and
2 Harm
basic
the
following
by
reason of
1 Serious physical injury inflicted upon the child by

intentional
neglect or malnutrition or sexual abuse
4 Willful mental injury negligent treatment or
physical care
maltreatment of a child under the age of 18 by a person who is responsible for the child s welfare under
5
circumstances that indicate that the child s health or welfare is harmed or threatened thereby as determined
6
in accordance with regulations prescribed by the Director of Social Services
S Code Sections 1531 5
44 Under H
and
necessary and basic physical
care means care provided in a current and validly licensed or administrator certified community care
10
facility
11
12
Penal Code Section 11166 imposed mandatory statutory duties on defendant Interim to
45
13
report
S Code Section 1531 5 c 3 and 4 based on
the abuse of a dependent child pursuant to H
14
placement
in
uncertified
community
care
facilities in
violation of
S Code Section 1508
15
16
46 Section 88061 b imposed mandatory statutory duties on all defendant Interim s personnel
17
to
report
the
abuse of a
dependent
child pursuant
S Code Section 1531 5 c
to H
3 and 4 based on
18
placement
in
uncertified
community
care
facilities in
violation of
S Code Section 1508
19
47
20
21
22
23
child placed
constitutes an unusual
or
safety
of
any
child
in
incident
an uncertified
child abuse under
violation of
Section 88061
under
constituting
home in
S Code Section 1508
4 that threatens the physical or emotional health

4 mandating a
report under Penal Code Section 11166
24
48
Section 88061 g imposed mandatory statutory duties on defendant Interim to report child
25
abuse under
26
Health
and
Safety
Code Section 1531 5
4 based on placement in uncertified homes in
27 violation of Health and Safety Codes Section 1508

28
49 Section 88061 h imposed mandatory statutory duties on defendant Interim to provide a log
COMPLAINT
1 of family homes certified and decertified during the month to the Department by the tenth of the following
2
3
month
50
Section 88068 imposed mandatory statutory duties on defendant Interim to complete and
maintain current admission agreements with each certified parent with whom the children were placed
5
51
Section 89200 a imposed mandatory statutory duties on defendant Interim to ensure
6
compliance with all applicable law and regulations
g
9
10
52
Under Section 89201
Deficiency means any failure to comply with any
provision of the Community Care Facilities Act commencing with Section 1500 of the Health and Safety
Code and or regulations adopted by the Department pursuant to the Act
11
53
Under Section 89201
Serious Deficiency means any deficiency that presents an
12
13
14
15
16
immediate or substantial threat to the physical health mental health or safety of any child in the home
54
Under Section 89201
Provision
or provide
means whenever any regulation
required that provision be made for or that there be provided any service personnel or other requirement
the care giver shall do so directly or present evidence to the licensing agency that the requirements have
17
been met by some other means

18
19
55
Under Section 89201
Licensed Home means a home that is licensed by
20 Community Care Licensing in accordance with the standards set forth in Article 3 ofthis chapter The
21
22
license cannot be transferred to another person or location

56
Under Section 89201
Unlicensed Community Care Facility means a facility as
23
defined in Section 1503 5
of
the H
S Code
24
57 Under Section 89201
89201 U
1 O 3
Unlicensed Community Care
25
26 Facility means a licensed home that moves to a new location

27
58
Section 89205 imposed mandatory statutory duties ori defendant Interim not to operate
28
io
COMPLAINT
establish manage conduct or maintain a foster family home or hold out advertise or represent by any
2 means to do so without first obtaining a current valid license from the licensing agency
3
59
Under
Section
89206
An unlicensed facility as defined in Section 89201 u 1 is in
violation of Section 1503 5 and or 1 508 of the Health and Safety Code
5
60 Section 89206 d imposed mandatory statutory duties on defendant Interim to issue an

6
immediate civil penalty on parents for operating an illegal unauthorized uncertified home pursuant to Title
g 22 section 89255 and Section 1547 of the Health and Safety Code
9
10
61
Section 89206
imposed mandatory statutory duties on defendant Interim to notify
the appropriate placement or protective service agency of an immediate threat to clients health and safety
11
62 Health and Safety Code Section 1508 imposed mandatory statutory duties on defendant
12
13
14
Interim not to operate establish manage or maintain uncertified homes
63 Health and Safety Code Section 1508 imposed mandatory statutory duties on
15 defendants administrators KHUSHANUD AZARIAH JOEL DOMINGUEZ and SHANZIA RAMNIT

16
not to operate establish manage or maintain uncertified family homes
17
64 Health and Safety Code Section 1508 imposed mandatory statutory duties on defendant
18
CEO SUKHWINDER SINGH not to operate establish manage or maintain uncertified family homes
19
20
65 Health and Safety Code Section 1508 imposed mandatory statutory duties on
21 defendants directors FREDDIE WILSON AJAY MALHOTRA and BHUPINDER CHHUDU not to
22
operate establish manage or maintain uncertified family homes
23
66
Section 89240 a imposed mandatory statutory duties on defendants administrators
24
25
KHUSHANiJD AZARIAH JOEL DOMINGUEZ and SHANZIA RAMNIT to deny an application for
26 certification if it is determined the applicant is not in compliance with applicable laws and regulations
27
28
67
Under Section 89242 a the Department shall have the authority to suspend or
revoke any license on any ofthe grounds specified in Health and Safety Code section 1550
11
COMPLAINT
68
Under Health
and
Safety
Code
section
1550
T he department may deny an
2 application for or suspend or revoke any license or any administrator certificate issued under this chapter
3
upon
any
the
of
4
grounds
Violation
and
following grounds
the manner provided
in this
for any of the following
chapter
of the rules and regulations promulgated under this chapter b
the licensee
by
in
Aiding abetting or permitting the violation ofthis chapter or of the rules and regulations promulgated
under
this chapter
individual in
or
Conduct which is inimical to the health morals welfare or safety of either an
receiving
from the
services
facility
or
the people of the
State
of
California
Engaging
9 in acts of financial malfeasance concerning the operation of a facility including but not limited to
10
fraudulent app rop riation for personal gain
of
facilit Y
moneY s and
P roPertY
or willful or ne g li gent failure
11
to provide services
12
69
Under Section 89361
each caregiver shall furnish such reports to the
13
14 licensing approval agency and the child s authorized representative required by the Department including
15
but
not
limited to the
16
emotional
health
or
following 3 Any unusual incident or child absence that threatens the physical or
safety
of
any
child
Any
suspected physical or psychological abuse of
any
child
17
When there is a change in the location of the home the caregiver shall notify the licensing approval agency
18
30 days prior to the move or as soon as the information is available

19
20
70
21
limited to
22
Under Section 89372
the
furnishings
following
each child shall have personal rights which include but are not
1 To be accorded safe healtliful and comfortable home accommodations
and equipment appropriate
to his her
needs
2 To be treated with respect and to be free from
23
sexual
physical
emotional or other abuse
4 To be free from corporal or unusual punishment infliction
24
of pain humiliation intimidation ridicule coercion threat mental abuse or other actions of a punitive
25
26 nature including but not limited to interference with the daily living functions of eating sleeping or
27
28
toileting
healthy
or
withholding
food
of shelter
clothing
or aids
to
physical
functioning
To receive adequate and
6 To be provided adequate clothing and personal items in accordance with Section
1z
COMPLAINT
1
2
89372 O 3
B To
necessary medical
possess and use
dental
vision
his her
own personal
and mental
health
items
services
including toiletries
8 To receive
10 To have social contacts with people
3 outside of the foster care system such as teachers church members mentors and friends in accordance
4
with
Section 89372
11
To
contact
family
members
unless prohibited
by
court order
16 To make
and receive confidential phone calls and send and receive unopened mail unless prohibited by court order
6
20 To attend school and participate in extracurricular cultural and personal enrichment activities
developmental level that is
consistent
with
state
consistent with the child
accorded dignity in his her personal relationships with other persons in the home
10
s age and
law
23 To be
Section 89376 a imposed mandatory statutory duties on certified parents to provide
11
or ensure at least three nutritious meals per day

12
72
13
Section 89376 a imposed mandatory statutory duties on certified parents to ensure
14 foster children have their meals with foster family members in a family setting
15
73
16
care and supervision as necessary to meet each child s needs

17
74
18
19
opportunity for and encourage participation in group sports leisure time family special school and daily
20 living skills activities

21
22
75
On 12 1 06 the Department of Social Services Department issued defendant Interim
a license to operate a Foster Family Agency FFA to certify foster parents and their homes as meeting all
23
licensing requirements to provide foster care for dependent children entrusted to defendant Interim s
24
25
26
27
28
custody
76
Prior to the issuance of defendant Interim s FFA license to certify family homes defendant
issued defendants OATES WILSON a Certificate of Approval on 11 16 06
77 On or about 12 11 06 defendant Interim placed plaintiffs JONES dob 5 3 95 then age 11
13
COMPLAINT
1 JONES dob 3 26 96 then age 10 and DYSON dob 5 10 97 then age 9 with defendants OATES WILSO
2
in
1 on 13945 Topmast Drive Helendale California 92342
Facility
78
Defendant Interim knew or should have known defendants OATES WILSON violated
4
plaintiffs
JONES JONES
and
11
16
DYSON
s personal rights enumerated
in Sections 89372 1
5
6
10
20
23 in
Facility
Topcast
by
but
not
limited
to
forced to
scrub walls floors vacuum and sweep floors lift rugs move and replace furniture clean toilets kitchen
g and bathrooms nightly in violation of Section 89378 suffering extreme pain fatigue and severe sleep
9
2 not allowed to eat the same food as defendants Oates and Wilson s family in violation of
deprivation
10
Section 89376
3 not allowed to eat at the same table as defendants Oates and Wilson in violation of
Section 89376
11
deprived of adequate food in violation of Section 89376 causing a constant state of
12
13
14
5 prohibited from opening the refrigerator or entering the food pantry in violation of Section
hunger
g9376
6 barred from court ordered contact with relatives in violation of Section 89379
and 7 forced to
15 Wear ill fitting shoes causing permanent injuries

16
9 In or about 6 07 defendants OATES WILSON plaintiffs JONES JONES and DYSON
i
moved
to
Facility
2 on 12547 Dulce Street Victorville The Certificate of Approval defendant Interim
18
19
20
issued on 11 16 06 was void by operation of law upon change of location under Title 22 Section 88030 e
and
80 Defendants OATES WILSON breached mandatory statutory duties imposed
21
22
S Code Sections 1524 1503 5
by H
S Code
Section 1534 and Title 22 Sections 89234 d by failing to report a change in location to defendant Interim
23
81 Defendants OATES WILSON breached mandatory statutory duties imposed by Section

24
89218
25
26
82
by failing
to
submit an application
for
approval on
Facility
2 Dulce
Defendants OATES WILSON breached mandatory statutory duties imposed
by
27 Code Section 1534 and Title 22 Sections 89234 d and 89361 d by failing to obtain a Certificate of
28
Approval
on
Facility
2 Dulce
14
COMPLAINT
Defendant Interim provided no supervision over defendants OATES WILSON no site
83
1
to
Facility
2 Dulce
little or no contact with plaintiffs JONES JONES and DYSON putting
visit
plaintiffs at risk of foreseeable harm knowing or should know plaintiffs suffered ongoing abuse and
4
neglect
84
Defendant Interim s administrator defendant KHUSHANUD AZARIAH did not and could no
6
issue
Certificate
of
Approval
on
Facility
2 Dulce
given defendants OATES WILSON s violations of
g mandatory statutory duties alleged in pars 80 81 83

9
85
10
g9201
Facility
2
89201
Dulce
was not a certified
89201
family
89206
home
and
pursuant
to Sections 88001
88005
S Code sections 1503 5 and 1508
11
86
Defendants OATES WILSON were not certified parents who met licensing requirements
12
13
14
in
C
uncertified
89206
Facility
a
pursuant
to Sections
88001
88005
89201 1
89201
89201
S Code sections 1503 5 and 1508 putting plaintiffs JONES JONES and DYSON at
15 risk of foreseeable harm

16
Defendant Interim breached mandatory statutory duties imposed by Sections 88005 88030
17
b
80001
80005 89201
89205
89206
89227
89231
S Code Sections 1503 5 and 1508
18
19
by
operating
uncertified
Facility
2 Dulce
with no supervision over and little if any contact with
20 plaintiffs JONES JONES and DYSON putting plaintiffs at risk of foreseeable harm knowing or should
21
22
know plaintiffs suffered ongoing abuse and neglect

88
Defendants directors FREDDIE WILSON AJAY MALHOTRA and BHUPINDER
23
CHHUDU
breached mandatory statutory duties imposed
by
S Code Section 1508 by operating
24
uncertified
25
Facility
2 Dulce with no supervision over and little if any contact with plaintiffs JONES
26 JONES and DYSON putting plaintiffs at risk of foreseeable harm knowing or should know plaintiffs
27 suffered ongoing abuse and neglect
28
89
Defendant administrator KHUSHANUD AZARIAH breached mandatory statutory duties
15
COMPLAINT
o
imposed
by
S Code Section 1508
by
operating
Facility
uncertified
2 Dulce with no supervision
2 over and little if any contact with plaintiffs JONES JONES and DYSON putting plaintiffs at risk of
3 foreseeable harm knowing or should know plaintiffs suffered ongoing abuse and neglect
4
Defendant CEO SUKHWINDER SINGH breached mandatory statutory duties imposed by
90
5
H
S Code Section 1508
by
operating
uncertified
Facility
2 Dulce
with no supervision over and
little if any contact with plaintiffs JONES JONES and DYSON putting plaintiffs at risk of foreseeable
g harm knowing or should know plaintiffs suffered ongoing abuse and neglect
9
10
g9255
91
Defendant Interim breached mandatory statutory duties imposed by Sections 89206 d
and
S Code Section 1547 by failing to issue an immediate civil penalty against defendants
11
OATES WILSON
on uncertified
Facility
2 Dulce
12
92 Defendant Interim breached mandatory statutory duties imposed by Section 86206 fl by
13
14 failing to notify the CPS placement agency that plaintiffs JONES JONES and DYSON were in uncertified
15
16
2 in
Facility
violation of
S Code Sections 1505 and 1508 with no supervision over and little if any
contact with plaintiffs JONES JONES and DYSON putting plaintiffs at risk of foreseeable harm
17
knowing or should know plaintiffs suffered ongoing abuse and neglect

18
93
Defendant Interim
breach
of
19
20
failure to notify CPS
21
plaintiffs
22
that
mandatory statutory duties imposed
defendants OATES WILSON
JONES JONES
and
DYSON to
remain
in
moved
to
uncertified
by
an uncertified
Facility
2 in
Section 86206
Facility
by
2 caused
violation of
S Code
Section 1508 as opposed to immediate removal mandated by law with no supervision over and little if
23
any contact putting plaintiffs at foreseeable risk of harm knowing or should know plaintiffs suffered
24
25
26
ongoing abuse and neglect

94
Defendant Interim s breach of mandatory statutory duties imposed by Section 86206
27 constituted inimical conduct that caused plaintiffs JONES JONES and DYSON to remain in uncertified
28
Facility
2 in
violatiori of
S Code Section 1508 as opposed to immediate removal mandated by law
16
COMPLAINT
1 with no supervision over and little if any contact putting plaintiffs at risk of foreseeable harm knowing or
2 should know plaintiffs suffered ongoing abuse and neglect
3
Defendant Interim breached mandatory statutory duties imposed by Section 89205 holding
95
uncertified
and uncertified
2 out as certified to CPS causing
Facility
5
plaintiffs
to remain
in
uncertified
2 in
Facility
violation of
S Gode Section 1508
as opposed to
immediate removal mandated by law with no supervision over and little if any contact putting plaintiffs
g at foreseeable risk of harm knowing or should know plaintiffs suffered ongoing abuse and neglect
9
Defendarit Interim s breach of mandatory statutory duties imposed by Section 88061 CO
96
10
holding
out uncertified
Facility
and uncertified
2 Dulce as certified to
11
CPS constituted a serious deficiency under Section 89201 s 1 causing plaintiffs JONES JONES and
12
13
DYSON to remain in
uncertified
Facility
in
violation of
S Code Section 1508 as opposed to
14 immediate removal mandated by law with no supervision over and little if any contact putting plaintiffs
15 at foreseeable risk of harm knowing or should know plaintiffs suffered ongoing abuse and neglect
16
Defendant Interim
97
breach
of
mandatory
statutory
duties imposed
by
section
89206
for
17
failure to
report
defendants OATES WILSON and
Facility
2 Dulce were uncertified in violation of H
18
19
S Code Section 1508 constituted a serious deficiency under Section 89201 s
20 JONES JONES
21
22
and
DYSON to
remain
in
uncertified
Facility
2 in
1 causing plaintiffs
violation of
S Code Section
1508 as opposed to immediate removal mandatecl by law with no supervision over and little if any
contact putting plaintiffs at foreseeable risk of harm knowing or should know plaintiffs suffered ongoing
23
abuse and neglect
24
98
Plaintiffs JONES JONES
and
DYSON
s placement
in
uncertified
Facility
Dulce in
25
26
violation of
27
and
28
and
plaintiffs
Welf
S Code Section 1508 was child abuse under Health and Safety Code Section 1531 5 c 3
Inst Code Section 300 b reportable under Penal Code Section 11166 mandating
immediate removal
COMPLAINT
99 Penal Code Section 11166 imposed mandatory statutory duties on defendant Interim to report
1
2
3
plaintiffs
JONES JONES
and
DYSON
s placement
in
uncertified
2 Dulce in violation of H
Facility
S Code Section 1508 maridating plaintiffs immediate removal
100 Defendant Interim s breach of mandatory statutory duties imposed by Penal Code Section
5
11166 for failure
to report plaintiffs
JONES JONES
DYSON
and
placement
in
uncertified
Facility
6
Dulce causing
plaintiffs
to
remain
in
uncertified
Facility
2 in
violation of
S Code Section 1508 as
g opposed to immediate removal mandated by law with no supervision over and little if any contact put
9 plaintiffs at foreseeable risk of harm knowing or should know plaintiffs suffered ongoing abuse and
1
10
neglect
11
Defendant Interim s breach of mandatory statutory duties imposed by Penal Code Section
101
12
13
14
15
16
11166 for failure to
89201
report
Facility
caused plaintiffs
violation of
2 Dulce was uncertified was a serious deficiency under section
JONES JONES
and
DYSON to
remain
in
uncertified
Facility
2 in
S Code Section 1508 as opposed to immediate removal mandated by law with no
supervision over and little if any contact putting plaintiffs at foreseeable risk of harm knowing or should
17

18
102
19
20
21
22
11166
Title 22 Sections 89205
and
contact
aided
Dulce in
abetted
violation of
86206
and permitted
88661
among others with no supervision little if any
s operation of uncertified
Facility
S Code Section 1508 as opposed to plaintiffs JONES JONES and DYSON s
23
immediate removal mandated by law putting plaintiffs at risk of foreseeable harm knowing or should
24
25
26

103
Defendant Interim engaged in acts of financial malfeasance based on payments from the
27 U S Department of Health and Human Services California Department of Social Services and San
28 Bernadino Department of Social Services for plaintiffs JONES JONES and DYSON s placement in
is
COMPLAINT
uncertified
Facility
2 in
violation of
S Code Section 1508 unbeknownst to said government funding
2 agencies as opposed to immediate removal mandated by law with no supervision little if any contact
3
putting plaintiffs at risk of foreseeable harm knowing or should know plaintiffs suffered ongoing abuse and
4
neglect
5
104
6
CHHUDU breached mandatory statutory duties imposed
by
Section 88063
2 by approving and
g monitoring a budget based on payments from the U S Department of Health and Human Services
9 California Department of Social Services and San Bernadino Department of Social Services for plaintiffs
10
JONES JONES
and
DYSON
s placement
in
uncertified
Facility
2 in
violation of
S Code Section
11
1508 unbeknownst to said government funding agencies with no supervision little if any contact putting
12
13
plaintiffs at risk of foreseeable harm as opposed to immediate removal mandated by law knowing
14 plaintiffs suffered ongoing abuse and neglect

15
16
105
by
Section 88063
3 by approving and
17
monitoring a budget to cover operation costs based on payments from the U S Department ofHealth and
18
19
Human Services California Department of Social Services and San Bernadino Department of Social
20 Services for
21
22
plaintiffs
JONES JONES
and
DYSON
s placement
in
uncertified
Facility
2 in violation of
S Code Section 1508 unbeknownst to said government funding agencies with no supervision little if
any contact putting plaintiffs at risk of foreseeable harm as opposed to immediate removal mandated by
23
law knowing or should know plaintiffs suffered ongoing abuse and neglect
24
106
Defendants directors FREDDIE WILSON AJAY MALHOTRA and
25
26
BHUPINDER CHHUDU breached mandatory statiztory duties imposed
by
Section 88063
3 by
27 accessing and maintaining defendant Interim s level of funding to cover operation costs based on payments
28 from the U S Department of Health and Human Services California Department of Social Services and
19
COMPLAINT
1
2
3
4
San Bernadino Department of Social Services for plaintiffs JONES JONES and DYSON s placement in
Facility
uncertified
2 in
violation of
S Code Section 1508 unbeknownst to said government funding
agencies with no supervision little if any contact putting plaintiffs JONES JONES and DYSON at risk
of foreseeable harm as opposed to immediate removal mandated by law knowing or should know plaintiffs
5
suffered ongoing abuse and neglect
6
107
g CHHUDU breached mandatory statutory duties imposed by Sections 80000 1 3 and 88018 by operating
9
10
Facility
uncertified
2 Dulce in
violation of
S Code Section 1508 unbeknownst to the above
alleged governmental funding agencies with no supervision little if any contact putting plaintiffs JONES
11
JONES and DYSON at risk of foreseeable harin as opposed to immediate removal mandated by law
12
owing or should know plaintiffs suffered ongoing abuse and neglect
13
108
14
Defendant CEO SUKHWINDER SINGH engaged in acts of financial malfeasance based on
15 payments from the U S Department of Health and Human Services California Department of Social
16
Services and San Bernadino Department of Social Services for plaintiffs JONES JONES and DYSON s
17
placement
in
uncertified
Facility
2 in
violation of
S Code Section 1508 unbeknownst to said
18
19
government funding agencies with no supervision little if any contact putting plaintiffs JONES JONES
20 and DYSON at risk of foreseeable harm as opposed to immediate removal mandated by law knowing or
21
shoulcl know plaintiffs suffered ongoing abuse and neglect
22
Defendants OATES WILSON engaged in conduct inimical to plaintiffs JONES JONES
109
23
and
DYSON
health
rnorals
welfare
and
safety
by
operating
uncertified
Facility
Dulce in violation
24
of
25
S Code Section 1508 unbeknownst to above alleged governmental funding agencies

110
26
27 for
28
plaintiffs
Defendants Oates and Wilson engaged in acts of financial malfeasance based on payments
JONES JONES
Oates Wilson
and
Facility
and
DYSON
placement in
uncertified
2 Dulce were certified
Zo
COMPLAINT
Facility
2 on pretext defendants
Defendant Interim knew or should have known and defendant WILSON observed
111
2 defendant OATES plaintiffs JONES JONES and DYSON to either fight other foster children or
3 beaten tortured by defendant forced to steal food or go hungry forced D JONES to walk 14 miles to and
4
from school when his home school was five minutes away forced DYSON to sit in a small banana crate all
day
forced DYSON
to wear ill
fitting shoes
that caused permanent
disability
damage
forced plaintiffs to
ask defendant for a glass of water for toilet paper for tooth paste demeaned and cursed plaintiffs forced
g plaintiffs to clean defendant s house several hours each night to wear used clothes to wear clothes that
9
10
were too small causing shame and embarrassment took plaintiffs personal possessions beat plaintiffs with
belts shoes anything defendant OATES could find refused to allow plaintiffs JONES JONES and
11
DYSON to
wash clothes
in defendant
s machine
in
Facility
2 forced plaintiffs to walk or ride a bike
12
13 carrying plastic bags of clothes miles to and from the laundromat in the dark at night in all kinds of
14
eather
15
16
112
DYSON
In or about 9 07 defendants OATES WILSON plaintiffs JONES JONES and
moved
location
to
Facility
Pool
17
113
Defendants OATES WILSON breached mandatory statutory duties imposed by
18
19
S Code Section 1534 and Title 22 Sections 89234 d by failing to report a change in location to
20 defendant Interim
21
22
114
Section 89218

c
by failing to
to defendant Interim for
approval on
Facility
23
Pool
24
115
25
S Code Section 1534 and Title 22 Sections 89234 d and 89361 d by failing to obtain a Certificate of
26
27
Approval from defendant KHUSHANUD AZARIAH
2g
116
on
Facility
Pool
Defendant Interim s administrator defendant KHUSHANUD AZARIAH did not
21
COMPLAINT
and could not
issue
Certificate
of
Approval
on
3 Pool under Section 89240 a given
Facility
2 defendants OATES WILSON S licensing violations defendant Interim made no site visit provided no
3
supervision little if any contact putting plaintiffs JONES JONES and DYSON at risk of foreseeable
harm as opposed to immediate removal mandated by law knowing or should know plaintiffs suffered
5
6

117
3 Pool was not a certified family home pursuant to Title 22 Sections
Facility
88005
89201 1
89201
89201
89206
and
S Code Sections
88001
1503 5 and 1508 putting plaintiffs JONES JONES and DYSON at foreseeable risk of harm
10
Defendants OATES WILSON were not certified parents who met licensing requirements in
118
11
uncertified
Facility
pursuant
to Sections 88001
88005
89201 1
89201
89201
12
13
89206
S Code sections 1503 5 and 1508 while defendant Interim provided no supervision
14 little if any contact putting plaintiffs JONES JONES and DYSON at risk of foreseeable harm as opposed
15 to immediate removal mandated by law knowing or should know plaintiffs suffered ongoing abuse and
16
neglect
17
119
Defendant Interim
Facility
Pool
breached
18
19
20
89206
89227
89231
and
by
H
Sections 88005
88030
80001
80005 89201
89205
S Code Sections 1503 5 and 1508 with no supervision little if
21 any contact putting plaintiffs JONES JONES and DYSON at risk of foreseeable harm as opposed to
22
immediate removal mandated by law knowing or should know plaintiffs suffered ongoing abuse and
23
neglect
24
120
25
26
BHUPINDER CHHUDU breached mandatory statutory duties imposed
27
operation of uncertified
Facility
by
S Code Section 1508 by
3 Pool with no supervision little if any contact putting plaintiffs
28 JONES JONES and DYSON at risk offoreseeable harm as opposed to immediate removal mandated by
az
COMPLAINT
1 law knowing ar should know plaintiffs suffered ongoing abuse and neglect
Defendant administrator KHUSHANUD AZARIAH breached mandatory statutory
121
duties imposed
by
S Code Section 1508
by
Facility
Pool
with no
supervision little if any contact putting plaintiffs JONES JONES and DYSON at risk of foreseeable
5
harm as opposed to immediate removal mandated by law knowing or should know plaintiffs suffered
6
9
10
Defendant CEO SUKHWINDER SINGH breached mandatory statutory duties
122
imposed
by
S Code Section 1508
by
Facility
Pool
with no supervision
little if any contact putting plaintiffs JONES JONES and DYSON at risk of foreseeable harm as opposed
11
to immediate removal mandated by law knowing or should know plaintiffs suffered ongoing abuse and
12
neglect
13
15
16
Defendant Interim breached mandatory statutory duties imposed by Sections 89206 d
123
14
g9255
Oates
and
and
S Code Section 1547 by failing to issue an immediate civil penalty against defendants
Wilson
on uncertified
Facility
Pool
17
124
Defendant Interim breached mandatory statutory duties imposed by Section 86206 fl by
18
19
failing to notify the CPS placement agency that plaintiffs JONES JONES and DYSON were placed in
Facility
Pool
in
violation of
S Code Section 1 508 with no supervision little if any
20
uncertified
21
contact putting plaintiffs at risk of foreseeable harm as opposed to immediate removal mandated by law
23
125
Defendant Interim
breach
of
by
Section 86206
for
24
failure
25
26
Pool
to notify
CPS
that
caused plaintiffs
plaintiffs
to remain
in
JONES JONES
uncertified
and
Facility
DYSON
3 in
were placed
violation of
in
uncertified
in
Facility
S Code Section 1508 with
27 no supervision little if any contact putting plaintiffs at risk of foreseeable harm as opposed to immediate
28
removal mandated by law knowing or should know plaintiffs suffered ongoing abuse and neglect
23
COMPLAINT
Defendant Interim
breach ofmandatory statutory duties imposed
by
126
Code Section 1508
no supervision and little if any contact putting plaintiffs JONES JONES and DYSON at risk of
constituted
inimical
causing plaintiffs to
conduct
remain
in
uncertified
3 with
Facility
foreseeable harm as opposed to immediate removal mandated by law knowing or should know plaintiffs
5
6
Defendant Interim breached mandatory statutory duties imposed by Section 89205 by
127
as certified and
uncertified
Facility
3 Pool
as
holding
certified to CPS constituting conduct inimical to plaintiffs JONES JONES and DYSON s health morals
out uncertified
10
elfare
causing
plaintiffs
to
remain
in
uncertified
Facility
3 in
violation of
S Code Section 1508
11
with no supervision and little if any contact putting plaintiffs at risk of foreseeable harm as opposed to
12
13
immediate removal mandated by law knowing or should kriow plaintiffs suffered ongoing abuse and
14 neglect
15
16
Defendant Interim breached mandatory statutory duties imposed by Section 88061 O by
128
holding
out uncertified
and uncertified
Facility
3 Pool as certified to CPS
17
constituting a serious deficiency under Section 89201 s 1 causing plaintiffs JONES JONES and
18
DYSON to
remain
in
uncertified
19
Facility
in
violation of
S Code Section 1508 with no supervision
20 and little if any contact putting plaintiffs at risk of foreseeable harm as opposed to immediate removal
21 mandated by law knowing or should know plaintiffs suffered ongoing abuse and neglect
22
Defendant Interim
129
breach
of
by
section
23
failing
to
report plaintiffs
JONES JONES
and
DYSON
s placement
in
uncertified
Facility
89206
3 Pool
by
in
24
violation of
25
26
plaintiffs
to
S Code Section 1508 was a serious deficiency under Section 89201 s 1 causing
remain
in
uncertified
Facility
3 with no supervision and little if any contact putting plaintiffs
27 at risk of foreseeable harm as opposed to immediate removal mandated by law knowing or should know
28
plaintiffs suffered ongoing abuse and neglect
24
COMPLAINT
2
3
130
1
Pool
was child abuse under
and
DYSON
s placement
in
and
uncertified
Facility
Inst Code Section 300 b
Welf
reportable under Penal Code Section 111 66 mandating plaintiffs immediate removal from uncertified
4
5
131
Defendant Interim breached mandatory statutory duties imposed by Penal Code Section
6
11166
g
9
10
Pool
in
by failing
in
violation of
uncertified
JONES JONES
DYSON
s placement
in
uncertified
Facility
S Code Section 1508 causing plaintiffs JONES JONES and DYSON to remain
Facility
and
3 with no supervision and little if any contact putting plaintiffs at risk of
11
12
132
13
14
11166
15
pool
by failing
in
to
violation of
16
causing
report plaintiffs
plaintiffs
JONES
JONES JONES
and
DYSON
s placement
in
uncertified
Facility
S Code Section 1508 was a serious deficiency under section 89201 s 1

JONES
and
DYSON to remain in
uncertified
Facility
3 with no supervision
17
and little if any contact putting plaintiffs at risk of foreseeable harm as opposed to immediate removal
18
19
mandated by law knowing or should know plaintiffs suffered ongoing abuse and neglect
133
20
21
22
11166 and Title 22 Sections 89205 86206 fl 88661 c aided abetted and permitted uncertified defendants
OATES WILSON
3 Pool
Facility
in
violation of H
S Code section 1508
23
causing
plaintiffs
JONES JONES
and
DYSON to
remain
in
uncertified
Facility
3 with no supervision
24
25
and little if any contact with defendant Interim putting plaintiffs at risk of foreseeable harm as opposed to
26 immediate removal mandated by law knowing or should know plaintiffs suffered ongoing abuse and
27 neglect
28
134
Defendant Interim engaged in acts of financial malfeasance based on payments from the
25
COMPLAINT
1 U S Department of Health and Human Services California Department of Social Services and San
2 Bernadino Department of Social Services for plaintiffs JONES JONES and DYSON s placement in
3
4
uncertified
Facility
3 in
violation of
S Code section 1508 unbeknownst to said government funding
agencies with no supervision and little if any contact putting plaintiffs at risk of foreseeable harm as
opposed to immediate removal mandated by law knowing or should know plaintiffs suffered ongoing abuse
6
and neglect
9
10
135
CHUDU breached mandatory statutory duties imposed
by
Section 88063
2 by approving and
monitoring a budget for defendant Interim based on payments from the U S Department of Health and
il
12
13
Services for
14 H
plaintiffs
JONES JONES
and
DYSON
s placement
in
uncertified
Facility
3 in violation of
S Code Section 1508 unbeknownst to said government funding agencies with no supervision and
15 little if any contact putting plaintiffs at risk of foreseeable harm as opposed to immediate removal
16
17
136
18
19
BHUPINDER CHHUDU breached mandatory statutory duties imposed
by
Section 88063
3 by
20 approving and monitoring a budget to cover operating costs based on payments from the U S Department
21
22
of Health and Human Services California Department of Social Services and San Bernadino Department
of
Social Services for
plaintiffs
JONES JONES
and
DYSON
s placement
in
uncertified
Facility
3 in
23
violation of
S Code Section 1508 unbeknownst to said government funding agencies with no
24
25
supervision and little if any contact putting plaintiffs at risk of foreseeable harm as opposed to immediate
26 removal mandated by law knowing or should know plaintiffs suffered ongoing abuse and neglect
27
28
137
by
26
COMPLAINT
Section 88063
3 by accessing and
1 maintaining defendant Interim s level of funding to cover operation costs based on payments from U S
2 Department of Health and Human Services California Department of Social Services and San Bernadino
3 Department of Social Services for plaintiffs JONES JONES and DYSON s placement in uncertified
4
3 in
Facility
violation of
S Code Section 1508 unbeknownst to said government funding agencies
5
6
neglect
9
10
138
BHUPINDER CHHUDU breached mandatory statutory duties imposed by Sections 80000 1 3 and
11
88018 by covering operation costs based on payments from the U S Department of Health and Human
12
Services California Department of Social Services and San Bernadino Department of Social Services for
13
JONES
JONES
and
DYSON
s placement
in
uncertified
Facility
3 in
violation of
S Code
14
plaintiffs
15
Section 1508 unbeknownst to said government funding agencies with no supervision and little if any
16
17

18
139
19
Defendant CEO SUKHWINDER SINGH engaged in acts of financial malfeasance
20 based on payments from the U S Department of Health and Human Services California Department of
21
Social Services and San Bernadino Department of Social Services for plaintiffs JONES JONES and
22 DYSON
s placement
in
uncertified
Facility
3 in
violation of
S Code Section 1508 unbeknownst to
23
said government funding agencies with no supervision and little if any contact putting plaintiffs at risk of
24
25

27
28
140
JONES
and
Defendants OATES WILSON engaged in inimical conduct fo plaintiffs JONES

DYSON
by
maintaining
uncertified
Facility
COMPLAINT
Pool
in
violation of
S Code Section
1508 unbeknownst to said government funding agencies with no supervision and little if any contact
2 putting plaintiffs at risk at foreseeable harm as opposed to immediate removal mandated by law knowing or
3
should know plaintiffs suffered ongoing abuse and neglect
Defendants OATES and WILSON engaged in acts of financial malfeasance by taking
141
5
federal state and county payments for plaintiffs JONES JONES and DYSON placement on pretext
6
defendants
to
Facility
10
Facility
3 were certified
On 11 20 07 defendants OATES WILSON plaintiffs JONES JONES and DYSON moved
142
g
9
and
4 on 14594 Woodworth Way Victorville California
143
Defendants OATES WILSON breached mandatory statutory duties imposed by Sections
11
89234 d
and
89361
by failing
to notify defendant Interim
of
the relocation to
Facility
12
Woodworth
13
144
14
15
g9218
16
Defendants OATES WILSON breached mandatory statutory duties imposed by Section
by failing
145
to
The identical factual
scenario
for
in
approval on
76
1l l
Facility
with regard
to
uncertified
Facility
Dulce
17
and
112
141
with regard
to
uncertified
3 Pool
Facility
repeated with regard to uncertified Facility
18
4 Woodworth
Defendant Interim s administrator defendant KHUSHANUD AZARIAH did not and
19
issue a Certificate
of
Approval
on
Facility
4 Woodworth under Section 89240 a given
20
could not
21
defendants OATES WILSON were not in compliance with licensing regulations defendant Interim made
22
no site visit provided no supervision little if any contact putting plaintiffs JONES JONES and DYSON
23
at risk of foreseeable harm as opposed to immediate removal mandated by law knowirig or should know
24
25
26

146
Defendant Interim continued to engage in acts of financial malfeasance based on payments
28 San Bernadino Department of Social Services for plaintiffs JONES JONES and DYSON s placement in
28
COMPLAINT
Facility
uncertified
4 in
violation
of H
S Code Section 1508 unbeknownst to said government
2 funding agencies with no supervision and little if any contact putting plaintiffs at risk of foreseeable harm
3
as opposed to immediate removal mandated by law knowing or should know plaintiffs suffered ongoing
4
abuse and neglect
5
147
Defendant CEO SUKHWINDER SINGH continued to engage in acts of financial
malfeasance based on payments from U S Department of Health and Human Services California
g Department of Social Services and San Bernadino Department of Social Services for plaintiffs JONES
9
10
JONES
and
DYSON
s placement
in
uncertified
Facility
4 in
violation of
S Code Section 1508
unbeknownst to said government funding agencies with no supervision and little if any contact putting
1T
plaintiffs at risk of foreseeable harm as opposed to immediate removal mandated by law knowing or
12
13

148
14
15 BHUPINDER CHHUDU continued to breach mandatory statutory duties imposed by Section 88063 c
16
2 by approving and monitoring a budget for defendant Interim based on payments from the U S
17
Department of Health and Human Services California Department ofSocial Services and San Bernadino
18
Department of Social Services for plaintiffs JONES JONES and DYSON s placement in uncertified
19
20
Facility
4 in
violation of
21 with no supervision and little if any contact putting plaintiffs at risk of foreseeable harm as opposed to
22
23
neglect
24
149
25
26 BHUPINDER CHHUDU continued to breach mandatory statutory duties imposed by Section 88063 c
27
3 by approving and monitoring a budget to cover operation costs based on payments from the U S
g Department of Health and Human Services California Department ofSocial Services and San Bernadino
29
COMPLAINT
1 Department of Social Services for plaintiffs JONES JONES and DYSON s placement in uncertified
4 in
Facility
violation of
5
neglect
150
g BHUPINDER CHHUDU continued to breach mandatory statutory duties imposed by Section 88063 c
9
10
3 by accessing and maintaining defendant Interim s level of funding to cover operation costs based on
payments from the U S Department of Health and Human Services California Department of Social
11
Services and San Bernadino Department of Social Services for plaintiffs JONES JONES and DYSON s
12
placement
13
in
uncertified
Facility
4 in
violation
of H
14 government funding agencies with no supervision and little if any contact putting plaintiffs at risk of
15 foreseeable harm as opposed to immediate removal mandated by law knowing or should know plaintiffs
16
17
151
18
19
BHUPINDER CHHUDU continued to breach mandatory statutory duties imposed by Sections 80000 1 3
88018
by operating
uncertified
Facility
4 Woolworth
in
violation of
S Code Section 1508
20
and
21
unbeknownst to said governmental funding agencies with no supervision and little if any contact putting
22
plaintiffs JONES JONES and DYSON at risk of foreseeable harm as opposed to immediate removal
23
24
152
Defendants OATES WILSON continued to engage in conduct inimical to plaintiffs JONES
25
26
27
28
JONES
and
Woodworth
DYSON
health
in violation
of
morals
welfare
and
safety
by
operating
uncertified Facility
S Code Section 1508 unbeknownst to the above alleged governmental
funding agencies with no supervision and little if any contact putting plaintiffs at risk of foreseeable harm
30
COMPLAINT
as opposed to immediate removal mandated by law knowing or should know plaintiffs suffered ongoing
abuse and neglect
153
Defendants OATES WILSON continued to engage in acts of financial malfeasance
by obtaining federal state and county payments for plaintiffs JONES JONES and DYSON s foster care
5
on pretext
defendants
uncertified
OATES WILSON
Facility
and uncertified
Woodworth were
certified while plaintiffs suffered foreseeable ongoing abuse and neglect

154
g
9
10
On 11 11 07 unlawful detainer Case No UDVS 701833 was filed against defendants
OATES WILSON for
nonpayment of rent
3 534 96
on
Facility
13945 Topmast Drive Helendale
California 92342
11
155
On 11 11 07 plaintiffs JONES JONES DYSON and defendants
12
13
OATES WILSON
156
14
resided
in
uncertified
Facility
4 Woodworth
On 12 4 07 defendants OATES WILSON
were evicted
from
1 13945 Topmast
Facility
15 Drive Helendale California 92342 by court order Case No UDVS 701833

16
157
Defendants OATES WILSON
s eviction
from
Facility
13945 Topmast
17
Drive
while also
residing in
uncertified
Facility
Woodworth
was an unusual incident reportable
18
under Section 88061
19
158
20
21
22
88061
Defendant Interim breached mandatory statutory duties imposed by Section
by failing
to report
defendants OATES WILSON S
eviction
from
Facility
13945 Topmast
Drive Helendale California 92342 on 12 4 07
23
159
On 2 1 08 unlawful detainer Case No UDVS 800320 was filed against
24
defendants OATES WILSON for
nonpayment of rent
4 870 00
on uncertified
Facility
25
26
27
28
Woodworth
160
DYSON
On 2 20 08 defendants OATES WILSON plaintiffs JONES JONES and
were evicted
from
uncertified
Facility
4 Woodworth Case No UDVS 800320 for nonpayment
31
COMPLAINT
4 870 00 unbeknownst to the above alleged governmental funding agencies due to financial
of rent
2 malfeasance of defendants Interim defendants directors FREDDIE WILSON AJAY MALHOTRA
3 BHUPINDER CHHUDU defendant CEO SUKHWINDER SINGH defendant administrator

4
KHUSHANUD AZARIAH and defendants OATES WILSON
5
161
and
DYSON
s eviction
from
uncertified
Facility
6
Woodworth
162
11166
nonpayment of
rent
was child abuse under
4 and
Inst Code Section 300 b reportable under Penal Code Section 11166
Wel
9
10
for
by failing
JONES 70NES
and
DYSON
s eviction
from
Facility
11
Woodworth
12
163
13
14
15
11166
by failing
JONES JONES
and
DYSON
s eviction
from
uncertified
Facility
Woodworth was a serious deficiency under Section 89201 s 1 that caused plaintiffs to remain in the
16
custody
ofuncertified
defendants OATES WILSON in violation
of
S Code section 1508 with no
17
18
19
20
21
22
removal mandated by law knowing or should know plaintiffs suffered ongoing abuse and neglect
164
Plaintiffs JONES JONES DYSON and defendants OATES WILSON s eviction from
unauthorized uncertified
Facility
Woodworth due to financial malfeasance of defendants Interim
defendants directors FREDDIE WILSON AJAY MALHOTRA BHUPINDER CHHUDU defendant CEO
23
SUKHWINDER SINGH defendant administrator KHUSHANUD AZARIAH and defendants OATES

24
WILSON constituted an unusual incident under Section 88061 4 and a serious deficiency under Section
25
26 89201 s 1
27
28
165
Defendant Interim breached mandatory statutory duties imposed by Section 88061 4 by
failing to report to the Department that plaintiffs JONES JONES and DYSON were evicted from
32
COMPLAINT
1
2
3
Defendant Interim s breach of mandatory statutory duties imposed by Section 88061 by
166
failing
to
4 Woodworth
Facility
uncertified
report plaintiffs
JONES JONES
and
DYSON
s eviction
from
uncertified
Facility
Woodworth was a serious deficiency under Section 89201 s 1 that caused plaintiffs to remain in the
5
custody
of uncertified
defendants OATES WILSON in
violation of
S Code section 1508 with no
g removal mandated by law knowing or should know plaintiffs suffered ongoing abuse and neglect
9
10
Defendant Interim
167
notify CPS
breach
JONES JONES
of plaintiffs
of
and
mandatory statutory
DYSON
s eviction
duty imposed by
from
Facility
Section 89206
to
Woodworth
11
constituted a serious deficiency under Section 89201 s 1 that caused plaintiffs to remain in the custody
12
13
of uncertified
violation of
S Code section 1508 with no supervision
14 and little if any contact putting plaintiffs at risk of foreseeable harm as opposed to immediate removal
16
On 3 1 08 plaintiffs JONES JONES DYSON defendants OATES WILSON moved to
168
17
Facility
5 on 13547 Silversand Street Victorville
18
169
19
20
21
Sections 89234 d
and
89361
by failing
to notify
defendant Interim
of
the move to
Facility
Silversand
22
170
23
Section 89218
by failing to
for
approval on
Facility
Silversand
24
171
scenario
in
79
111
with regard
to
uncertified
Facility
25
26
Dulce
112
141
uncertified
Facility
Pool
Silversand
158
uncertified
repeated with regard
28
KHUSHANUD AZARIAH breached mandatory statutory duties imposed
uncertified
Facility
33
COMPLAINT
Facility
4 Woodworth
Defendant Interim s administrator defendant
27
to
142
by
operating
Facility
5 without a Certificate of Approval defendant Interim made no site visit provided no
2 supervision little if any contact putting plaintiffs JONES JONES and DYSON at risk of foreseeable
3 harm as opposed to immediate removal mandated by law knowing or should know plaintiffs suffered
4
5
Defendant Interim continued to engage in acts of financial malfeasance based on
172
payments from the U S Department of Health and Human Services California Department of Social
g
Services
in
10
and
San Bernadino Department of Social Services for
violation of
children placed
in
uncertified
Facility
supervision or contact putting the children at risk of foreseeable harm as opposed to immediate removal
11
12
173
13
14 malfeasance based on payments from the U S Department of Health and Human Services California
15 Department of Social Services and San Bernadino Department of Social Services for children placed in
16
uncertified
Facility
5 in
violation of
17
funding agencies with no supervision or contact putting the children at risk of foreseeable harm as
18
19
20
opposed to immediate removal mandated by law knowing or should know plaintiffs suffered ongoing
abuse and neglect
174 Defendants directors FREDDIE WILSON AJAY MALHOTRA and BHUPINDER
21
22
CHHUDU
continued to
breach mandatory statutory duties imposed
by
Section 88063
2 by approving
23
and monitoring a budget based on payments from the U S Department of Health and Human Services
24
California Department of Social Services and San Bernadino Department of Social Services for children
25
26
placed
in
uncertified
Facility
5 in
violation of
27 government funding agencies with no supervision or contact putting the children at risk of foreseeable
34
COMPLAINT
1 ongoing abuse and neglect

2
3
175
CHHUDU continued to breach mandatory statutory duties imposed
by
Section 88063
3 by approving
and monitoring a budget to cover operation costs based on payments from the U S Department of Health
5
arid Human Services California Department of Social Services and San Bernadino Department of Social
6
Services for foster
care provided
in
uncertified
Facility
5 in
violation of
S Code Section 1508
g unbeknownstto said government funding agencies with no supervision or contact putting the children at
9
risk of foreseeable harm as opposed to immediate removal mandated by law knowing or should know
10

11
176
12
13
CHHUDU
continued
to breach mandatory statutory duties imposed
by
Section 88063
3 by accessing
14 and maintaining defendant Interim s level of funding to cover operation costs based on payments from the
15
16
U S Department of Health and Human Services California Department of Social Services and San
Bernadino Department
of
Social Services for foster
care
in
uncertified
Facility
5 in
violation of
17
Code Section 1508 unbeknownst to said government funding agencies with no supervision or contact
18
19 putting the children at risk of foreseeable harm as opposed to immediate removal mandated by law
20 knowing or should know plaintiffs suffered ongoing abuse and neglect
21
22
177
CHHLJDU continued to breach mandatory statutory duties imposed by Sections 80000 1 3 and 88018 by
23
operating
uncertified
Facility
Silversand in
violation of
24
25
the above alleged governmental funding agencies with no supervision or contact putting the children at
26 risk of foreseeable harm as opposed to immediate removal mandated by law knowing or should know
28
178
Defendant Interim breached mandatory statutory duties imposed by Section 89205
35
COMPLAINT
1 in or about 3 09 by holding out uncertified defendants OATES WILSON and uncertified Facility 5
2
Silversand as certified to the placing CPS agency
In or about 3 09 defendant Interim placed plaintiffs siblings S ADAMS dob 10 31 92 and
179
4
S ADAMS 2 8 94 in
uncertified
Facility
Silversand
Defendants Interim knew or should have known shortly after placement that plaintiffs
180
6
ADAMS
g
9
10
personal rights under
were violated
assaulted
by
by
uncertified
Sections 89372 1
defendant Oates
adult son
Dwayne
including but
not
10
limited to
11
16
20
23
1 sexually
2 forced to scrub walls floors vacuum and sweep
floors lift rugs move and replace furniture clean toilets kitchen
and bedrooms nightly several hours
11
3 not allowed to eat the same food as defendants OATES WILSON family
deprivation
causing sleep
12
13
14 in
15
16
not allowed
to
eat at
constant state of
the same table as
hunger
entering the food pantry
suffered
sleep deprivation
suffered corporal punishment
abuse and neglect of plaintiffs JONES
deprived of adequate food
7 prohibited from opening the refrigerator or

physical and mental
abuse
9 witnessed the
JONES and DYSON among others
17
181 Defendant Interim continued to engage in acts of financial malfeasance based on payments
18
from the U S Department of Health and Human Services California Department of Social Services and
19
Department
20 San Bernadino
21
22
in
violation of
of
Social Services for
plaintiffs
ADAMS
placement
in
uncertified
Facility
supervision and little if any contact putting plaintiffs ADAMS ADAMS JONES JONES and DYSON
23
among others at foreseeable risk of harm as opposed to immediate removal mandated by law knowing or
24
25
26

182
28 Department of Social Services and San Bernadino Department of Social Services for plaintiffs ADAMS
36
COMPLAINT
placement
in
uncertified
Facility
5 in
violation of
2 government funding agencies with no supervision and little if any contact putting plaintiffs ADAMS
3 ADAMS JONES JONES and D YSON among others at risk of foreseeable harm as opposed to
4
5
neglect
6
183
g BHUPINDER CHHUDU continued to breach mandatory statutory duties imposed by Section 88063 c
9
10
2 by approving and monitoring a budget based on payments from the U S Department of Health and
11
Services for
plaintiffs
ADAMS
placement
in
uncertified
Facility
5 in
violation of
S Code Section
12
13
14 putting plaintiffs ADAMS ADAMS JONES JONES and DYSON among others at risk of foreseeable
16
17
184
18
CHHUDU
continued to
19
breach mandatory statutory duties imposed by Section 88063
3 by approving
20 and monitoring a budget to cover operating costs based on payments from the U S Department of Health
21
22
and Human Services California Department of Social Services and San Bernadino Department of Social
Services for
plaintiffs
ADAMS
placement
in
uncertified
Facility
5 in
violation of
S Code Section
23
24
25
putting plaintiffs ADAMS ADAMS JONES JONES and DYSON among others at risk of foreseeable
27 ongoing abuse and neglect
28
185
37
COMPLAINT
1
2
BHUPINDER CHHUDU continued to breach mandatory statutory duties imposed by Section 88063 c
3 by accessing and maintaining defendant Interim s level of funding based on payments the U S
4
Department
of
Social Services for
plaintiffs
ADAMS
placement
in
uncertified
Facility
5 in violation of
5
H
S Code Sectiori 1508 unbeknownst to said governmerit funding agencies with no supervision and
little if any contact putting plaintiffs ADAMS ADAMS JONES JONES and DYSON among others at
g risk of foreseeable harm as opposed to immediate removal mandated by law knowing or should know
9
10
186
11
CHHUDU continued to breach mandatory statutory duties imposed by Sections 80000 1 3 and 88018 by
12
13
operating
uncertified
Facility
Silversand
in
violation of
14 the governmental funding agencies alleged herein with no supervision and little if any contact putting
15 plaintiffs ADAMS ADAMS JONES JONES and DYSON among others at risk of foreseeable harm as
16
17
abuse and neglect
18
187
19
20
In or about 3 09 defendant Interim placed plaintiffs siblings S GALVAN dob 7 8 93 and
M GALVAN in
uncertified
5 Silv ersand
Facility
in
violation of
S Code Section 1508 in the
21 custody of uncertified defendants OATES WILSON

22
188
Deferidant Interim knew or should know that shortly after placement plaintiffs GALVANS
23
personal rights under
Sections 89372 1
10
11
16
20
23 were
24
26
violated
by
plaintiff
S GALVAN S
25
uncertified
sexual
abuse
including
but
not
uncertified
limited to
Facility
5 Silversand in addition to
1 forced to scrub walls floors
27 vacuum and sweep floors lift rugs move arid replace furniture clean toilets kitchen and bedrooms
28
nightly
not allowed
to
eat the same
food
as
38
COMPLAINT
family
not allowed to
1
2
3
eat at
the same table as
prohibited
defendants Oates
from opening
physical and mental
abuse
the
and
refrigerator
Wilson
or
deprived
of adequate
food
5 sleep deprivation
suffered corporal punishment
8 witnessing the abuse and neglect of plaintiffs JONES JONES and DYSON
4
among others
189
g San Bernadino Department of Social Services for plaintiffs GALVANS placement in uncertified Facility
9
10
5 in
violation of
supervision and little if any contact putting plaintiffs GALVAN GALVAN JONES JONES and
11
DYSON among others at risk of foreseeable harm as opposed to immediate removal mandated by law
12
13
14

190
16
Department of Social Services and San Bernadino Department of Social Services for plaintiffs
17
GALVANS
placement
in
uncertified
Facility
5 in
violation of
S Code Section 1508 unbeknownst
18
19
to said government funding agencies with no supervision and little if any contact putting plaintiffs
20 GALVAN GALVAN JONES JONES and DYSON among others at risk offoreseeable harm as
21
22
abuse and neglect
23
191
24
CHHUDU
continued
25
by
Section 88063
2 by approving
26 and monitoring a budget for defendant Interim based on payments from the U S Department of Health and
27 Human Services California Department of Social Services and San Bernadino Department of Social
28
Services for
plaintiffs
GALVANS
placement
in
uncertified
39
COMPLAINT
Facility
5 in
violation of
S Code
2 contact putting plaintiffs GALVAN GALVAN JONES JONES and DYSON among others at risk of
4
5
192
6
CHHUDU
continued to
by
Section 88063
3 by approving
g and monitoring a budget to cover operation costs based on payments from the U S Department of Health
9
10
Services for
plaintiffs
GALVANS
placement
in
uncertified
Facility
5 in
violation of
S Code
11
12
13
contact putting plaintiffs GALVAN GALVAN JONES JONES and DYSON among others
14 at risk of foreseeable harm as opposed to immediate removal mandated by law knowing ar should know
16
193
17
CHHUDU
continued
by
Section 88063
3 accessing and
18
19
maintaining defendant Interim s level of funding based on payments from the U S Department of Health
20 and Human Services California Department of Social Services and San Bernadino Department of Social
21
22
Services for
plaintiffs
GALVANS
placement
in
uncertified
Facility
5 in
violation of
S Code
23
contact putting plaintiffs GALVAN GALVAN JONES JONES and DYSON among others at risk of
24
25

27
194
Defendants directors FREDDIE WILSON AJAY MALHOTR A and BHUPINDER
28 CHHUDU continued to breach mandatory statutory duties imposed by Sections 80000 1 3 and 88018 by
40
COMPLAINT
operating
uncertified
Facility
Silversand in
violation of
S Code Section 1508 with no
2 supervision and little if any contact putting plaintiffs GALVAN GALVAN JONES JONES and
3 DYSON among others at risk of foreseeable harm as opposed to immediate removal mandated by law
4

5
195
On 8 25 09 defendants OATES WILSON plaintiffs JONES JONES DYSON and M
6
GALVAN
were evicted
from
uncertified
Facility
Silversand
for nonpayment of rent for six months
8 400 00 Case No UDVS 902368
San Bernadino Sheriffs locked plaintiffs JONES JONES DYSON M GALVAN
196
10
out of uncertified
Facility
5 Silversand exercising a Writ of Possession
11
permitting plaintiffs five minutes to retrieve few if any personal belongings carried away in plastic bags
12
Defendants OATES WILSON plaintiffs JONES JONES DYSON and M GALVAN
197
13
14
ere homeless for five months from on or about 8 25 09 to 1 1 10
15
198
16
eviction
from
Defendants OATES WILSON plaintiffs JONES JONES DYSON and M GALVAN s
uncertified
Facility
5 for nonpayment of 8 400 00 rent followed by five months
17
homelessness was due to financial malfeasance of defendants Interim directors FREDDIE WILSON
18
19
AJAY MALHOTRA BHUPINDER CHHUDU
CEO SUKHWINDER SINGH administrator
20 KHUSHANLJD AZARIAH and OATES WILSON alleged hereinabove with particularity

21
22
199
Plaintiffs JONES JONES DYSON
and
GALVAN
s eviction
from
uncertified
Facility
for nonpayment of rent and homelessness for five months was child abuse under Health and Safety Code
23
Section 1531 5
and
Welf
Inst Code Section 300 b reportable under Penal Code Section 11166
24
200
25
26
11166 by failing to report plaintiffs JONES JONES DYSON and GALVAN s eviction from uncertified
27
Facility
5 and homelessness causing plaintiffs to remain homeless in the custody of homeless uncertified
28 defendants OATES WILSON with no supervision and little if any contact putting plaintiffs at risk of
41
COMPLAINT

3
201
11166 by failing to report plaintiffs JONES JONES DYSON and GALVAN s eviction from uncertified
5
Facility
5 and homelessness were serious deficiencies under Section 89201 s
1 causing plaintiffs to
remain homeless in the custody of homeless uncertified defendants OATES WILSON with no supervision
and little if any contact putting plaintiffs at risk of foreseeable harm as opposed to immediate removal
9
mandated by law knowing or should know plaintiffs suffered ongoirig abuse and neglect
10
202
Plaintiffs
JONES JONES
DYSON GALVAN defendants OATES WILSON s eviction
11
from
uncertified
Facility
5 and homelessness due to financial malfeasance ofdefendants Interim
12
13
defendants directors FREDDIE WILSON AJAY MALHOTRA and BHUPINDER CHHUDU defendant
14 CEO SUKHWINDER SINGH and defendants Oates Wilson constituted an unusual incident under Section
15 gg061 4 and a serious deficiency under Section 89201 s 1

16
203
17
failing to report plaintiffs JONES JONES DYSON and GALVAN s eviction from uncertified Facility
18
19
20
21
22
5 homelessness no supervision and little if any contact causing plaintiffs to remain homeless with
uncertified
homeless defendants OATES WILSON in
violation of
S Code Section 1508
unbeknownst to said government funding agencies with no supervision and little or no contact putting
plaintiffs at risk of foreseeable harm as opposed to immediate removal mandated by law knowing or
23

24
204
25
Defendant Interim s breach of mandatory statutory duties imposed by Section 88061 by
26 failure to report plaintiffs JONES JONES DYSON and GALVAN s eviction and homelessness was a
27
28
serious deficiency under Section 89201 s 1 that caused plaintiffs to remain homeless with uncertified
violation of
q2
COMPLAINT
S Code Section 1508 with no supervision and
little if any contact putting plaintiffs at risk of foreseeable harm as opposed to immediate removal
3
205
Defendant Interim s breach of mandatory statutory duties imposed by Section 89206 fl by
failing to notify CPS of plaintiffs JONES JONES DYSON and GALVAN s eviction and homelessness
5
constituted a serious deficiency under Section 89201 s
1 that caused plaintiffs to remain homeless in
6
the
custody
of uncertified
violation of
S Code Section
1508 with no supervision and little if any contact putting plaintiffs at risk of foreseeable harm as opposed
9 to immediate removal mandated by law knowing or should know plaintiffs suffered ongoing abuse and
10
neglect
11
206
12
13
14 San Bernadino Department of Social Services for plaintiff GALVAN s placement in a purported certified
15 facililty while plaintiffs GALVAN JONES JONES and DYSON were homeless in the custody of
16
homeless
uncertified
violation of
S Code Section 1508 unbeknownst
17
to said government funding agencies with no supervision and little if any contact putting plaintiffs at risk
18
19
20
21
22
of foreseeable harm as opposed to immediate removal mandated by law knowing or should know plaintiffs
207
malfeasance based on payments from the U S Department of Health and Human Services California
23
Department of Social Services and San Bernadino Department of Social Services for plaintiff GALVAN s
24
25
26
placement in a purported certified facility while plaintiffs GALVAN JONES JONES and DYSON were
homeless
in the custody
of
homeless
uncertified
violation of
S Code
27 Section 1508 unbeknownst to said government funding agencies with no supervision and little if any
28
43
COMPLAINT
2
3
208
CHHUDU continued to breach mandatory statutory duties imposed
by Section
88063
2 by approving
and monitoring a budget based on payments from the U S Department of Health and Human Services
5
California Department of Social Services and San Bernadino Department ofSocial Services for plaintiff
6
GALVAN s placement in a purported certified home whereas plaintiff was homeless in violation of H
g S Code Section 1508 unbeknownst to said governrnent funding agencies with no supervision and little if
9
any contact putting plaintiffs M GALVAN JONES JONES and DYSON M GALVAN at risk of
10
foreseeable harm as opposed to immediate removal mandated by law knowing or should know plairitiffs
11
12
209
13
14
WILSON
15
16
On 1 1 10 plaintiffs JONES JONES DYSON M GALVAN defendants OATES
moved
210
g9234 d
to
6 on 13141 Snowview Road Victorville
Facility
Defendants OATES WILSON breached mandatory statutory duties imposed by Sections
and
89361
by failing to riotify
defendant Interim of the move to
Facility
Snowview
17
211
Defendants OATES WILSON breached mandatory statutory duties imposed by Section
18
19
g9218
212
20
21
22
by failing to
Dulce
112
Facility
141 with
regard
Woodworth
168
for
approval on
scenario alleged
to uncertified
186 with
in
Facility
regard
to
Facility
79
111
Pool
uncertifiecl
6 Snowview
with regard
142
Facility
to
uncertified
Facility
158 with regard to uncertifie

Silversand repeated with
23
regard
to
uncertified
Facility
Snowview
Defendant Interim s administrator defendant
24
25
26
KHUSHANLJD AZARIAH breached mandatory statutory duties imposed
failing
to issue
Certificate
of
Approval
on
Facility
6 Silversand
by
defendant Interim made no site visit
27 provided no supervision little if any contact putting plaintiffs JONES JONES and DYSON at risk of
44
COMPLAINT
213
4
San Bernadino Department of Social Services for plaintiff GALVAN s placement in uncertified Facility
5
6 in
violation of
supervision and little if any contact putting plaintiffs GALVAN JONES JONES and DYSON among
g others at risk of foreseeable harm as opposed to immediate removal mandated by law knowing or should
9 know plaintiffs suffered ongoing abuse and neglect

10
214
11
malfeasance by payments from the U S Department of Health and Human Services California Department
12
13
f Social Services and San Bernadino Department of Social Services for plaintiff GALVAN s placement
14 in
uncertified
Facility
6 in
violation of
15 funding agencies with no supervision and little if any contact putting plaintiffs GALVAN JONES
16
JONES and DYSON among others at risk of foreseeable harm as opposed to immediate removal
17
18
19
215
CHHUDU
21
and monitoring a budget for defendant Interim based on payments from the U S Department of Health and
22
continued to
Section 88063
20
by
2 by approving
23
Services for
plaintiff
GALVAN
s placement
in
uncertified
Facility
6 in
violation of
S Code Section
24
25
26 putting plaintiffs GALVAN JONES JONES and DYSON among others at risk of foreseeable harm as
27 opposed to immediate removal mandated by law knowing or should know plaintiffs suffered ongoing
28
abuse and neglect
45
COMPLAINT
r ri
1
2
3
216
CHHUDU
continued to
by
Section 88063
3 by approving
4
5
Services for
plaintiff
GALVAN
s placement
in
uncertified
6 in
Facility
violation of
S Code Section
g putting plaintiffs GALVAN JONES JONES and DYSON among others at risk of foreseeable harm as
9
10
abuse and neglect
11
217
12
13
CHHUDU
continued to
by
Section 88063
3 by accessing
14 and maintaining defendant Interim s level of funding to cover operation costs based on payments from the
15 the U S Department of Health and Human Services California Department of Social Services and Sari
16
of
Social Services for
plaintiff
GALVAN
s placement
in
uncertified
Facility
6 in
17
violation of
18
19
supervision and little if any contact putting plaintiffs GALVAN JONES JONES and DYSON among
20 others at risk of foreseeable harm as opposed to immediate removal mandated by law knowing or should
21
22

218
23
24
25
operating
uncertified
Facility
Snowview
in
violation of
26 governmental funding agencies with no supervision and little if any contact putt ing plaintiffs GALVAN
27 JONES JONES and DYSON among others at risk of foreseeable harm as opposed to immediate removal
28
46
COMPLAINT
219
1
2
operating
Defendants uncertified OATES WILSON continued to engage in inimical conduct by
uncertified
220
Facility
Snowview
in
violation of
S Code Section 1508
Defendants OATES WILSON continued to engage in acts of financial malfeasance
by taking
federal
state
and
county
payments
for
plaintiff
GALVAN
foster
care
in
uncertified
Facility
5
Snowview
in
violation of
S Code Section 1508 unbeknownst to governmental funding agencies
6
On
221
Snowview
222
1 25 10 defendant Interim
or about
defendants Oates
with uncertified
and
placed plaintiff
Wilson in
SAIS in
violation of
uncertified
Facility
S Code Section 1508
Defendant Interim knew or should have known shortly after placement that plaintiffSAIS
10
personal rights under sections
89372 1
10
11
16
20
23
were
11
violated
in
Facility
Snowview
including but
not
limited to
forced to scrub walls floors vacuum
12
and
13
14
15
sweep floors lift
rugs
food
allowed
to eat the same
table as
defendants 0ates
16
prohibited
move and replace
from opening
as
and
the
furniture
defendants Oates
Wilson
refrigerator
or
and
clean
Wilson
toilets
kitchen
family
deprived of adequate food

and
bedrooms nightly
not
not allowed to eat at the same
suffered
sleep deprivation
7 suffered corporal punishment
17
physical and mental abuse
8 witnessed the abuse and neglect of plaintiffs JONES JONES and DYSON
18
19
20
21
22
among
others
223
coerced and threatened to lie to social workers
San Bernadino Department
of
Social Services for
plaintiff
SAIS
placement
in
uncertified
Facility
6 in
23
violation of
24
25
supervision and little if any contact putting plaintiffs SAIS JONES JONES and DYSON among others
26 at risk of foreseeable harm as opposed to immediate removal mandated by law knowing or should know
28
224
47
COMPLAINT
r
1
2 Department of Social Services and San Bernadino Department of Social Services for plaintiff SAIS
3
placement
in
uncertified
Facility
6 in
violation of
government funding agencies with no supervision and little if any contact putting plaintiffs SAIS
5
6
JONES JONES and DYSON among others at risk of foreseeable harm as opposed to immediate removal
225
CHHUDU
continued
to
by
Section 88063
2 by approving
10
and monitoring a budget based on payments obtained from the U S Department of Health and Human
11
Services California Department of Social Services and San Bernadino Department of Social Services for
12
13
SAIS
plaintiff
foster
care provided
in
uncertified
Facility
6 in
violation of
S Code Section 1508
14 unbeknownst to said government funding agencies with no supervision and little if any contact putting
15 plaintiffs SAIS JONES JONES and DYSON among others at risk of foreseeable harm as opposed to
16
17
neglect
18
19
226
20 CHHUDU
21
22
continued to
by
Section 88063
3 by approving
23
Services for
plaintiff
SAIS foster
care provided
in
uncertified
Facility
6 in
violation of
S Code
24
25
26 contact putting plaintiffs SAIS JONES JONES and DYSON among others at risk of foreseeable harm as
27 opposed to immediate removal mandated by law knowing or should know plaintiffs suffered ongoing
28
abuse and neglect
4s
COMPLAINT
2
3
Defendants directars FREDDIE WILSON AJAY MALHOTRA and BHUPINDER
227
CHHUDU
continued to
by
Section 88063
3 by accessing
and maintaining defendant Interim s level of funding to cover operation costs based on payments from the
4
the U S Department of Health and Human Services California Department of Social Services and San
5
of
Social Services for
plaintiff
SAIS
placement
in
uncertified
Facility
6 in
6
violation of
9
at risk of foreseeable harm as opposed to immediate removal mandated by law knowing or should know
10
ll
228
12
13
14 operating
uncertified
Facility
Snowview
in
violation of
15 governmental funding agencies alleged herein with no supervision and little if any contact putting
16
plaintiffs SAIS JONES JONES and DYSON among others at risk of foreseeable harm as opposed to
17
18
neglect
19
229
20
21
In or about 12 10 defendant JOEL DOMINQUEZ came on board as defendant Interim s
Administrator
22
230
Defendant JOEL DOMINQUEZ continued to
operate uncertified
Facility
6 Snowview
23
certified
in breach
of
mandatory duties imposed
by
24
25
governmental funding agencies alleged herein with no supervision and little if any contact putting
26 plaintiffs SAIS JONES JONES and DYSON among others at risk of foreseeable harm as opposed to
27 immediate removal mandated by law knowing or should know plaintiffs suffered ongoing abuse and
28
neglect
49
COMPLAINT
as
On 12 8 10 unlawful detainer Case No UDVS 1004160 was filed against defendants Oates
231
1
and
Wilson
on uncertified
232
On 2 23 11
Facility
Snowview
defendants OATES WILSON plaintiffs JONES JONES DYSON and SAIS
4
were evicted
from
uncertified
Facility
6 Snowview by court order No UDVS 1004160 unbeknownst to
governmental funding agencies alleged herein

6
233
Defendants OATES WILSON plaintiffs JONES JONES DYSON and SAIS eviction
g for nonpayment of rent was due to financial malfeasance of defendants Interim directors FREDDIE
9 WILSON AJAY MALHOTRA BHUPINDER CHHUDU CEO SUKHWINDER SINGH and

10
administrator JOEL DOMINQUEZ alleged hereinabove with particularity

11
234
Defendant Interim breached mandatory statufory duties imposed by Penal
12
13 Code Section 11166 by failing to report plaintiffs JONES JONES DYSON SAIS eviction from
14
Facility
uncertified
Snowview
15
235
16
1
18
19
By failing
Defendant Interim s breach of mandatory duties imposed by Penal Code Section 11166
JONES JONES DYSON SAIS
Snowview was a serious deficiency under Section 89201 s

uncertified
violation of
eviction
from
uncertified
Facility
1 causing plaintiffs to remain with

20
and little if any contact putting plaintiffs SAIS JONES JONES and DYSON among others at risk of
21
22
23
foreseeable harm as opposed to immediate removal mandated by law knowirig or should know plaintiffs
24
236
Plaintiffs
JONES JONES DYSON SAIS and defendants OATES WILSON s eviction
25
26
from
unauthorized
uncertified
Facility
6 Snowview due to financial malfeasance of defendants Interim
27 defendants directors FREDDIE WILSON AJAY MALHOTRA BHUPINDER CHHUDU defendant

2g CEO SUKHWINDER SINGH defendant administrator JOEL DOMINQUEZ and defendants Oates and
50
COMPLAINT
Wilson constituted an unusual incident under Section 88061 4 and a serious deficiency under Section
89201 s
3
237
failing
JONES JONES DYSON
and
SAIS
eviction
from
uncertified
Facility
6
7
Snowview
238
Defendant Interim s breach of mandatory statutory duties imposed by Section
9 88061 by failure to report plaintiffs JONES JONES DYSON and SAIS eviction from uncertified
10
Facility
Snowview
was a
serious
deficiency
under
Section 89201
that caused plaintiffs to
11
remain with uncertified
violation of
S Code Section 1508 with no
12
13
14
15
16
239
Defendant Interim breached mandatory statutory duties imposed
by
Section 89206
by
failing to
notify CPS
of plaintiffs
JONES JONES DYSON
and
SAIS
eviction
from
Facility
18
Snowview constituting a serious deficiency under Section 89201 s
1 causing plaintiffs to remain with
19
uncertified
20
21
violation of
and little if any contact putting plaintiffs SAIS JONES JONES and DYSON among others at risk of
23
24
240
In 3 11
plaintiffs JONES
JONES DYSON and SAIS defendants OATES WILSON
25
moved
26
27
28
to
Facility
241
7 on Bluegrass in Victorville
Defendants knew or should have known after placement that plaintiffs JONES JONES
DYSON SAIS
personal rights under sections
89372 1
51
COMPLAINT
10
11
16
1
2
3
20
23
were violated
including
replace
but
not
furniture
by
defendants Oates
uncertified
limited to
and
Wilson in
uncertified
Facility
7 Bluegrass
1 forced to scrub walls floors vacuum and sweep floors lift rugs move and
kitchen
clean toilets
and
bedrooms nightly
2 not allowed to eat the same food as
4
family
not allowed to eat at the same table as defendants
5
4
OATES WILSON
deprived
food
of adequate
suffered
6
the
opening
g
9
abuse
refrigerator or
witnessed
the abuse and neglect of plaintiffs
sleep deprivation
6 prohibited from
suffered corporal punishment physical and mental
JONES JONES
and
DYSON among
others
coerced and threatened to lie to social workers
10
242 Defendants OATES WILSON breached mandatory statutory duties imposed by Sections
11
89234 d
and
89361
by failing
to notify deferidant Interim
of
the
move
to
uncertified
Facility
12
13
Bluegrass
243
14
15
g9218
16
Defendants OATES WILSON breached mandatory statutary duties imposed by Section
by failing
244
to submit an application
for
approval on
scenario alleged
79
in
Facility
111
Bluegrass
with regard
to uncertified
Facility
17
Dulce
112
141
Facility
Pool
142
158
Facility
4 Woodworth
168
186 Facility
18
5 Silversand
209 231
19
20
21
22
Bluegrass
of
Approval
little if any
Facility
Snowview
was repeated witli regard
to uncertified
Facility
Defendant Interim s administrator defendant JOEL DOMINGUEZ did not issue a Certificate
on
Facility
contact
7 Bluegrass
putting
plaintiffs
defendant Interim made no site visit provided no supervision
SAIS
JONES JONES and DYSON at risk of foreseeable harm
23
knowing or should know plaintiffs suffered ongoing abuse and neglect as opposed to immediate removal
24
25
26
27
28
mandated by law
245
San Bernadino Department
of
Social Services for
plaintiff
SAIS
52
COMPLAINT
placement
in
uncertified
Facility
7 in
violation of
2 supervision and little if any contact putting plaintiffs SAIS JONES JONES and DYSON among others
3
4
5
246
Defendant CEO SUKHWINDER SINGH continued to engage in acts offinancial
6
g
9
Department of Social Services and San Bernadino Department of Social Services for plaintiff SAIS
placement
in
uncertified
Facility
7 Bluegrass
in
violation of
10
said government funding agencies with no supervision and little if any contact putting plaintiffs SAIS
11
JONES JONES and DYSON among others at risk of foreseeable harm as opposed to immediate removal
12
13
247
14
15
CHHUDU
continued
by
Section 88063
2 by approving
16
and monitoring a budget for defendant Interim based on payments from the U S Department of Health and
17
Human
ervices California Department of Social Services and San Bernadino Department of Social
18
Services for
plaintiff
SAIS
placement
in
uncertified
19
20 H
21
Facility
7 Bluegrass
in violation of
little if any contact putting plaintiffs SAIS JONES JONES and DYSON among others at risk of
22
23
24
248
25
26
CHHUDU

continued
to
breach mandatory statutory
duties
imposed
by
Section 88063
3 by approving
27 and monitoring a budget to cover operation costs based on payments from the U S Department of Health
28
53
COMPLAINT
1
2
Services for
plaintiff
SAIS
placement
in
uncertified
Facility
Bluegrass
in violation of
3 little if any contact putting plaintiffs SAIS JONES JONES and DYSON among others at risk of
4
5
6

249
CHHUDU
9
10
continued to
by
Section 88063
3 by accessing
and maintaining defendant Interim s level of funding to cover operation costs based on payments from the
U S Department of Health and Human Services California Department of Social Services and San
11
of
Social Services for
plaintiff
SAIS
placement
in
uncertified
Facility
12
13
14
15
16
Bluegrass
in
violation of
ith no supervision and little if any contact putting plaintiffs SAIS JONES JONES and DYSON
ong others at risk of foreseeable harm as opposed to immediate removal mandated by law knowing or
17
250
Defendants directors FREDDIE WILSON AJAY MALHATRA and BHUPINDER
18
CHHUDU
continued to
19
20 operating
21
22
uncertified
Facility
Bluegrass
in
violation of
by
Sections 80000 1
3 and 88018 by
governmental funding agencies alleged herein with no supervision and little if any contact putting
plaintiffs SAIS JONES JONES and DYSON among others at risk of foreseeable harm as opposed to
23
24
neglect
25
251
26
27 illegal
28
Defendants OATES WILSON continued to engage in inimical conduct by operating
uncerti ced
Facility
7 Bluegrass in
violation of
governmental funding agencies alleged herein
54
COMPLAINT
S Code Section 1508 unbeknownsf to
252 Defendants OATES WILSON continued to engage in acts of financial malfeasance by
1
2
3
taking federal
state
and
county
payments
for
plaintiff
SAIS
foster
care
in
uncertified
Facility
Bluegrass unbeknownst to governmental funding agencies alleged herein
4
253
On 3 4 11 the state licensed defendant OATES to operate a family child care home at the
5
same
location
as uncertified
7 Bluegrass apparently unaware defendant was uncertified and
Facility
6
operated at least six uncertified homes since 6 07 with four evictions and five months homeless due to
g defendants financial malfeasance alleged above with particularity

9
In ar about 10 18 11 defendant RAMNIT came on board as defendant Interim s
254
10
administrator
11
255
Defendant RAMNIT continued to hold out uncertified defendants OATES WILSON to the
12
13
14
placement CPS as certified in breach of mandatory statutory duties imposed by Section 89250 to procure
and maintain placements
for
uncertified
Facility
Bluegrass in
violation of
S Code Section 1508
15 unbeknownst to said governmental funding agencies

16
256
Defendant RAMNIT
continued
to operate uncertified
Facility
7 in violation of Health and
17
Safety
Code Section 1508 to
procure and maintain more
foster
child placements
for
uncertified
Facility
18
Bluegrass
19
257
20
21
22
Approval to
On 1 20 12 defendant administrator RAMNIT issued defendant WILSON a Certificate of
operate a certified
family
home located
at a
different location
than uncertified
Facility
Bluegrass
23
258
Defendant RAMNIT and thereby breached mandatory statutory duties imposed by Section
24
89240
25
namely defendant WILSON was in noncompliance with applicable licensing regulations since
26 6 07 operated six uncertified facilities for a period of five years including numerous evictions for
27 nonpayment of rent homelessness due to financial malfeasance
28
259
On 10 3 12 defendant Interim revoked defendants OATES WILSON s Certificate of
55
COMPLAINT
Approval
on
1 issued on 11 16 06
Facility
260
On 6 25 13 the California Department of Social Services Department filed and served
3 ACCUSATION CDSS No 6712269202 against defendants OATES WILSON to revoke the Certificate of
4
Approval defendant Interim issued
on
11
16 06
on
Facility
1 purportedly located on Bluegrass
5
261
According to the ACCUSATION defendant Interim issued defendant OATES one
Certificate of Approval on 11 16 06 in effect untilrevoked 10 3 12 whereas defendant OATES lived in 8

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

10
262
Unbeknownst
to the
Department
Facility
was not
located
on
Bluegrass
Facility
1 was
11
located on 13945 Topmast Drive Helendale California 92342 defendants Oates Wilson were evicted
12
13
from
Facility
Topmast on 12 4 07 UDVS 701833 defendants OATES WILSON did not reside on
14 Bluegrass unti12011
15
16
263
Exemption
ACCUSATION CDSS No 6712269202 petitioned to
Rescind Previous Criminal Record
of defendant Wilson
17
264
ACCUSATION CDSS No 6712269202 alleged
CONDUCT INIMICAL under Health and
18
19
Safety Code
section
1558
Estes
arms
pushed her against a wall and pinned her arms above her head and
20
will
21
committed a battery upon her with sexual intent Additionally defendant Wilson made a statement to the
22
grabbed plaintiff
On or about April 16 2012 defendant Wilson forcibly and against her
effect that he was going to commit a forcible sex act upon her person making Estes fearful that she was
23
going to be raped
24
265
25
ACCUSATION CDSS No 6712269202 alleged PHYSICAL ABUSE PERSONAL
26 RIGHTS VIOLATIONS
27
28
section
89372
as
follows
defendant Wilson
struck
under Health and
18
Safety
Code
sections
1534 b
1558
1596 885
Regulation
Between and on or about November 16 2006 to October 12 2012
three foster
children
JONES JONES
56
COMPLAINT
and
DYSON
19 On at least one occasion
during
the
period
from
about
December 2011 through January 2013
defendant Wilson while wearing a
2 cast hit plaintiffD JONES about the body resulting in welts on the buttocks thighs and back
3
Wilson
Additionally
made
threatening
statements to
plaintiff
D JONES
such as
If I wasn t hurt I d get
4
Y u
5
ACCUSATION CDSS No
266
6712269202
20
alleged
In or about March 2012 defendant
Oates made threatening statements to plaintiff D JONES to the effect that she would put him in the
g
hospital
21
In or about February 2012 defendant Oates choked child 4

The ACCUSATION
267
alleged with respect
to
plaintiff
R JONES
that defendant Oates
10
slapped
choked
attempted
to
slammed the child to the ground and
pull off plaintiffls acrylic nails
11
prevented the child from going up the stairs by dragging her down Choked plaintiff R JONESJ
12
ACCUSATION CDSS No
268
13
14 from December 2011

15
through
plaintiffJ in the face causing
16
plaintiffJ
with a spoon
January
2012
bleeding
handle
6712269202
alleged
with respect
to
On several occasions during the period
plaintiff
hit plaintiff with a belt
D JONES
defendant Oates
hit plaintiff with a small bat
hit
stabbed
made plaintiff squat while holding heavy objects for long periods of time
17
as a
form
of
discipline
would pinch plaintif s arms the objects were dropped during that time
18
ACCUSATION CDSS No
269
6712269202
alleged
On several occasions in or about 2011
19
20
21
22
with respect
plaintiffJ
to plaintiff
on
the head
hit plaintiffJ
S DYSON defendant Oates
and about
the
body
on
the
head
with
her fist
hit
made plaintiffJ squat and or run while holding heavy objects
as form of discipline
23
270
ACCUSATION CDSS No 6712269202
alleged
REPORTING REQUIREMENTS
24
Health
25
and
Safety
Code Sections 1534 b
and
1558
Regulation
section
89361
On several
26 occasions during the period from in or about 2011 through in or about March 2012 defendant Wilson
27
28
failed to report incidents of physical abuse or corporal punishment that he witnessed or had been informed
of To wit seeing defendant Oates strike foster children being told defendant Oates had struck a foster
57
COMPLAINT
1
2
child
271
In addition to the findings in the ACCUSATION defendants OATES WILSON assaulted
3 battered and terrorized plaintiffs JONES JONES and DYSON for nearly six years forced plaintiffs to
4
fight other foster children or be beat by defendant Oates not allowed to eat the same food as defendants
5
Oates and Wilson s family
not allowed to eat at the same table as defendants Oates and Wilson
deprived
of adequate food prohibited from opening the refrigerator or entering the food pantry forced to steal food
or go hungry
9
272
In addition defendants OATES WILSON forced D JONES to walk 7 miles to school when
10
his home school was five minutes away forced DYSON to sit in a small banana crate all day and wear
11
shoes so small as to cause permanent damage forced plaintiffs to ask defendant for a glass of water for
12
13
14
15
16
toilet paper for sanitary napkins for tooth paste demeaned and cursed plaintiffs
forced plaintiffs to scrub
alls floors vacuum and sweep floors lift rugs move and replace furniture clean toilets
bathrooms nightly
several
hours in
the
early morning before
school
kitchen and
suffered sleep deprivation forced
plaintiffs to wear used clothes took plaintiffs personal possessions beat plaintiffs with belts shoes
17
anything defendant OATES could find refused to allow plaintiffs JONES JONES and DYSON to wash
18
19
clothes in defendant s washing machine forced plaintiffs to walk or ride one bike four miles to wash their
20 clothes hit in the face causing bleeding slammed in the ground dragged downstairs beat with belts
21
22
forced to run around the block for hours carrying heavy milk gallons filled with water plaintiff SAIS was
forced to walk to school on crutches 3 miles each way
23
273
In addition defendants OATES WILSON assaulted battered and terrorized plaintiffs
24
ADAMS GALVANS and SAIS and forced plaintiffs to witness the abuse and terror of each other and all
25
26 the other children

27
274
The ACCUSATION further
alleged
RECISSION OF PREVIOUS CRIMINAL RECORD
28 EXEMPTION and LACK OF GOOD CHARACTER Health and Safety Code Sections 1522 and
58
COMPLAINT
1558
Regulation Section 89319 defendant Wilson violated the conditions ofthe previous criminal
2 record exemption in that he failed to comply with Licensing laws or regulations failed to continue to
3 demonstrate good character engaged in conduct inimical as alleged in paragraphs 17 18 19 and 25

4
above
5
275
On August 29 2013 the Department issued a default decision against defendant WILSON
finding the factual allegations in the Accusation to be true correct and constitute violations of Health and
Safety Code Sections 1522 1534 b and 1558 a and California Code of Regulations Title 22 Sections
9 89319 89361 and 89372 and grounds under Health and Safety Code section 1522 to rescind defendant
10
wilson s previously granted criminal exemption

11
276
12
13
The Department s duly served Default Decision informed defendant WILSON of the right to
request the decision be vacated within seven 7
days after the Department mailed the default decision and
14 order to defendant Wilson and the procedure to make said request

15
16
277
In or about January 2014 the Department issued a default decision against defendant
OATES finding the factual allegations in the ACCUSATION to be true and correct and constitute
17
violations of Health and Safety Code Sections 1522 1534 b and 1558 a and California Code of
18
Regulations Title 22 Sections 89319 89361 and 89372
19
20
21
22
278
The Department s duly served Default Decision informed defendant OATES of the right to
request the decision be vacated within seven 7 days after the Department mailed the default decision and
order to defendant Oates and the procedure to make said request
23
279
Defendant OATES WILSON did not request the default decision be vacated
280
Defendant Interim maintained little if any contact with plaintiffs providing no supervision
24
25
26 over plaintiffs care in multiple uncertified community care facilities over a period of six years
27
28
281
As a direct result of above alleged acts and omissions plaintiffs suffered severe physical
and mental abuse
trauma humiliation intimidation threats
59
COMPLAINT
embarrassment
and
shame
deprivation of
liberty and freedom and substantial hurt and injury to plaintiffs health strength activity and substantial
2 enduring shock and injury to plaintiffs nervous system mental anguish depression anxiety inability to
3
sleep loss of focus and concentration confusion anger indignity nervousness hopelessness shame fear
4
panic and desperation all of which injuries caused and continue to cause plaintiffs severe mental pain and
5
6
suffering for which defendants are liable

Plaintiffs are informed believe and thereupon allege that said injuries will result in some
282
permanent disability and general damages in an amount which will be stated according to proof pursuant to
9 California Code of Civil Procedure Section 425 10 which amount is in excess of Twenty five Thousand
10
25 000 00
Dollars
11
WHEREFORE PLAINTIFFS PRAY for judgment against defendants and each of them as
12
13
follows
For General Damages in a sum which will be stated according to proof pursuant to the
14 California Code of Civil Procedure which sum is in excess of Twenty Five Thousand Dollars
15
16
25 000 00
2 For
medical and
incident expenses incurred
and
to be incurred in the future
For loss
of earnings incurred and future loss of earning capacity according to proof 4 For pre judgment interest
17
according to
proof
For
costs of suit
incurred herein
and
For such other and further relief as the
18
19
Court deems just and proper
20
21
22
SECOND CAUSE OF ACTION
FOR NEGLIGENCE PER SE
VIOLATION OF MANI ATORY STATUTORY DUTIES
23
PLAINTIFFS DEANDRE JONES REANDRANE JONES ISAIAH SAIS SALEENA GALVAN

24
MARK GALVAN
SURPRISE ADAMS SHAWNA ADAMS
SUAVE DYSON AGAINST
25
26
DEFENDANTS INTERIM SUKHWINDER SINGH FREDDIE WILSON AJAY MALHAOTRA
27
BHUPINDER CHHUDU KHUSHANUD AZARIAH JOEL DOMINGUEZ SHAHZIA RAMNIT
28
LISA OATES NAWAB WILSON and DOES 1 20
60
COMPLAINT
283
284
by
Plaintiffs
1 282 as though fully set forth
reallege
Plaintiffs were dependent children under court supervision within the class to be protected
S Code Section 1508 the statutes and regulations alleged herein who suffered the injuries the
statute and regulations were enacted promulgated to prevent unsafe placements in six uncertified
5
unsupervised community care facilities with uncertified caregivers abuse corporal punishment extreme
6
neglect
g
9
evictions
142
208 Eviction
158
and
homelessness
Facility
Facility
alleged with
159
197
specificity in
167 Eviction
79 111
Facility
208 Homelessness
168
231
209
Facility
186
112 141 Facility
Facility
232
Facility
195
240
10
Eviction
Facility
240
258
Facility
11
285
Defendant Interim breached mandatory statutory duties alleged with specificity in
12
13
14
91 92 93 97 100
189 200 201 203
103
206 213
119 123
124
129
223 234 235 237
131
134
146
158
162
163
165
167 172
178
181
239 245 causing plaintiffs members of the protected
15 class to suffer the injuries the statutes and regulations were enacted promulgated to prevent unsafe
16
placements in six uncertified unsupervised community care facilities with uncertified caregivers abuse
17
corporal punishment extreme neglect evictions and homelessness
18
2g6
19
Defendant SUKHWINDER SINGH breached mandatory statutory duties alleged with
20 specificity in
21
22
64 H
S Code Section
1508
90 108
122
139 147 164 173
182 190
198 207
214 224 246 causing plaintiffs members of the protected class to suffer the injuries the statute and
regulations were enacted to prevent unsafe placements in six uncertified unsupervised community care
23
facilities with uncertified caregivers abuse corporal punishment extreme neglect evictions and
24
homelessness
25
287 Defendants directors FREDDIE WILSON AJAY MALHOTRA and
26
27
28
BHUPINDER CHHUDU breached mandatory statutory duties

136
137
138
148
149 150
151
164
174
175
176 177
61
COMPLAINT
alleged
183
in
184 185
104 105
186
191
106
107 120
192 193
135
194 208
1 215 216 217 218 225 226 227 248 249 150 causing plaintiffs members ofthe protected class to
2 suffer the injuries said statutes regulations were enacted promulgated to prevent unsafe placements in six
3
uncertified unsupervised community care facilities with uncertified caregivers abuse corporal
4
punishment extreme neglect evictions and homelessness
5
288
Defendants administrators KHUSHANUD AZARIAH JOEL DOMINGUEZ and
6
SHAHZIA RAMNIT breached mandatory statutory duties
alleged
in
84 89 116
121
145 164
178
198 212 229 230 233 236 255 256 257 258 causing plaintiffs members of the protected class to
suffer the injuries said statutes regulations were enacted promulgated to prevent unsafe placements in six
10
uncertified unsupervised community care facilities with uncertified caregivers abuse corporal
11
punishment extreme neglect evictions and homelessness

12
2g9
13
As a result of defendants breach of mandatory statutory duties plaintiffs were placed with
14 uncertified defendants OATES WILSON in multiple uncertified homes suffering terror trauma PTSD
15 humiliation intimidation threats embarrassment and shame substantial hurt and injury to plaintiffs
16
health strength activity and substantial enduring shock and injury to plaintiffs nervous system mental
17
anguish depression anxiety inability to sleep loss of focus and concentration confusion anger indignity
18
19
nervousness hopelessness shame
fear panic and desperation all of which injuries caused and continue to
20 cause plaintiffs severe mental pain and suffering for which defendants are liable
21
22
290
23
California Code of Civil Procedure Section 425 10 which amount is in excess of Twenty five Thousand
24
Dollars
25 000 00
25
WHEREFORE
26
27 follows
2g
PLAINTIFFS PRAY for judgment against defendants and each of them as
For General Damages in a sum which will be stated according to proof pursuant to
the California Code of Civil Procedure which sum is in excess of Twenty Five Thousand Dollars
62
COMPLAINT
25 000 00
2 For medical
and
incident
expenses
incurred
and to
be incurred in tlie future
For loss
2 of earnings incurred and future loss of earning capacity according to proof 4 For prejudgment interest
3
according to
proof
For
costs of suit
incurred herein
and
4
5
THIRD CAUSE OF ACTION

6
FOR INTENTIONAL
gNFLICTgON OF EMOTIONAL DISTRESS

9
PLAINTIFFS DEANDRE JONES REANDItANE JONES ISAIAH SAIS SALEENA
10
GALVAN MARK GALVAN
SURPRISE ADAMS SHAWNA ADAMS
SUAVE
11
DYSON AGAINST DEFENDANTS IN
ERIM SUK IWINDER S NGH FREDDIE
12
WILSON AJAY 1VIALHOTRA BHUPINDER CHHITDU
13
14
USHANUD AZARIAH JOEL DOMINGU
15
Z SHAHZIA RAMN T LISA OATES NAWAB
WILSON and DOES 1 20
16
291
Plaintiffs reallege pars 1 290 as though fully set forth
17
292
Defendants operated a kids for cash
scam for six years off the backs of foster children of
18
19
tender years dependent plaintiffs herein to cheat hundreds of thousands of foster care dollars from the U S
21
22
County Department of Social Services for plaintiffs placement in seven illegaUuncertified unlicensed
homes
with uncertified
defendants OATES
and
WILSON in
violation of
S Code Section 1508 with
23
four 4 evictions for none payment of rent and half vear of homelessness with no supervision by and
24
25
diminimus contact knowing or should know plaintiffs suffered ongoing unrestrained relentless torture
26 trauma severe mental and emotional abuse by uncertified caregivers defendants OATES WILSON in
27
79 111
Facility
112 141
Facility
142
158
28
63
COMPLAINT
Facility
159
167 Eviction
Facility
209
168
186
231
Facility
293
Facility
232
195
208 Eviction
240 Eviction
Defendants despicable
outrageous
Facility
Facility
240
kids for cash
5
258
197
Facility
208 Homelessness
scam either intentional or carried out
with reckless disregard for plaintiffs safety shocks the conscience and exceeds all bounds of decency
5
6
usually tolerate d by a decent society of a nature especially calculated to cause and did cause severe
sustained mental and emotional distress
294
9
Defendant Interim held out uncertified defendants OATES WILSON as certified and
operated uncertified
Facility
as certified
in
violation of
S Code Section 1508 abandoned
10
plaintiffs JONES JONES and DYSON providing no supervision and little if any contact putting
11
12
13
plaintiffs at risk of foreseeable harm knowing or should know plaintiffs suffered ongoing abuse and
neglect
295
14
15
uncertified
Defendants directors WILSON MALHOTRA and BHUPINDER CHHUDU held out

16
violation of
as certified and operated uncertified
Facility
2 as certified in
S Code Section 1508 knowing or should know defendant Interim provided no supervision
17
and little if any contact putting plaintiffs JONES JONES and DYSON at risk of foreseeable harm
18
19
296
20
21
22
Defendant SINGH held out uncertified defendants OATES WILSON as certified and
Facility
as certified
in
violation of
S Code Section 1508
knowing or should
know defendant Interim provided no supervision and little if any contact putting plaintiffs JONES
23
JONES and DYSON at risk of foreseeable harm knowing or should know plaintiffs suffered ongoing
24
abuse and neglect
25
297 Defendants uncertified OATES and WILSON held themselves and uncertified Facility
26
27
out
as certified
in
violation of
S Code Section 1508 while abusing and terrorizing plaintiffs knowing
28
plaintiffs suffered severe ongoing pain neglect mental and emotional abuse
64
COMPLAINT
ir
298
1
2
3
Defendant Interim held out defendants uncertified OATES WILSON as certified
and operated uncertified
Facility
as certified
in
violation of
S Code Section 1508 knowing or
should know defendant Interim provideii no supervision and little if any contact putting plaintiffs JONES
S
abuse and neglect
6
299
g
9
Defendants directors WILSON MALHOTRA and BHUPINDER CHHUDU held
out uncertified
in
violation of
Facility
3 as certified
S Code Section 1508 knowing or should know defendant Interim provided no
10
supervision and little if any contact putting plaintiffs JONES JONES and DYSON at risk of foreseeable
11
harm knowing or should know plaintiffs suffered ongoing abuse and neglect
12
13
14
15
16
300
Facility
as certified
in
violation of
S Code Section 1508 knowing or should
ow defendant Interim provided no supervision and little if any contact putting plaintiffs JONES
17
abuse and neglect
18
301
19
Defendarit administrator AZARIAH held out uncertified defendants OATES WILSON as
Facility
violation of
S Code Section 1508
certified and operated uncertified
21
knowing or should know defendant Interim provided no supervision and little if any contact putting
22
as certified
in
20
plaintiffs JONES JONES and DYSON at risk of foreseeable harm knowing or should know plaintiffs
23
24
25
26
302
certified
in
Defendants OATES
violation of
and
WILSON held themselves
and operated uncertified
Facility
S Code Section 1508 provided no supervision and little if any contact
27 putting plaintiffs JONES JONES and DYSON at risk of foreseeable harm knowing or should know
28
65
COMPLAINT
3 as
1
2
303
Facility
as certified
in
violation of
3 know defendant Interim provided no supervision and little if any contact putting plaintiffs JONES
4
5
abuse and neglect
6
304
g
9
uncertified
violation of
Facility
4 as certified in
10
supervision and little if any contact putting plaintiffs JONES JONES and DYSON at risk of foreseeable
11
12
13
14
15
harm knowing or should know plaintiffs suffered ongoing abuse and neglect
305
Facility
as certified
in
violation of
ow defendant Interim provided no supervision and little if any contact putting plaintiffs JONES
16
17
abuse and neglect
18
19
306
Defendant administrator AZARIAH held out uncertified defendants
20 OATES WILSON
21
22
Facility
as certified
in
violation of
S Code
Section 1508 knowing or should know defendant Interim provided no supervision and little if any
contact putting plaintiffs JONES JONES and DYSON at risk of foreseeable harm knowing or should
23

24
307
Defendants OATES and WILSON held themselves out as certified and operated uncertified
25
26
Facility
as certified
in
violation of
S Code Section 1508 knowing or should know defendant
27 Interim provided no supervision and little if any contact while defendants abused and neglected plaintiffs
28
308
66
COMPLAINT
ay
Facility
as certified
in
violation
of H
2 know defendant Interim provided no supervision and little if any contact putting plaintiffs ADAMS
3 ADAMS JONES JONES and DYSON at risk of foreseeable harm knowing or should know plaintiffs
4
5
309
6
uncertified
g
9
10
violation of
as certified and operated
uncertified
Facility
5 as certified in
supervision and little if any contact putting plaintiffs ADAMS ADAMS JONES JONES and DYSON
at risk of foreseeable harm knowing or should know plaintiffs suffered ongoing abuse and neglect
11
310
12
13
14
Facility
as certified
in
violation of
ow defendant Interim provided no supervision and little if any contact putting plaintiffs ADAMS
15 ADAMS JONES JONES and DYSON at risk of foreseeable harm knowing or should know plaintiffs
16
17
311 Defendant administrator AZARIAH held out uncertified defendants OATES WILSON as
18
19
Facility
as certified
in
violation
of H
S Code Section 1508
20 knowing or should know defendant Interim provided no supervision and little if any contact putting
21
22
plaintiffs ADAMS ADAMS JONES JONES and DYSON at risk of foreseeable harm knowing ar should
23
312
Defendant Interim covered up concealed plaintiffs M GALVAN JONES JONES and
24
DYSON
homelessness
with
homeless
uncertified
violation of
25
26 Code Section 1508 knowing or should know defendant Interim provided no supervision and little if any
27 contact putting plaintiffs GALVAN JONES JONES and DYSON at risk of foreseeable harm knowing o
28
67
COMPLAINT
2
3
Defendants directors WILSON MALHQTRA and BHUPINDER CHHUDU covered
313
1
up
M GALVAN JONES JONES and DYSON s homelessness with homeless
concealed plaintiffs
defendants
uncertified
WILSON
OATES
in
violation of
know defendant Interim provided no supervision and little if any contact putting plaintiffs GALVAN
5
6
JONES JONES and DYSON at risk of foreseeable harm kriowing or should know plaintiffs suffered

Defendant SINGH covered up concealed plaintiffs M GALVAN JONES JONES and
314
9
10
DYSON
s and
defendant OATES
WILSON
homelessness in
violation of
S Code Section 1508
owing or should know defendant Interiin provided no supervision and little if any contact putting
11
plaintiffs GALVAN JONES JONES and DYSON at risk of foreseeable harm knowing or should know
12
13
14
15
16
Defendant administratar AZARIAH covered up concealed plaintiffs M GALVAN
315
JONES JONES
and
DYSON
s and
defendant OATES WILSON
homelessness in
violation
of
Code Section 1508 knowing or should know defendant Interim provided no supervision and little if any
17
contact putting plaintiffs GALVAN JONES JONES and DYSON at risk of foreseeable harm knowing o
18
19
20
21
22

316
Facility
as cerEified
in
violation of
S Code Section 1508
knowing or should
know defendant Interim provided no supervision and little if any contact putting plaintiffs SAIS JONES
23
24
25
26
27
28
abuse and neglect
317
uncertified
violation
defendants
of
OATES
WILSON
Facility
6 as certified in
68
COMPLAINT
supervision and little if any contact putting plaintiffs SAIS JONES JONES and DYSON at risk of
3
318
4
Facility
as certified
in
violation of
6
g
abuse and neglect
319
Defendant administrator AZARIAH held out uncertified defendants
10
OATES WILSON
Facility
as certified
in violation
of
S Code
11
Section 1508
knowing or should know defendant Interim provided no supervision and little if any
12
13
contact putting plaintiffs SAIS JONES JONES and DYSON at risk of foreseeable harm knowing or
14 should know plaintiffs suffered ongoing abuse and neglect

15
320
Defendant administrator DOMINGUEZ held out uncertified defendants OATES WILSON
16
Facility
as certified
in
violation of
S Code Section 1508
17
knowing or should know defendant Interim provided no supervision and little if any contact putting
18
19
plaintiffs SAIS JONES JONES and DYSON at risk of foreseeable harm knowing or should know

21
321
22
Facility
as certified
in
violation of
23
24
25
26 abuse and neglect

27
28
322
uncertified

69
COMPLAINT
Facility
7 as certified in
violation of
2 supervision and little if any contact putting plaintiffs SAIS JONES JONES and DYSON at risk of
4
323
5
Facility
in
as certified
violation of
g JONES and DYSON at risk of foreseeable harm knowing or should know plaintiffs suffered ongoing
9
abuse and neglect
10
324
Defendant administrator DOMINGUEZ held out uncertified defendants OATES WILSON
11
Facility
in
as certified
violation of
S Code Section 1508
12
13
owing or should know defendant Interim provided no supervision and little if any contact putting
14 plaintiffs SAIS JONES JONES and DYSON at risk of foreseeable harm knowing or should know

16
325
Defendant administrator RAMNIT held out uncertified defendants OATES WILSON as
17
Facility
as certified
in
violation of
S Code Section 1508
18
19
owing or should know defendant Interim provided no supervision and little if any contact putting
20 plaintiffs SAIS JONES JONES and DYSON at risk of foreseeable harm knowing or should know

22
326 Defendants abandoned failed to supervise and had little or no contact with plaintiffs in a series
23
of unlicensed facilities with unlicensed caregivers defendants OATES WILSON putting plaintiffs at risk of
24
25
26
foreseeable harm knowing or should know plaintiffs suffered ongoing abuse and neglect
327
At all times herein defendants operated a despicable outrageous
kids for cash scam to
27 cheat the government out of lucrative foster care funds for plaintiffs illegal placements knowing or should
28 know plaintiffs were suffering ongoing abuse and neglect that would and did increase alleged herein
o
COMPLAINT
1 with particularity causing plaintiffs to suffer severe mental trauma PTSD humiliation intimidation
2 threats embarrassment and shame deprivation of liberty and freedom and substantial hurt and injury to
3
plaintiffs health strength activity and substantial enduring shock and injury to plaintiffs nervous system
mental anguish depression anxiety inability to sleep loss of focus and concentration confusion anger
5
6
indignity nervousness hopelessness shame fear panic and desperation all of which injuries caused and
continue to cause plaintiffs severe mental pain and suffering for which defendants are liable
328
g
9
10
11
25 000 00
Dollars
12
WHEREFORE PLAINTIFRS PRAY for judgmerit against defendants and each of them as
13
14 follows
15 the California Code of Civil Procedure which sum is in excess of Twenty Five Thousand Dollars
16
25 000 00
2 For
medical and
incident expenses incurred
and
to
be incurred in
the
future
For loss
17
of earnings incurred and future loss of earning capacity according to proof 4 For pre judgment interest
18
19
according
to proof
For
costs of suit
incurred herein
and
20 Court deems just and proper

21
22
FOURTH CAUSE OF ACTION
FOR CONSPIRACY
23
PLAINTIFFS DEANDRE JONES
LZEANDRANE JONES ISAIAH SAIS SALEENA
24
GALVAN MARK GALVAN
SUItPRISE ADAMS SHAWNA ADAMS
SUAVE
25
26
DYSON AGAINST DEFENDAN TS INTERIM SUKHWINDER SgNGH FREDDIE
27
WILSON AJAY MALHOTRA BHUPINDER CH IUDU
28
KHUSHANUD AZARIAH JOEL DOMINGUEZ SHAHZIA RAMNIT LISA OATES NAWAB
COMPLAINT
WILSON and DOES 1 20
1
2
329
330
Plaintiffs reallege pars 1 328 as though fully set forth

4
defendants Administrators and defendants OATES WILSON held uncertified OATES WILSON and
5
seven uncertified facilities out as certified by INTERIM in violation of Health and Safetv Code Section
6
1508 to bilk hundreds of thousands of foster care dollars from the U S Dept of Health and Human
Services Title N E
Federal Foster Care Funds California Dept of Social Services DSS
State Foster
9 Funds and San Bernadino County Child Proteetive Services Foster Care Funds knowing or should know
10
plaintiffs suffered unconscionable ongoing unrestrained unmitigated terror torture corporal punishment
11
physical and mental
abuse and neglect perpetrated
by
unchecked
12
331
13
At all times herein
defendant INTERIM defendants board members defendant CEO
14 defendants Administrators and OATES WILSON placed accepted plaintiffs foster children in seven
15
facilities
16
uncertified
332
by
INTERIM
over a period of six years
in
violation of
S Code Section 1508
Defendant INTERIM defendants board members defendant CEO defendants
17
Administrators
in cahoots with defendants OATES WILSON perpetrated the
kids for cash scam
18
owing or should know plaintiffs suffered unconscionable ongoing unrestrained terror torture
19
20 corporal punishment physical and mental abuse and neglect at the hands of defendants OATES WILSON
21
unchecked
22
333
23
and defendants Administrators knew plaintiffs foster children were evicted from four 4 of the seven
24
25
uncerti ed facilities with uncertified dangerous defendants OATES WILSON while holding said evicted
26 defendants out as certified by INTERIM in cahoots with defendants OATES WILSON in violation of
27 H
S Code Section 1508 placed more dependent children collected lucrative federal state and county
28 foster care funds perpetrating the kids for cash scam knowing or should know evicted plaintiffs foster
72
COMPLAINT
1 children suffered unconscionable ongoing unrestrained terror torture corporal punishment physical and
2
mental abuse and neglect at
334
the
hands
of
unchecked
4
and defendants Administrators knew defendants OATES WILSON and plaintiffs foster children were
5
homeless for
six months
homeless foster
took no action held said homeless uncertified
children
defendants out as certified by INTERIM in cahoots with defendants OATES WILSON in violation of
g
S Code Section 1508 placed more dependent children collected lucrative federal state and county
9 foster care funds perpetrating the kids for cash scam knowing or should know homeless plaintiffs
10
suffered unconscionable ongoing unrestrained terror torture corporal punishment physical and mental
11
abuse and neglect at the hands of defendants OATES WILSON unchecked
12
335
13
As a result of defendants kids for cash
scam plaintiffs suffered terror trauma PTSD
14 humiliation intimidation threats embarrassment and shame substantial hurt and injury to plaintiffs
15 health strength activity and substantial enduring shock and injury to plaintiffs nervous system mental
16
anguish depression anxiety inability to sleep loss of focus and concentration confusion anger indignity
17
nervousness
hopelessness
shame
fear panic and desperation all ofwhich injuries caused and continue to
18
19
cause plaintiffs severe mental pain and suffering for which defendants are liable
336
20
21 permanent disability and general damages in an amount which will be stated according to proof pursuant to
22
23
Dollars
25 000 00
24
25
26 follows
WHEREFORE
PLAINTIFFS PRAY for judgment against defendants and each of them as
27 the California Code of Civil Procedure which sum is in excess of Twenty Five Thousand Dollars
28
73
COMPLAINT
25 000 00
2 For
medical and
incident
expenses
incurred
and
to be incurred in the future
3 For loss
2 of earnings incurred and future loss of earning capacity according to proof 4 For pre judgment interest
3
according to
proof
For
costs of suit
incurred herein
and
4
5
6
DATED October 2
L014
8
9
By
10
L Wallace Pate Esq Attorneys for Plaintiffs

il
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
74
COMPLAINT
DEMAND FOR Ji1RY TRIAL
1
2
3
Plaintiffs hereby demand trial by jury of all causes of action
4
5
DATED October 2
014
6
7
8
9
By
10
L Wallace Pate Esq Attorneys for Plaintiffs

11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
75
COMPLAINT
SUPERIOR COURT OF CAU
N BERNARDINO
CI11G 141
CASE NO
Vs
17
CERTIFICATE OF ASSIGNMENT
c
L1
Aresidence
civil actionof aorparty
proceeding
presented for filing must be accompanied by this Certificate If the ground is the
name and residence shall be stated
The
un
rsigned declares that the above entitled matter is filed for proceedings in the
District of the Superior Court under Rule 404 of this court for the
checked reason
General
Collection
Nature of Action
Adoption
2 Conservator
3 Contract
1
Equity
Eminent Domain
Family
Guardianship
Harassment
Mandate
Name Change
Personal Injury
Personal Property
Probate
9
0
11
12
13
Law
Ground
Petitioner resides within the district
Petitioner or conservatee resides within the district
Performance in the district is expressly provided for
The cause of action arose within the district

The property is located within the district
Plaintiff defendant petitioner or respondent resides within the district
Petitioner or ward resides within the district or has property within the district
Plaintiff defendant petitioner or respondent resides within the district
The defendant functions wholly within the district

The petitioner resides within the district
The injury occurred within the district
Decedent resided or resides within the district or had property within the
district
14
Prohibition
15
Review
O16
Title to Real
17
Property
Transferred Action
Unlawful Detainer
18
19
20
Domestic Violence
Other
21
THIS FILING WOUL D

The lower court is located within the district
The petitioner defendant plaintiff or respondent resides within the district

NORMALLY FALL WITHIN JURISDICTION OF SUPERIOR COURT
The address of theinaccident

perFormance
party detention place of business or other factor which qualifies
the
designed district js
this case fer filin

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NAME
IN
above
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J
TE TITLE QR OTHER QUA JFY NG FACTOR
RESS
CITY
STATE
I declare
on
under
penalty of perjury that the forego
at
is tr
ZIP CODE
nd correct and that this declaration was executed
Signature ofAttomey Party
13
16503 360
Rev 06 2014
CERTIFICATE OF ASSIGNMENT
California

Jones Et Al V Interim Care Foster Family Agency Oct 27 2014 PDF

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Jones Et Al V Interim Care Foster Family Agency Oct 27 2014 PDF

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CIV 141027 CIV DS 1416170 CASEEN 130002

Scanned Document Coversheet

PURPOSES ONLY AIVD THIS IS NOT

A PART OF THE OFFICIAL RECORD

THIS COVERSHEET IS FOR COURT

Complaint and Party information entered

LAW OFFICES OF L WALLACE PATE

2 9903 Santa Monica Boulevard Suite 3100

310 203 2210

RNAF DINO ISTf ICT

Attorneys for Plaintiffs

LEANDRA HENDRIX DEPUTY

SUPERIOR COURT FOR THE STATE OF CALIFORNIA

DEANDRE JONES REANDRENE JONES

ISAIAH SAIS SALEENA GALVAN

SHAWNA ADAMS individuals

DYSON minor by and through his Guardian

COMPLAINT FOR DAMACES

AGENCY a California Corporation

SHAHZIA RAMNIT LISA OATES

22 NAWAB WILSON Individuals and DOES

Plaintiffs DEANDRE JONES REANDRENE JONES ISAIAH SAIS SALEEN

At all times herein

14 Trademark Street A Rancho Cucamonga California 91730

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

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

Federal Foster Care Funds

26 OATES WILSON and defendants seven facilities

Plaintiffs DEANDRE JONES REANDRENE JONES ISAIAH SAIS SALEEN

and defendants uncertified LISA OATES and NAWAB WILSON

14 Trademark Street A Rancho Cucamonga California 91730

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

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

Human Services Title IV E

Federal Foster Care Funds

26 OATES WILSON and defendants seven facilities

took no action held out said homeless defendants as

S Code Section 1508 placed more dependent children

Defendant SUKHWINDER SINGH defendant Interim s Chief Financial Officer and

S Cocle Section 1508

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

S Code Section 1508

S Code Section 1508

At all times herein defendant BHUPINDER CHHUDU defendant Interim s director

S Code Section 1508

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

14 employed as defendant Interim s Administrator 10251 Trademark Street A Rancho Cucamonga

S Code Section 1508

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

facilities were certified

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

1 employed as defendant Interim s Administrator 10251 Trademark Street A Rancho Cucamonga

S Code Section 1508

FIRST CAUSE OF ACTION FOR NEGLIGENCE

pLAINTIFFS DEANDRE JONES REANDRANE JONES ISAIAH SAIS SALEENA

GALVAN MARK GALVAN SU1tPRISE ADAMS SHAWNA A AMS SUAVE

DYSON AGAINST DEFENDANTS INTERIM SUKHWINDER SINGH FREDDIE

WILSON AJAY MALHOTRA BHUPINDER CHHUDU

KHUSHANUD AZARIAH JOEL DOMINGUEZ SHAHZIA RAMNIT LISA OATES

NAWAB WILSON and DOES 1 20

Plaintiffs reallege pars 1 17 as though fully set forth herein

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

a foster farnily agency and named defendants as its board members