Valentini 268586 v. Thornell ( 2023 )

1 WO ASH 2 3 4 5 6 IN THE UNITED STATES DISTRICT COURT 7 FOR THE DISTRICT OF ARIZONA 8 9 Rick Wayne Valentini, No. CV-23-00323-TUC-SHR 10 Plaintiff, 11 v. ORDER 12 Ryan Thornell, et al., 13 Defendants. 14 15 Plaintiff Rick Wayne Valentini, a frequent litigant1 who is confined in the Arizona 16 State Prison Complex-Yuma, has filed a pro se civil rights Complaint pursuant to 42 U.S.C. 17 § 1983 (Doc. 1), an Application to Proceed In Forma Pauperis (Doc. 2), two Motions for 18 Preliminary Injunction (Docs. 5, 6), and a Motion of Acquisition (Doc. 10). After review, 19 the Court denies the Motions for Preliminary Injunction, grants Plaintiff’s Application to 20 Proceed and Motion for Acquisition, and dismisses the Complaint with leave to amend for 21 the reasons set forth below. 22 I. Application to Proceed In Forma Pauperis and Filing Fee 23 The Court grants Plaintiff’s Application to Proceed In Forma Pauperis. 28 U.S.C. 24 § 1915(a). Plaintiff must pay the statutory filing fee of $350.00. 28 U.S.C. § 1915(b)(1). 25 The Court will assess an initial partial filing fee of $63.37. The remainder of the fee will 26 be collected monthly in payments of 20% of the previous month’s income credited to 27 Plaintiff’s trust account each time the amount in the account exceeds $10.00. 28 U.S.C. 28 1 Plaintiff has filed at least nine actions in this Court. 1 § 1915(b)(2). The Court will enter a separate Order requiring the appropriate government 2 agency to collect and forward the fees according to the statutory formula. 3 II. Statutory Screening of Prisoner Complaints 4 The Court is required to screen complaints brought by prisoners seeking relief 5 against a governmental entity or an officer or an employee of a governmental entity. 28 6 U.S.C. § 1915A(a). The Court must dismiss a complaint or portion thereof if a plaintiff 7 has raised legally frivolous or malicious claims, failed to state a claim upon which relief 8 may be granted, or sought monetary relief from a defendant who is immune from such 9 relief. 28 U.S.C. § 1915A(b)(1)–(2). 10 A pleading must contain a “short and plain statement of the claim showing that the 11 pleader is entitled to relief.” Fed. R. Civ. P. 8(a)(2) (emphasis added). While Rule 8 does 12 not demand detailed factual allegations, “it demands more than an unadorned, the- 13 defendant-unlawfully-harmed-me accusation.” Ashcroft v. Iqbal, 556 U.S. 662, 678 14 (2009). “Threadbare recitals of the elements of a cause of action, supported by mere 15 conclusory statements, do not suffice.” Id. 16 Rule 8(a) of the Federal Rules of Civil Procedure requires a “short and plain 17 statement of the claim.” Fed. R. Civ. P. 8(a)(2). Rule 8(d)(1) states “[e]ach allegation 18 must be simple, concise, and direct.” A complaint having the factual elements of a cause 19 of action scattered throughout the complaint and not organized into a “short and plain 20 statement of the claim” may be dismissed for failure to satisfy Rule 8(a). See Sparling v. 21 Hoffman Constr. Co., 864 F.2d 635, 640 (9th Cir. 1988); see also McHenry v. Renne, 84 22 F.3d 1172 (9th Cir. 1996). Plaintiff has been repeatedly informed of these standards.2 23 Plaintiff’s Complaint fails to comply with federal pleading requirements. Local 24 Rule of Civil Procedure 3.4 requires, in part, all complaints by incarcerated persons “be 25 signed and legibly written or typewritten on forms approved by the court and in accordance 26 with the instructions provided with the forms.” The instructions provided with the court- 27 2 See Valentini v. Shinn, CV 2:22-01612-PHX-MTL (DMF) (D. Ariz. Order dated 28 Apr. 24, 2023); Valentini v. Shinn, CV 2:23-00325-PHX-MTL (DMF) (D. Ariz. Orders dated Apr. 7, 2023, and Sept. 26, 2023). 1 approved civil rights complaint form state a plaintiff may only allege “one violation per 2 count.” (Emphasis in original.) Each of Plaintiff’s eight claims cites numerous legal bases 3 for the claims, including “RLUIPA of 2000,”3 the “1st, 5th, 8th, and 14th Amendments,” 4 the “American Cares Act,”4 and “Rouser v. White.”5 All of Plaintiff’s claims make 5 allegations against multiple Defendants and relate to events occurring over many weeks or 6 months. As such, Plaintiff’s allegations make it impossible for the Court to determine 7 what, exactly, Plaintiff’s claims are, and against whom they are directed. It is not the 8 responsibility of the Court to review a rambling narrative in an attempt to determine the 9 number and nature of Plaintiff’s claims. Plaintiff’s allegations are neither short nor plain, 10 and it would be impossible for any Defendant to meaningfully respond to the Complaint. 11 Accordingly, the Court finds the Complaint fails to comply with Rule 8 of the Federal 12 Rules of Civil Procedure and Rule 3.4 of the Local Rules of Civil Procedure, and it will 13 thus be dismissed. 14 III. Leave to Amend 15 By Monday, January 8, 2024, Plaintiff may submit a first amended complaint to 16 cure the deficiencies outlined above. The Clerk of Court will mail Plaintiff a court- 17 approved form to use for filing a first amended complaint. If Plaintiff fails to use the court- 18 19 3 Plaintiff presumably refers to the Religious Land Use and Institutionalized Persons Act (RLUIPA). 20 4 Plaintiff presumably refers to the Coronavirus Aid, Relief, and Economic Security 21 (CARES) Act. In another case, the Court has informed Plaintiff there is no private right of action pursuant to the CARES Act. See Valentini v. Shinn, CV 2:22-01612-PHX-MTL 22 (DMF) (D. Ariz. Order dated Oct. 17, 2023). 23 5 As the Court has previously noted, it is unclear what case Plaintiff is referring to. See Valentini v. Shinn, CV 2:22-01612-PHX-MTL (DMF) (D. Ariz. Order dated Oct. 17, 24 2023). To the extent Plaintiff may be referring to Rouser v. White, 825 F.3d 1076 (9th Cir. 2016), or the underlying consent decrees from the United States District Court for the 25 Eastern District of California, Plaintiff may not enforce the settlement or consent decrees entered in a separate action. See Cagle v. Sutherland, 334 F.3d 980, 986 (11th Cir. 2003); 26 Klein v. Zavaras, 80 F.3d 432, 435 (10th Cir. 1996); DeGidio v. Pung, 920 F.2d 525, 534 (8th Cir. 1990); Green v. McKaskle, 788 F.2d 1116, 1122–23 (5th Cir. 1986). Moreover, 27 standing alone, remedial orders and settlement terms cannot serve as a substantive basis for a § 1983 claim because they do not create “rights, privileges, or immunities secured by 28 the Constitution and laws.” Green, 788 F.3d at 1123–24. Rather, settlements and remedial decrees are the means by which unconstitutional conditions are corrected. Id. at 1123. 1 approved form, the Court may strike the first amended complaint and dismiss this action 2 without further notice to Plaintiff. 3 Plaintiff must clearly designate on the face of the document it is the “First Amended 4 Complaint.” The first amended complaint must be retyped or rewritten in its entirety on 5 the court-approved form and may not incorporate any part of the original Complaint by 6 reference. Plaintiff may include only one claim per count. 7 A first amended complaint supersedes the original Complaint. Ferdik v. Bonzelet, 8 963 F.2d 1258, 1262 (9th Cir. 1992); Hal Roach Studios v. Richard Feiner & Co., 896 F.2d 9 1542, 1546 (9th Cir. 1990). After amendment, the Court will treat the original Complaint 10 as nonexistent. Ferdik, 963 F.2d at 1262. Any cause of action raised in a previous 11 complaint and voluntarily dismissed or dismissed without prejudice is waived if it is not 12 alleged in an amended complaint. Lacey v. Maricopa County, 693 F.3d 896, 928 (9th Cir. 13 2012) (en banc). 14 If Plaintiff files a first amended complaint, Plaintiff must write short, plain 15 statements telling the Court: (1) the constitutional right Plaintiff believes was violated; 16 (2) the name of the Defendant who violated the right; (3) exactly what each Defendant did 17 or failed to do; (4) how the action or inaction of each Defendant is connected to the 18 violation of Plaintiff’s constitutional right; and (5) what specific injury Plaintiff suffered 19 because of each Defendant’s conduct. See Rizzo v. Goode, 423 U.S. 362, 371–72, 377 20 (1976). 21 Plaintiff must repeat this process for each person he names as a Defendant. If 22 Plaintiff fails to affirmatively link the conduct of each named Defendant with the specific 23 injury suffered by Plaintiff, the allegations against that Defendant will be dismissed for 24 failure to state a claim. Conclusory allegations a Defendant or group of Defendants 25 has violated a constitutional right are not acceptable and will be dismissed. 26 IV. Motions for Preliminary Injunction 27 Plaintiff has filed two Motions seeking preliminary injunctive relief. In the first 28 (Doc. 5), Plaintiff asserts certain religious books and items have been confiscated as 1 “contraband,” and they were scheduled to be destroyed on July 6, 2023. Plaintiff seeks an 2 injunction halting the items’ destruction. However, Plaintiff’s Motion was not received 3 until August 4, 2023, well after the items had already been destroyed. Accordingly, no 4 effective injunctive relief can be granted, and the first Motion will thus be denied as moot. 5 In the second Motion (Doc. 6), Plaintiff seeks an order directing he be placed in 6 protective custody due to alleged threats to his safety. However, Plaintiff makes no threat 7 to safety allegations in his Complaint. An injunction is appropriate to grant “intermediate 8 relief of the same character as that which may be granted finally,” but relief is not proper 9 when it is requested on matters “lying wholly outside the issues in the suit.” DeBeers 10 Consol. Mines, Ltd. v. United States, 325 U.S. 212, 220 (1945). “When a plaintiff seeks 11 injunctive relief based on claims not pled in the complaint, the court does not have the 12 authority to issue an injunction.” Pacific Radiation Oncology, LLC v. Queen’s Med. Ctr., 13 810 F.3d 631, 633 (9th Cir. 2015); see also Devose v. Herrington, 42 F.3d 470, 471 (8th 14 Cir. 1994) (per curiam) (to obtain injunctive relief, the party “must necessarily establish a 15 relationship between the injury claimed in the party’s motion and the conduct asserted in 16 the complaint”). Because Plaintiff’s request for injunctive relief is unrelated to the claims 17 in his Complaint, his second Motion will be denied. 18 V. Warnings 19 A. Release 20 If Plaintiff is released while this case remains pending, and the filing fee has not 21 been paid in full, Plaintiff must, within 30 days of his release, either (1) notify the Court 22 he intends to pay the unpaid balance of his filing fee within 120 days of his release or (2) 23 file a non-prisoner application to proceed in forma pauperis. Failure to comply may result 24 in dismissal of this action. 25 B. Address Changes 26 If Plaintiff’s address changes, Plaintiff must file and serve a notice of a change of 27 address in accordance with Rule 83.3(d) of the Local Rules of Civil Procedure. Plaintiff 28 must not include a motion for other relief with a notice of change of address. Failure to 1 | comply may result in dismissal of this action. 2 C. Possible Dismissal 3 If Plaintiff fails to timely comply with every provision of this Order, including these 4) warnings, the Court may dismiss this action without further notice. See Ferdik, 963 F.2d 5 | at 1260-61 (a district court may dismiss an action for failure to comply with any order of the Court). 7| ITIS ORDERED: 8 (1) Plaintiff's Application to Proceed In Forma Pauperis (Doc. 2) is GRANTED. 9 (2) As required by the accompanying Order to the appropriate government 10 | agency, Plaintiff must pay the $350.00 filing fee and is assessed an initial partial filing fee of $63.37. 12 (3) | The Complaint (Doc. 1) is DISMISSED for failure to comply with Rule 8 of 13 | the Federal Rules of Civil Procedure and Rule 3.4 of the Local Rules of Civil Procedure. Plaintiff has up to and including Monday, January 8, 2024, to file a first amended 15 | complaint in compliance with this Order. 16 (4) ‘If Plaintiff fails to file an amended complaint by the end of the day Monday, January 8, 2024, the Clerk of Court must, without further notice, enter a judgment of 18 | dismissal of this action without prejudice and deny any pending unrelated motions as moot. 19 (5) Plaintiff's two Motions for Preliminary Injunction (Docs. 5 and 6) are 20 | DENIED. 21 (6) Plaintiff's Motion for Acquisition (Doc. 10) is GRANTED. 22 (7) The Clerk of Court must mail Plaintiff a court-approved form for filing a 23 | civil rights complaint by a prisoner and must mail Plaintiff a copy of his complaint (Doc. 24} 1). 25 Dated this 8th day of December, 2023. ted 27 cited States District Fudge 28 Instructions for a Prisoner Filing a Civil Rights Complaint in the United States District Court for the District of Arizona 1. Who May Use This Form. The civil rights complaint form is designed to help incarcerated persons prepare a complaint seeking relief for a violation of their federal civil rights. These complaints typically concern, but are not limited to, conditions of confinement. This form should not be used to challenge your conviction or sentence. If you want to challenge a state conviction or sentence, you should file a petition under 28 U.S.C. ' 2254 for a writ of habeas corpus by a person in state custody. If you want to challenge a federal conviction or sentence, you should file a motion under 28 U.S.C. § 2255 to vacate sentence in the federal court that entered the judgment. 2. The Form. Local Rule of Civil Procedure (LRCiv) 3.4(a) provides that complaints by incarcerated persons must be filed on the court-approved form. The form must be typed or neatly handwritten. The form must be completely filled in to the extent applicable. All questions must be answered clearly and concisely in the appropriate space on the form. If needed, you may attach additional pages, but no more than fifteen additional pages, of standard letter-sized paper. You must identify which part of the complaint is being continued and number all pages. If you do not fill out the form properly, you will be asked to submit additional or corrected information, which may delay the processing of your action. You do not need to cite law. 3. Your Signature. You must tell the truth and sign the form. If you make a false statement of a material fact, you may be prosecuted for perjury. 4. The Filing and Administrative Fees. The total fees for this action are $400.00 ($350.00 filing fee plus $50.00 administrative fee). If you are unable to immediately pay the fees, you may request leave to proceed in forma pauperis. Please review the “Information for Prisoners Seeking Leave to Proceed with a (Non-Habeas) Civil Action in Federal Court In Forma Pauperis Pursuant to 28 U.S.C. ' 1915” for additional instructions. 5. Original and Judge=s Copy. You must send an original plus one copy of your complaint and of any other documents submitted to the Court. You must send one additional copy to the Court if you wish to have a file-stamped copy of the document returned to you. All copies must be identical to the original. Copies may be legibly handwritten. This section does not apply to inmates housed at an Arizona Department of Corrections facility that participates in electronic filing. 6. Where to File. You should file your complaint in the division where you were confined when your rights were allegedly violated. See LRCiv 5.1(a) and 77.1(a). If you were confined in Maricopa, Pinal, Yuma, La Paz, or Gila County, file in the Phoenix Division. If you were confined in Apache, Navajo, Coconino, Mohave, or Yavapai County, file in the Prescott Division. If you were confined in Pima, Cochise, Santa Cruz, Graham, or Greenlee County, file in the Tucson Division. Mail the original and one copy of the complaint with the $400 filing and administrative fees or the application to proceed in forma pauperis to: Revised 3/11/16 1 Phoenix & Prescott Divisions: OR Tucson Division: U.S. District Court Clerk U.S. District Court Clerk U.S. Courthouse, Suite 130 U.S. Courthouse, Suite 1500 401 West Washington Street, SPC 10 405 West Congress Street Phoenix, Arizona 85003-2119 Tucson, Arizona 85701-5010 7. Change of Address. You must immediately notify the Court and the defendants in writing of any change in your mailing address. Failure to notify the Court of any change in your mailing address may result in the dismissal of your case. 8. Certificate of Service. You must furnish the defendants with a copy of any document you submit to the Court (except the initial complaint and application to proceed in forma pauperis). Each original document (except the initial complaint and application to proceed in forma pauperis) must include a certificate of service on the last page of the document stating the date a copy of the document was mailed to the defendants and the address to which it was mailed. See Fed. R. Civ. P. 5(a), (d). Any document received by the Court that does not include a certificate of service may be stricken. This section does not apply to inmates housed at an Arizona Department of Corrections facility that participates in electronic filing. A certificate of service should be in the following form: I hereby certify that a copy of the foregoing document was mailed this (month, day, year) to: Name: Address: Attorney for Defendant(s) (Signature) 9. Amended Complaint. If you need to change any of the information in the initial complaint, you must file an amended complaint. The amended complaint must be written on the court-approved civil rights complaint form. You may file one amended complaint without leave (permission) of Court within 21 days after serving it or within 21 days after any defendant has filed an answer, whichever is earlier. See Fed. R. Civ. P. 15(a). Thereafter, you must file a motion for leave to amend and lodge (submit) a proposed amended complaint. LRCiv 15.1. In addition, an amended complaint may not incorporate by reference any part of your prior complaint. LRCiv 15.1(a)(2). Any allegations or defendants not included in the amended complaint are considered dismissed. All amended complaints are subject to screening under the Prison Litigation Reform Act; screening your amendment will take additional processing time. 10. Exhibits. You should not submit exhibits with the complaint or amended complaint. Instead, the relevant information should be paraphrased. You should keep the exhibits to use to support or oppose a motion to dismiss, a motion for summary judgment, or at trial. 11. Letters and Motions. It is generally inappropriate to write a letter to any judge or the staff of any judge. The only appropriate way to communicate with the Court is by filing a written pleading or motion. 12. Completing the Civil Rights Complaint Form. HEADING: 1. Your Name. Print your name, prison or inmate number, and institutional mailing address on the lines provided. 2. Defendants. If there are four or fewer defendants, print the name of each. If you name more than four defendants, print the name of the first defendant on the first line, write the words “and others” on the second line, and attach an additional page listing the names of all of the defendants. Insert the additional page after page 1 and number it “1-A” at the bottom. 3. Jury Demand. If you want a jury trial, you must write “JURY TRIAL DEMANDED” in the space below “CIVIL RIGHTS COMPLAINT BY A PRISONER.” Failure to do so may result in the loss of the right to a jury trial. A jury trial is not available if you are seeking only injunctive relief. Part A. JURISDICTION: 1. Nature of Suit. Mark whether you are filing the complaint pursuant to 42 U.S.C. ' 1983 for state, county, or city defendants; “Bivens v. Six Unknown Federal Narcotics Agents” for federal defendants; or “other.” If you mark “other,” identify the source of that authority. 2. Location. Identify the institution and city where the alleged violation of your rights occurred. 3. Defendants. Print all of the requested information about each of the defendants in the spaces provided. If you are naming more than four defendants, you must provide the necessary information about each additional defendant on separate pages labeled “2-A,” “2-B,” etc., at the bottom. Insert the additional page(s) immediately behind page 2. Part B. PREVIOUS LAWSUITS: You must identify any other lawsuit you have filed in either state or federal court while you were a prisoner. Print all of the requested information about each lawsuit in the spaces provided. If you have filed more than three lawsuits, you must provide the necessary information about each additional lawsuit on a separate page. Label the page(s) as “2-A,” “2-B,” etc., at the bottom of the page and insert the additional page(s) immediately behind page 2. Part C. CAUSE OF ACTION: You must identify what rights each defendant violated. The form provides space to allege three separate counts (one violation per count). If you are alleging more than three counts, you must provide the necessary information about each additional count on a separate page. Number the additional pages “5-A,” “5-B,” etc., and insert them immediately behind page 5. Remember that you are limited to a total of fifteen additional pages. 1. Counts. You must identify which civil right was violated. You may allege the violation of only one civil right per count. 2. Issue Involved. Check the box that most closely identifies the issue involved in your claim. You may check only one box per count. If you check the box marked “Other,” you must identify the specific issue involved. 3. Supporting Facts. After you have identified which civil right was violated, you must state the supporting facts. Be as specific as possible. You must state what each individual defendant did to violate your rights. If there is more than one defendant, you must identify which defendant did what act. You also should state the date(s) on which the act(s) occurred, if possible. 4. Injury. State precisely how you were injured by the alleged violation of your rights. 5. Administrative Remedies. You must exhaust any available administrative remedies before you file a civil rights complaint. See 42 U.S.C. § 1997e. Consequently, you should disclose whether you have exhausted the inmate grievance procedures or administrative appeals for each count in your complaint. If the grievance procedures were not available for any of your counts, fully explain why on the lines provided. Part D. REQUEST FOR RELIEF: Print the relief you are seeking in the space provided. SIGNATURE: You must sign your name and print the date you signed the complaint. Failure to sign the complaint will delay the processing of your action. Unless you are an attorney, you may not bring an action on behalf of anyone but yourself. FINAL NOTE You should follow these instructions carefully. Failure to do so may result in your complaint being stricken or dismissed. All questions must be answered concisely in the proper space on the form. If you need more space, you may attach no more than fifteen additional pages. But the form must be completely filled in to the extent applicable. If you attach additional pages, be sure to identify which section of the complaint is being continued and number the pages. 4 ___________________________________________ Name and Prisoner/Booking Number ___________________________________________ Place of Confinement ___________________________________________ Mailing Address ___________________________________________ City, State, Zip Code (Failure to notify the Court of your change of address may result in dismissal of this action.) IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF ARIZONA _________________________________________ , (Full Name of Plaintiff) ) Plaintiff, v. CASE NO. __________________________________ (To be supplied by the Clerk) (1) _______________________________________ , (Full Name of Defendant) CIVIL RIGHTS COMPLAINT (2) _______________________________________ , BY A PRISONER (3) _______________________________________ , G Original Complaint (4) _______________________________________ , G First Amended Complaint G Second Amended Complaint Defendant(s). G Check if there are additional Defendants and attach page 1-A listing them. A. JURISDICTION 1. This Court has jurisdiction over this action pursuant to: G 28 U.S.C. § 1343(a); 42 U.S.C. § 1983 G 28 U.S.C. § 1331; Bivens v. Six Unknown Federal Narcotics Agents, 403 U.S. 388 (1971). G Other: . 2. Institution/city where violation occurred: . 550/555 B. DEFENDANTS 1. Name of first Defendant: . The first Defendant is employed as: ______________________________________________ at_______________________________________. (Position and Title) (Institution) 2. Name of second Defendant: . The second Defendant is employed as: as: ______________________________________________ at_______________________________________. (Position and Title) (Institution) 3. Name of third Defendant: . The third Defendant is employed as: ______________________________________________ at_______________________________________. (Position and Title) (Institution) 4. Name of fourth Defendant: . The fourth Defendant is employed as: ______________________________________________ at_______________________________________. (Position and Title) (Institution) If you name more than four Defendants, answer the questions listed above for each additional Defendant on a separate page. C. PREVIOUS LAWSUITS 1. Have you filed any other lawsuits while you were a prisoner? G Yes G No 2. If yes, how many lawsuits have you filed? . Describe the previous lawsuits: a. First prior lawsuit: 1. Parties: v. 2. Court and case number: . 3. Result: (Was the case dismissed? Was it appealed? Is it still pending?) . b. Second prior lawsuit: 1. Parties: v. 2. Court and case number: . 3. Result: (Was the case dismissed? Was it appealed? Is it still pending?) . c. Third prior lawsuit: 1. Parties: v. 2. Court and case number: . 3. Result: (Was the case dismissed? Was it appealed? Is it still pending?) . If you filed more than three lawsuits, answer the questions listed above for each additional lawsuit on a separate page. 2 D. CAUSE OF ACTION COUNT I 1. State the constitutional or other federal civil right that was violated: . 2. Count I. Identify the issue involved. Check only one. State additional issues in separate counts. G Basic necessities G Mail G Access to the court G Medical care G Disciplinary proceedings G Property G Exercise of religion G Retaliation G Excessive force by an officer G Threat to safety G Other: . 3. Supporting Facts. State as briefly as possible the FACTS supporting Count I. Describe exactly what each Defendant did or did not do that violated your rights. State the facts clearly in your own words without citing legal authority or arguments. . 4. Injury. State how you were injured by the actions or inactions of the Defendant(s). . 5. Administrative Remedies: a. Are there any administrative remedies (grievance procedures or administrative appeals) available at your institution? G Yes G No b. Did you submit a request for administrative relief on Count I? G Yes G No c. Did you appeal your request for relief on Count I to the highest level? G Yes G No d. If you did not submit or appeal a request for administrative relief at any level, briefly explain why you did not. . COUNT II 1. State the constitutional or other federal civil right that was violated: . 2. Count II. Identify the issue involved. Check only one. State additional issues in separate counts. G Basic necessities G Mail G Access to the court G Medical care G Disciplinary proceedings G Property G Exercise of religion G Retaliation G Excessive force by an officer G Threat to safety G Other: . 3. Supporting Facts. State as briefly as possible the FACTS supporting Count II. Describe exactly what each Defendant did or did not do that violated your rights. State the facts clearly in your own words without citing legal authority or arguments. . 4. Injury. State how you were injured by the actions or inactions of the Defendant(s). . 5. Administrative Remedies. a. Are there any administrative remedies (grievance procedures or administrative appeals) available at your institution? G Yes G No b. Did you submit a request for administrative relief on Count II? G Yes G No c. Did you appeal your request for relief on Count II to the highest level? G Yes G No d. If you did not submit or appeal a request for administrative relief at any level, briefly explain why you did not. . COUNT III 1. State the constitutional or other federal civil right that was violated: . 2. Count III. Identify the issue involved. Check only one. State additional issues in separate counts. G Basic necessities G Mail G Access to the court G Medical care G Disciplinary proceedings G Property G Exercise of religion G Retaliation G Excessive force by an officer G Threat to safety G Other: . 3. Supporting Facts. State as briefly as possible the FACTS supporting Count III. Describe exactly what each Defendant did or did not do that violated your rights. State the facts clearly in your own words without citing legal authority or arguments. . 4. Injury. State how you were injured by the actions or inactions of the Defendant(s). . 5. Administrative Remedies. a. Are there any administrative remedies (grievance procedures or administrative appeals) available at your institution? G Yes G No b. Did you submit a request for administrative relief on Count III? G Yes G No c. Did you appeal your request for relief on Count III to the highest level? G Yes G No d. If you did not submit or appeal a request for administrative relief at any level, briefly explain why you did not. . If you assert more than three Counts, answer the questions listed above for each additional Count on a separate page. E. REQUEST FOR RELIEF State the relief you are seeking: . I declare under penalty of perjury that the foregoing is true and correct. Executed on DATE SIGNATURE OF PLAINTIFF ___________________________________________ (Name and title of paralegal, legal assistant, or other person who helped prepare this complaint) ___________________________________________ (Signature of attorney, if any) ___________________________________________ (Attorney=s address & telephone number) ADDITIONAL PAGES All questions must be answered concisely in the proper space on the form. If you need more space, you may attach no more than fifteen additional pages. But the form must be completely filled in to the extent applicable. If you attach additional pages, be sure to identify which section of the complaint is being continued and number all pages. FILED LODGED RECEIVED ___ COPY JUL 1 7 2023 URT CLERK DISTRIGS SOK ict OF ARIZON Kick Vareninal 29586 BY DEPUTY Name and PrisoneyBooking Number oe Tucom Rinum 3-A-] Place of Confinement Mailing Address Tutcom, Az $5734- WYoR Cliy, State, Zip Code - (Failure to notify the Court of your change of address may result in dismissal of this action. IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF ARIZONA - ? Rick JA LENTIAI| ) Full Name of Plaintiff) Plaintiff, ) ma CASENO, _CV-23-00323-SHR-PSOT □ ) (To be supplied by the Clerk) Ryan Thor net) . 7 . (Full Name of Defendant) ) : □ Chosippwr TJosePouncz _. ) _ ) CIVIL RIGHTS COMPLAINT John Mechnez. ) BY A PRISONER ) / (4. Reonclalt Andrews ,) Original Complaint Defendant(s). ) © First Amended Complaint Chock ther re etna etendans and wh page I-A lating them ) Second Amended Complaint A, JURISDICTION 1. This Court has jurisdiction over this action pursuant to: HM 28 U.S.C. § 1343(a); 42 U.S.C. § 1983 C1] 28 U.S.C. § 1331; Bivens v. Six Unknown Federal Narcotics Agents, 403 U.S, 388 (1971). C1 Other: = 00991. PHX MT: OME Resurt.t... PENDING te D. CAUSE OF ACTION 1. State the constitutional or other federal civil right that was violated: _ | 5 8 □□□□□ ~ RLUIPA - (2079 } . CountI. Identify the issue involved. Check only one. State additional issues in separate counts. L] Basic necessities L] Mail C1] Access to the court L] Medical care | Disciplinary proceedings LC] Property iJ Exercise of religion L) Retaliation [] Excessive force by an officer LJ Threat to safety LJ Other: 3, Supporting Facts. State as briefly as possible the FACTS supporting Count I. Describe exactly what each Defendant did or did not do that violated your rights. State the facts clearly in your own words without legal authority or arguments. On 28 December 2022, T was dranslsrred t Loum □□□ - Tucson Co O O Ioere me O22 TL Aur pool OC le lode? Chaf ¢ 4 T hae OC NW ha! AOA a CAN OS) Haat : o dp Sian Un ds ciddengl cveorly Muth = tut Services On lp Toners 2023 7 Arne in aon eleohrw Yivwke, leddel dr Chao enaonzp, Aohbrraga Wim orcwed ther Tues a □□□□□ OS + L AM a bide. ts LQ) WV at ben . 4 h (CH) □□ □□□□ O Tenens 2023 veconed a tWmoen response Im Olan ZA realy ACH y £ On □□□ rv) Obbench Ac MiyyiAy □□□□ Wnecause, "To was He mig Wheean an He yor. he hot Ame 4 Nas eres haphens A> yu On ail of the hes Ulan oie ow. een )ipohiloited lm abdtachn □□□ □□□ aach Tam preg uct hs dhe mls ices mom the (yore, On ID Maerrh ZO24 J not ls dla Chaplin Venalm2a iA bie affes. aN ESCA ecloal olojechm he. Again Vy Tas Or fem attending Muth - Ruta Series “Vee curve 0 Injury. State how you were injured by the actions or inactions of the Defendant(s). T ha NOR Oc Oy) nat oe) 1 wtc: nv □ □□ by attend rela: er nel try omen A Sacred bash □□□□ te Capon ahrekn 1% pec of a 72 ear Ghat udhere. To have □□□□□□ prachurg my rehqom. Administrative Remedies: a. Are there any administrative remedies (grievance procedures or administrative appeals) available at your institution? Yes LI No b. Did you submit a request for administrative relief on Count I? (23-051349 4) Yes □ No c. Did you appeal your request for relief on Count I to the highest level? i Yes □□ No d. Ifyou did not submit or appeal a request for administrative relief at any level, briefly explain why you did not. COUNT II Mr 1. . State the constitutional or other federal civil right that was violated: _| 7 g / yn A □□□□□ p American Coes Act ° k LuuPA _( 201) 2. CountII. Identify the issue involved. Check only one. State additional issues in separate counts. L] Basic necessities C) Mail L] Access to the court C] Medical care Disciplinary proceedings Property L] Exercise of religion Retaliation Excessive force by an officer 1] Threat to safety C1) Other: 3. Supporting Facts. State as briefly as possible the FACTS supporting Count II. Describe exactly wha each Defendant did or did not do that violated your rights. State the facts clearly in your own words withou citing legal authority or arguments. On Feloruan4 202% the TRS Sent me tum checks { $1200), OD □□□ GE as Dard of Hu Dhmulis Package. OUth age m_ dae Aes ican Cares Ard □□□ lay dhe U5, Cmaerrsy. Uda AL Aon ne m™ Q. Pumort a f ~ a 441 a □□ Ancbren TnL vmale. te Aa OFce immechaleliy P120C) □□□ Qi oy, Mus “ke (SAL Atta AN acl ters Tu se. Nohfodl Har thew Aye 4H) Mier a Wns 2 af A 4 e @. fwoce Rone Andreu pared TV Vib □□□□ Coto Ky rp mes Nou clic io fecrha UM E □ Quid Came. vr A ier Cb cde CAO)? uA Ameri re Fx 2 WV Viohtins hyo C1 ZING Muu □ hd p Dervassipyy of Hae. radi Jal veeeunng Hare 11AS □□□ ond Ceriaahy iA not ¢ feryuss im 8 Anadlrtuss re | □□□□□ COTM Geum, Dud Merhner onc) Director Thornod) chose (G □□□□ nor answer pus Formal gneveo, ond — Fora) gntlane, appeals, 4. Injury. State how you were injured by the actions or inactions of the Defendant(s). Chad wer 1200 shen broom me That rawors WAS Supposect bd □□□ Stal. That fer A "0 alod ectmarker ts Nucchase liguiss □□□□□ ao £ am probiloite hom Pracncaadgy va rehgun- 5. Administrative Remedies. a. Are there any administrative remedies (grievance procedures or administrative appeals) available a your institution? MYes ON b. Did you submit a request for administrative relief on Count II? 4 23- 05237 3) Yes CIN c. Did you appeal your request for relief on Count II to the highest level? Yes ON d. Ifyou did not submit or appeal a request for administrative relief at any level, briefly explain why yo did not. COUNT UII dn Hh 1. State the constitutional or other federal civil right that was violated: 17 5 g 14 Amel □□□ ( 2ovn) 4 RouseR Vv. Waite, 2. Count III. Identify the issue involved. Check only one. State additional issues in separate counts. L] Basic necessities Mail L) Access to the court L) Medical care Disciplinary proceedings L) Property Exercise of religion CL] Retaliation Excessive force by an officer LJ Threat to safety [1 Other: 3. Supporting Facts. State as briefly as possible the FACTS supporting Count III. Describe exactly wha each Defendant did or did not do that violated your rights. State the facts clearly in your own words withou citing legal authority or arguments. On 3% Jane 2003, Twa afore lou Chatlan Venalmzo □□□□ TF . not alowed ty Drach co m4 rehiqun a ZL the (ican □□ the He Cited Safehs reasons twen Hugh T Wacl never expresserl on As alter Nahue hoy Ww of GUN oh fr As rd { ehguw □ toads autre do lous religuats looks Ternt Cemly and Runes. T Spent SUS em His low On | Merh. COTT Noel appraisal Poe order ond on 8 Marh Depuhs □ oppaed He orks, On 10 Marh Chaplan Venralonzo appmed The {adia'a vemuet fren pu Tare Park Attount □□□ oo Ch Sent ty lew selluyn Ponts - an ADoc opps xd venclor. On 3 Afi) 201% Wen Me lapoks arrind Twas dole TO td not oy 1 Ur 1 ww l Aboc has pmo mfyrws me Hnat □□□ of yu lommks watt be □□□□□□□ in Y ou OTT Nye Du) Merhngr, an haplan Venalonzp Inaud Haat onderecl ue laws □□□ Pres apped de ovalor. 4. Injury. State how you were injured by the actions or inactions of the Defendant(s). nent *U10 on hdua MOIS on A ehanss Mah unger the heot Amand me TOChO sl Gy, g plakect. 5. Administrative Remedies. a. Are there any administrative remedies (grievance procedures or administrative appeals) available a your institution? Xt Yes LI Nc b. Did you submit a request for administrative relief on Count III? ¢ 23- 09438 □ □□ Yes CI Ne c. Did you appeal your request for relief on Count III to the highest level? Yes LI Nc d. Ifyou did not submit or appeal a request for administrative relief at any level, briefly explain why you did not. If you assert more than three Counts, answer the questions listed above for each additional Count on a separate page. TZ COUNT & 1. . State the constitutional or other federal civil right that was violated: J 5” g" py Amenel RunPA of 2600; RouseR vi Whi Ww Se 2. Count B. Identify the issue involved. Check only one. State additional issues in separate counts. LJ Basic necessities L] Mail L] Access to the court ~ C1 Medical care Disciplinary proceedings L] Property BJ Exercise of religion C1 Retaliation Excessive force by an officer 1 Threat to safety [1 Other: 3. Supporting Facts. State as briefly as possible the FACTS supporting Count’ Describe exactly whe each Defendant did or did not do that violated your rights. State the facts clearly in your own words □□□□□□ citing legal authority or arguments. Oy 30 Tenens Wz Wile ad Ron AWYA OF ‘Lucs □□□□ L OW WoC) OU Chaplain RNa They’ __tuh DiDlhioited Won □□□□□ Muth - & Vy 2. 2 ED rng =O! ‘Tree AM ng AU be A AlRCNG etnad of Dyracnuna Ms rehoaip T owvelere Tor On Wn uine ms alee WA WJwaunde - a ADD DN-Ach □□ 0) IL Meehw 202%, * On Me. ClO ng cvrite 15 GNNQV ars UL Nive apn 4 Leouhs A Crelo Merhaee om ¢ Mer □□ Or Mor_w T Las Odrrrxecl lay, G\law) OlOA2O At □□□ □ twas Inia there was NO" Oaperumie to fii att owl Twas □□□ of He asool hy Seok Nerrussion from Senin sola □□ □□□ On Apr 20% Lie Apwemech vor, Fe AD4- Hat □ T) ] | Ac ale , Terot ( revs Gacd UALS ane laleelect □□□□ " load” Sahag shat Torot Comls ant Rurps rere. 2 32. Dehrimendn Hie sale Socure, ancl ovrleriys aperahm of Hie Koil ty J : fipel—2b28, Tagan meh iile “Chaplain Venalnreolanit Has he cernetaled Haar Thc not neccl ty Fi ou (aperunste ancl 4 4. Injury. State how you were injured by the actions or inactions of the Defendant(s). hae 2-20 nite Mm J □□□ Sh NAD i igh? AN WN af oF □□□ re. □□□ AYO CIOUD » T (Ly C0 YoU Bers ow □□ □ AMulu Cher kK h shtre LAse I pL 28 eS¢ by litvS. 5. Administrative Remedies. a. Are there any administrative remedies (grievance procedures or administrative appeals) available 2 your institution? Yes UN b. Did you submit a request for administrative relief on Count B? (73-054 3g 39 bd Yes ON c. Did you appeal your request for relief on Count ae the highest level? Yes ON d. Ifyou did not submit or appeal a request for administrative relief at any level, briefly explain why yo did not. mb tae he. tusuld.. Speak. bs He Senor. Chaplan_ (were) ard get □□□□□ aurea... HR. told me do.redumn Hae next olov ab 1O0D nts. He □□ Apal.2023, We mer nth me aad. wnbor edd... (foe. of □□□ ood bo All_out...Foces Qib-1. □□□□□□□□□□□□□□□□□□□□□□□□ Ship Hae Torok Conals and Runes... oak do □□□□□□□□□□□□□□□□□□□□□□□ have Llewettyn reship..dne.. Corclsandl_.cunes..loaels Haan ne usd give Hagm fe me nfarmal. response, COT Goruwodclesem sec! Are. Taner. □□□□□□□□□□ ems" when infact, they ore religions item. Aryedt_ts lated. The _gnievane as" UNPROCESSED. even... □□□□□ adsiqued it a Case number cad. ofheraliy ce spondled fe it Formal □□□□□□□□□□□□□□□□□□□□□ qvrietan. appeal. wert... never. Mw os COUNT cin ght 1. . State the constitutional or other federal civil right that was violated: _I°, 5 8 IW □□□□□□ RuweA (2opp) + Rouse Vv, WHITE x SSS 2. Count H. Identify the issue involved. Check only one. State additional issues in separate counts. L) Basic necessities L) Mail L) Access to the court L] Medical care L] Disciplinary proceedings L] Property Exercise of religion CJ Retaliation C1 Excessive force by an officer 1 Threat to safety [1 Other: 3. Supporting Facts. State as briefly as possible the FACTS supporting Count BN. Describe exactly wha each Defendant did or did not do that violated your rights. State the facts clearly in your own words withou citing legal authority or arguments. On 30 Tenses 2025 Ts inbsrmecl boy Chaplaa Venalontg thot FT us ited fmm _a neg FENG rs 4 n phe ple, Vea ay □□ □□□ oali4 Udican om Ho Lh are, J On | ann 202% T Q lavecl an ovvles Frsy eh gins law KS Wuidh □□□□□□□□□□ unde - an AMe - appns eel Vendy. On tha Lid LA OT Noel apprned He orde Lu ADALZZ □□□□□□□ the, Wverle Q Mere n Cape ef) 4) ONOMKRA The □□□□□ Meth On Cec, of tf Apnl 202% T ceeenech Form 9p4-% tahyeming COR Dunn conlscaterd pus rebiqioss loonk * " Toret bye Regnery □ COM Duan Clamed Here oes Nuelhy ia Hae lok □□□ dyut Prtsenhaa CL the Sort. There Oho) or Male □□ emiald eMtaha 1) TL YD ov) pf Corl ore. Vnelienecd loy Wrerans ty absiet on dunnahen - an □□□□ 4. Injury. State how you were injured by the actions or inactions of the Defendant(s). c Spent $2000 mm Hs lowe onal fe hgidus Mohby Larere Uilated un oF Aver mont Feborz| lo ) ¢ Re UipA - Lr) ? 5. Administrative Remedies. a. Are there any administrative remedies (grievance procedures or administrative appeals) available a your institution? T HYes ON b. Did you submit a request for administrative relief.gn Count W? (23 - 054384 7 Yes LIN c. Did you appeal your request for relief on Count the highest level? 4 Yes ON d. Ifyou did not submit or appeal a request for administrative relief at any level, briefly explain why yo did not. m7 WI COUNT Hy ah Hy 1. . State the constitutional or other federal civil right that was violated: _[ ° 5 "8° □ Avranlment R LuuPA ( □□□ )_’ Roser vi idbile 2. Count bE Identify the issue involved. Check only one. State additional issues in separate counts. Basic necessities L] Mail CL] Access to the court L) Medical care Disciplinary proceedings L] Property [] Exercise of religion L] Retaliation Excessive force by an officer 1 Threat to safety [1 Other: VI 3. Supporting Facts. State as briefly as possible the FACTS supporting Count B. Describe exactly wha each Defendant did or did not do that violated your rights. State the facts clearly in your own words withou citing legal authority or arguments. On 30 Tanueng 202% Twas informer □□□ Chreplaa Venalaneo Hoar Tw Ore mM OtrenAg FEA 1 e105 pyr thie, 6dlo PCISO 2) □ J LEA VM -TVo NOE. [| Mer 202% TE Dlacecl an olor for requis looks lith □□□□□ Udociawrele, - an Ao’ - apharecl Pedic, so Uencl. On that Saw claw CO mT Nbpel appawect This Peg ud wrler ond on 2023, Depuby laren Machaor aden” appre Hn oveles. On ID Merh 2023 Chaplain Venalomze appar Hud avele 2cudinc tb wwe iter none h Nrrtn 2 uf . a the eveman of Aan) b, 202 VECO ILE 409- Nbymiag □□ Hot COT Dunn had tonfiscaled ru religious look " Chakras far Regia ner: Fam Hae oveler lesen bert lowe. CO 1 Duan am. Stated that Here. Way Nucl, h4 (A He, laer\ié Lutthaut offer» Gas eviclonte of Has, There. ore. DL Plantess of Male wo Female Geni □□□ 15 36 \nersk alom ik Spicihaal 2 Nera Ctakers Thay been rmecl Hak Hae Vani unl hoe closhns 4ecl aber IO □□□□□□ 4. Injury. State how you were injured by the actions or inactions of the Defendant(s). —-- J Daucl $29.02 for Has look onal ry Chass fighh were widlatecl □□□□□□ Hw Firat: Amendrvnk od Fecleel fou. 5. Administrative Remedies. a. Are there any administrative remedies (grievance procedures or administrative appeals) available a your institution? vc MYes ON b. Did you submit a request for administrative reliefqn Count H? ¢ 23- 054395 Yes ON c. Did you appeal your request for relief on Count eb the highest level? bd Yes DON d. Ifyou did not submit or appeal a request for administrative relief at any level, briefly explain why yo did not. a3 Vit COUNT or Ah I □□ 1. State a constitutional or other federal civil right that was violated: 3 8 iy Arund ments RlLuifA of 2om Vit 2. Count Mf. Identify the issue involved. Check only one. State additional issues in separate counts. Basic necessities L] Mail L] Access to the court CL] Medical care L] Disciplinary proceedings L] Property & Exercise of religion LJ Retaliation LI Excessive force by an officer 1 Threat to safety [1 Other: 3. Supporting Facts. State as briefly as possible the FACTS supporting Count Describe exactly wha each Defendant did or did not do that violated your rights. State the facts clearly in your own words □□□□□□ citing legal authority or arguments. On 10 Merch 2024, mer wo Chaplara Venulon22 aloout □□□□□ Muih - fay Seritea as T am a Wea, He Said Phat Since Taw the only Lueca an He ord Tas not awed to atencl Multi - | Serves, He Di sa uf Het To ws a)werl awe □□□ Clery of mu Pethquv, Gai 2 a bashyal cg Keguest Fw 3 T hive it at a ve: at fy Wim on dhat Some cla $10 Mech 207327 LD □□□ Aiud at a S¢ m Cnel turne t bsne □□ leaker ther My rms □□□ N ALIVE ? CNce ah Aa? hil ait a Seem >é POG her wack hat mip uns “From mA Cle LGA, BW Noe igi) fom ebigindd clerai Coupled Untr te Umhscahm □□ e C11 Gis DeMics _€ Mage Ly Qlimag He _ Oyo □□□□□□ mM OtHenchaa re io See Grundy O FOI vy¥4 COM □□□ LO of ma Pynchon aad Dorhes pahrg (A my rehgqun The Anizna enh, of Correch mw had clo Clerecs cng] Wager □□□□ OA. MHaArguvr. 4. Injury. State how you were injured by the actions or inactions of the Defendant(s). Aso 2OU4 neon $ Ou AS1 elgiu □□□□□□ wv) 74 AGLI “A □□ was \dst_ alauecl GITeng oO” Derhcrpare in eursy” Serinced. 5. Administrative Remedies. a. Are there any administrative remedies (grievance procedures or administrative appeals) available a your institution? Wi Yes □□ Nc b. Did you submit a request for administrative relief. on Count B? x 23-054 67? Yes LI Nc c. Did you appeal your request for relief on Count PE the highest level? Yes Nc d. Ifyou did not submit or appeal a request for administrative relief at any level, briefly explain why you did not. ad COUNT @& r jy Ay fy 1. State the constitutions or other federal civil right that was violated: __| 5 8 14 Amendment * LuipA of 2000) 3 Roser vi While Wr 2. Count Mf. Identify the issue involved. Check only one. State additional issues in separate counts. L] Basic necessities L] Mail LJ Access to the court L] Medical care L] Disciplinary proceedings L] Property Exercise of religion L] Retaliation L] Excessive force by an officer LJ Threat to safety CJ Other: Vir 3. Supporting Facts. State as briefly as possible the FACTS supporting Count MZ. Describe exactly wha each Defendant did or did not do that violated your rights. State the facts clearly in your own words withou citing legal authority or arguments. On 30 Tenner, 202% sod informecl loy Chaplain Venalanzo dhe Asay Ag ANowrtedl tr Pathe iy , £ J □□□ Hr) ore Ye Cibenl Safehy rdoond Hrgn Taal noe? □□□□□ Mw WICO Ci) "Q rnahir wv) ot UN~S bo Ac, me Gli’ : AS" ALHVNN' 224 aA Qn Cb, thoum pry th" hes 0 ON Maaa □□ Wns aubrvzel dy Ourthase Ag T Spenr *292 “on > □□□□□ We orton ach AL 10)... He oreles M Meth □□□□□ Ch Aalanip apne p wrlo The Moris rd re mmsedd □ □□□□□□ Penk. ACh wid oN GPA 4 163 l May 20% T uns rnb bu COD Shunrg Hat □□ Dunn ak the wy CLE LL Lp = ASG rn ELA pve OCs □□□□□ SV oct fry Meany Magazi AL n J D5$065 70 ‘Thi □□□□ ow AD MGAaa21Ae Af NoSSeSSIw) v Lag LT aftere, 4. Injury. State how you were injured by the actions or inactions of the Defendant(s). Tuas arahect of 4292 0a and rug Cas h hubonra l Diglily carl tre 19 5” Bh pol [Ys Amenlveats Lyre wolatect 5. Administrative Remedies. a. Are there any administrative remedies (grievance procedures or administrative appeals) available a your institution? Wa Yes LIN b. Did you submit a request for administrative hee w@? g 235-0571 Wy Yes ON c. Did you appeal your request for relief on Count Mf to the highest level? Yes LIN d. Ifyou did not submit or appeal a request for administrative relief at any level, briefly explain why you did not. If you assert more than three Counts, answer the questions listed above for each additional Count on a separate page. @ _( Continual)... —receve Ave (5) Magazines. abo. hme, reac tren, □ chopose Hoan col. dren recewe another Rue. C9) magenass.,. all. 30. Magazines _Wxtre. reach onal ors porecl..of, tour. ADOC E. REQUEST FOR RELIEF State the relief you are seeking: The Ola nhfl Seeks an of 5 million collars for achua| damac NCOLaryer) 2 of re 10 DN □□□ □□ fi icke Oe 10012. AL □□□□ | ny, ™ ling feos lenal coples lega) mal, ele) ancl “pun due dam ered Ina He DYawblf cheb olelibemle untnshhuhmal □□□□ □ ach pomithd lay re. clelendlaak, no _Knou □ □□ Ahere Vaud WIE 4 E CNA AA TV} PAC YONG □ I declare under penalty of perjury that the foregoing is true and correct. Executed on Lly June 2025 EZ 208 □□□□ DATE SIGNATURE OF PLAINTIFF (Name and title of paralegal, legal assistant, or other person who helped prepare this complaint) (Signature of attorney, if any) (Attorney’s address & telephone number) ADDITIONAL PAGES All questions must be answered concisely in the proper space on the form. If you need more space, you may attach no more than fifteen additional pages. But the form must be completely filled in to the extent applicable If you attach additional pages, be sure to identify which section of the complaint is being continued and □□□□□□□ all pages. Bil