HomeMy WebLinkAbout07.19.26 Board Correspondence - FW_ RESUBMISSION_ FORMAL CRIMINAL COMPLAINT _ POLICE REPORT - ENLOE HEALTH ER (Medical Abandonment, Records Falsification.ATTENTION: This message originated from outside Butte County. Please exercise judgment before opening
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From:Clerk of the Board
To:Clerk of the Board; Cook, Holly; Cook, Robin; Jessee, Meegan; Kitts, Melissa; Krater, Sharleen; Lee, Lewis;
Pickett, Andy; Stephens, Brad J.; Sweeney, Kathleen; Zepeda, Elizabeth
Subject:Board Correspondence - FW: RESUBMISSION: FORMAL CRIMINAL COMPLAINT / POLICE REPORT - ENLOE
HEALTH ER (Medical Abandonment, Records Falsification, Security Intimidation, & Statutory Violations) (Original
Transmission: May 28, 2026, 6:43 AM)
Date:Monday, July 20, 2026 9:53:41 AM
Attachments:image001.png
Please see Board Correspondence -
Lewis LeeAdministrative Technician - ConfidentialButte County Administration25 County Center Drive, Suite 200 • Oroville, CA 95965T: 530.552.3326www.buttecounty.ca.gov | lelee@buttecounty.ca.gov
From: Jeff Coats <blizmare@gmail.com>
Sent: Sunday, July 19, 2026 7:32 AM
To: ereinbold@paradiseca.gov; District Attorney <District_Attorney@buttecounty.ca.gov>;
melvis@paradiseca.gov; Clerk of the Board <clerkoftheboard@buttecounty.ca.gov>; Connelly, Bill
<BConnelly@buttecounty.ca.gov>; Durfee, Peter <PDurfee@buttecounty.ca.gov>; Ritter, Tami
<TRitter@buttecounty.ca.gov>; Kimmelshue, Tod <TKimmelshue@buttecounty.ca.gov>; Teeter,
Doug <DTeeter@buttecounty.ca.gov>; police-records@chicoca.gov
Cc: Sommies Brown-Coats <sommies.bc@gmail.com>
Subject: RESUBMISSION: FORMAL CRIMINAL COMPLAINT / POLICE REPORT - ENLOE HEALTH ER
(Medical Abandonment, Records Falsification, Security Intimidation, & Statutory Violations) (Original
Transmission: May 28, 2026, 6:43 AM)
NOTICE OF RESUBMISSION: This document constitutes a formal resubmission of the
original Formal Criminal Complaint transmitted on May 28, 2026, at 6:43 AM. This version is
resubmitted to ensure the record is complete and properly logged with all relevant oversight
bodies as of this date.
REQUEST FOR ACKNOWLEDGMENT: To the Office of the Town Clerk of Paradise, the
Office of the Clerk of the Board of Supervisors for Butte County, and the Chico Police
Department: Please provide formal written acknowledgment of receipt of this filing and
confirm that it has been logged into the official record.
FORMAL CRIMINAL COMPLAINT / POLICE REPORT
I. JURISDICTIONAL & MANDATORY ADA ACCOMMODATION NOTICE: This
formal report is submitted digitally and remotely as a mandatory reasonable modification of
standard intake policies pursuant to Title II of the Americans with Disabilities Act (ADA), 42
U.S.C. §§ 12131-12134, and federal regulations at 28 C.F.R. Part 35. The primary
complainant is a homebound disabled citizen, making in-person filing or physical interviews
impossible. Furthermore, severe Neuropathy in the hands renders manual handwriting or
physically filling out standard paper reports completely impossible. Digital transmission is a
strict medical and functional necessity, as the complainant relies exclusively on voice-to-text
assistive technology to communicate and compile documentation. Standard public web forms
are structurally un-accommodating as they artificially restrict data field lengths and attachment
sizes, preventing a complete, unredacted criminal filing. Under federal and state law, public
entities are strictly prohibited from utilizing administrative methods, intake procedures, or
criteria that screen out or discriminate against individuals with disabilities.
Because local channels have failed to secure immediate intervention, this direct multi-agency
filing is legally necessary. Any attempt to reject, refuse, or delay the logging, investigation, or
processing of this formal report based on its digital/remote transmission format constitutes an
explicit failure to accommodate and an intentional deprivation of rights. Such actions establish
a direct, concurrent violation of the following statutory authorities:
Title II of the Americans with Disabilities Act (42 U.S.C. § 1983): Outlawing the
exclusion of qualified disabled individuals from participation in or denial of the benefits
of services, programs, or activities of a public entity.
Section 504 of the Rehabilitation Act of 1973 (29 U.S.C. § 794): Prohibiting
disability-based discrimination and exclusion from equal access under any program or
activity receiving federal financial assistance.
Federal ADA Department of Justice Regulations (28 C.F.R. § 35.130(b)(7)):
Requiring public entities to make reasonable modifications in policies, practices, or
procedures when necessary to avoid discrimination on the basis of disability.
California Government Code Section 11135: Prohibiting the denial of full and equal
access to benefits or discrimination by any program or activity funded or operated
directly by the State.
Deprivation of Rights Under Color of Law (42 U.S.C. § 1983): Creating immediate
civil liability for any public official who willfully subjects a citizen to the deprivation of
rights, privileges, or immunities secured by the Constitution and federal laws.
II. STATEMENT OF FACTS & REPORTED OFFENSES: Suspect Entity &
Unidentified Personnel:
Primary Corporate Entity: Enloe Health / Enloe Emergency Department
Suspect #1 (Enloe Triage Nurse): John Doe (Exact identity unknown; male; managed
data input on May 25, 2026)
Suspect #2 (Enloe Security Guard): Rudy (Badge Number: 15; initiated the fabricated
weapons search ultimatum)
Executive/Administrative Leadership Notified: Mike Wiltermood (CEO), Sean Maiorano,
Sandra Bernstein, Sean Liston, Kevin Woodward, Rick Krepelka, Gloria Godinez
Incident Timeline & Context: On May 25, 2026, the complainant—a homebound and
severely disabled adult suffering from documented Malignant Thyroid Nodules, Spinal
presenting an imminent risk of paraplegia), Asthma, Complex Post-Traumatic Stress Disorder
(C-PTSD), Agoraphobia (with Panic Disorder), and Chronic Severe Hypertension—was
experiencing an acute cardiac crisis consisting of severe chest pains, heart palpitations, and an
initial blood pressure reading of 165/90.
Because the Town of Paradise Police Department (Paradise PD) maintains an ongoing pattern
of targeted harassment, specifically weaponizing non-criminal Emergency Medical Services
(EMS) transport and deploying police presence to intimidate and harass the complainant into a
hypertensive crisis, the complainant was forced to utilize alternative, non-emergency methods
to seek help. Fearing further state-instigated medical trauma, the complainant and his Power of
Attorney were compelled to sit at a street corner with a sign, begging passersby for a ride to
the hospital, ultimately relying on a civilian bystander for transportation to the Enloe
Emergency Department. Due to acute, severe Asthma-related breathing difficulties and
profound physical exhaustion, the complainant was physically unable to handle continuous
questioning upon arrival and explicitly requested that triage personnel direct inquiries to his
present Power of Attorney. The Chico Police Department is included in this filing because the
incident occurred within their jurisdiction. Chico PD dispatch officers have been obstructing
my ability to make a report. When I called to complain about Paradise PD weaponizing non-
criminal EMS transport and the resulting inability to call for help during a medical crisis, the
dispatch officer said, "Call Paradise PD, this is not our jurisdiction," and when I pushed back,
they said, "You're tying up a 911 operator," and hung up. I did not call 911, I called the non-
emergency line. This pattern of behavior is consistent with the interactions previously
experienced with the Paradise Police Department.
Specific Criminal Conduct & Sequence of Events: Hostility, Fraudulent Charting, and
EKG Spiking: The intake triage nurse became overtly hostile toward this necessary medical
accommodation request. In direct response to this escalating conflict, the complainant
explicitly stated to the triage nurse: "This contention is causing hypertension." Immediately
upon hearing this statement, the triage nurse pulled the privacy curtain closed and aggressively
began typing his fabricated narrative into the electronic medical file.
During this active display of hostility, the complainant was under extreme psychological and
physical stress, actively spiking on the EKG monitor. The complainant's designated Power of
Attorney, Sommies Brown-Coats, was standing directly there witnessing the entire exchange.
She was directly watching the triage nurse enter data into the electronic medical file while
simultaneously watching the complainant actively spike on the EKG monitor. This hostile
interaction occurred in full view and auditory range of multiple civilian witnesses present in
the waiting room immediately adjacent to the triage room. The triage nurse intentionally
entered completely inaccurate information, falsely charting that the patient was able to "talk
freely without difficulty" in an overt attempt to falsify records, manipulate the medical chart,
and overwrite the patient's clear need for accommodation.
Manufactured Security Friction & Intimidation: The complainant was subsequently moved
to a private examination room, where medical treatment was proceeding safely and
constructively. Care, communication, and interaction between the complainant, the Power of
Attorney, and the assigned treatment room nurse were entirely civil, pleasant, and cooperative.
Despite this stable environment and without any internal justification, Enloe security guard
Rudy (BN: 15) abruptly breached the private room and halted an active Electrocardiogram
(EKG) diagnostic procedure. The guard demanded to perform a physical search for weapons
based on a completely fabricated, external claim of patient hostility. This unprovoked
treatment nurse was visibly surprised and blindsided by security's disruptive actions. This
fabricated intervention served solely to escalate patient distress and establish a highly hostile
environment during a live cardiac evaluation.
Coerced Departure via Unlawful Ultimatum: Faced with targeted security intimidation and
the sudden termination of emergency cardiac testing, the complainant was explicitly coerced
to leave the facility while in an active medical crisis. Security personnel issued an unlawful
ultimatum: the complainant must either submit to an unjust, humiliating, and entirely
fabricated physical search for weapons or immediately vacate the premises. Refusing to
comply with this illegal search as a condition for receiving emergency care, the complainant
was constructively forced out of the hospital.
Crucially, because the hospital engineered this forced departure, they completely failed to
issue any formal discharge papers, medical instructions, or administrative clearance,
effectively ejecting an unstable patient in active cardiac distress onto the street without a legal
discharge. Enloe security personnel followed the complainant outside the exit, deploying
snide, provocative, and antagonistic remarks while the complainant was visibly staggering,
disoriented, and wobbling.
Physical Trauma via Proximate Causation: Due directly to the physical distress,
unaccommodated Asthma exhaustion, neurological instability in his lower limbs, and
deliberate psychological provocation engineered by staff, the complainant fainted and
collapsed onto the pavement immediately outside the facility. Given the complainant's severe
Spinal Stenosis and lower body Neuropathy in his legs, this collapse caused an impactful head
injury and created an extreme, immediate risk of permanent spinal trauma.
Enloe medical and security personnel witnessed the exit and subsequent collapse but failed to
render emergency aid, provide basic medical assistance, or check on the patient's condition.
Furthermore, multiple civilian witnesses outside directly observed the collapse and the entire
aftermath; despite the clear medical emergency, absolutely nobody stopped to render
assistance or help. The complainant was left abandoned on the ground across the street from
the hospital for approximately one hour until private transportation could be secured.
Severance of Essential Emergency Access: By constructively hounding the complainant out
of the area's primary emergency room via a coercive security ultimatum, Enloe Health's staff
effectively severed his access to the only functional emergency medical infrastructure
available, leaving him in a critical state requiring urgent care for the underlying cardiac
complications, spinal trauma, and the newly sustained head injury.
III. EXPRESS STATUTORY VIOLATIONS & LEGAL EXPOSURE: The systematic
actions of the Enloe Health administration, triage staff, and security personnel constitute
direct, actionable violations of the following penal and civil codes:
California Penal Code § 471.5 (Falsification of Medical Records): The intake triage
nurse, with malicious intent, deliberately created a false electronic medical record by
charting that the complainant could "talk freely without difficulty" while concurrently
witnessing active respiratory distress and EKG spiking.
California Penal Code § 368 (Dependent Adult Endangerment): Staff held
temporary care and custody of a known dependent adult facing an imminent risk of
paraplegia during an active cardiac crisis. Conditioning medical care on a coercive,
fabricated search and hounding an unstable patient into the street willfully placed the
dependent adult in a position of extreme physical danger, proximately resulting in a
physical collapse and head injury.
Federal EMTALA Violation (42 U.S.C. § 1395dd): Federal law strictly mandates the
stabilization of any individual presenting to an emergency room with an active
emergency medical condition. Coercing a departure by issuing a non-medical security
ultimatum to an unstable cardiac patient—and failing to provide any legal discharge
papers, stabilization records, or formal medical clearance—constitutes a flagrant,
criminal breach of this federal statutory mandate.
California Health & Safety Code § 1317: State law mandates that emergency medical
services be provided immediately, continuously, and without interruption.
Manufacturing security friction and issuing an ultimatum to deliberately disrupt and
terminate an ongoing emergency EKG directly violates this healthcare mandate.
California Penal Code § 242 (Battery via Proximate Causation): By executing an
intentional, hostile course of conduct—specifically using a fraudulent security
ultimatum to hound, provoke, and drive a staggering, neurologically compromised
patient off the premises—the suspect's personnel proximately caused the physical
trauma, hard pavement impact, and subsequent head injury.
California Civil Code § 51 (Unruh Civil Rights Act) & The ADA: Triage and
security personnel explicitly refused to afford equal access and reasonable
accommodations by ignoring a present legal Power of Attorney, opting instead to falsify
charting records and deploy security forces to execute a coercive ultimatum against a
patient with documented conditions.
IV. DEMAND FOR ACTION & INDEPENDENT INVESTIGATION: The complainant
is actively lodging parallel enforcement complaints with the California Department of Public
Health (CDPH) and the Centers for Medicare & Medicaid Services (CMS). Due to
documented conflicts of interest, systemic local corruption, and the active participation of the
Town of Paradise Police Department (Paradise PD) and the Chico Police Department in a
broader, ongoing pattern of targeted harassment—including the weaponization of EMS and
police-led intimidation tactics—standard local law enforcement reporting channels are entirely
compromised. Consequently, the complainant demands that the Butte County District
Attorney and the California Department of Justice independently log, file, and investigate
these criminal charges against the administration and staff of Enloe Health under their
respective county and state enforcement mandates, completely bypassing local municipal
police involvement.
V. DECLARATION & SIGNATURE: I declare under penalty of perjury under the laws of
the State of California that the foregoing statements are true and correct to the best of my
knowledge and recollection.
Signed: Jeff Coats, Complainant Address: 1090 Shadowbrook Way, Unit 4, Paradise, CA
95969 Date: May 28, 2026
Signed: Sommies Brown-Coats, Power of Attorney (Executed January 28, 2025) Address:
1090 Shadowbrook Way, Unit 4, Paradise, CA 95969 Date: May 28, 2026
VI. MANDATORY ADA ACCOMMODATION & COMMUNICATION LIABILITY
DISCLAIMER: Pursuant to federal and state disability mandates, the complainant maintains
a permanent, non-negotiable "TEXT ONLY" communication restriction for all direct contact
due to severe medical, physical, and psychiatric accommodations.
Audible Voice Calls: Cannot be accommodated under any circumstances; any attempt
to force voice-based contention or phone interviews directly triggers severe, life-
threatening hypertensive crises.
Advanced Point of Contact: Sommies Brown-Coats is the designated Attorney-in-Fact
and advanced point of contact for all legal, medical, and logistical coordination.
Service Requirement: All formal responses, investigative updates, and correspondence
from receiving agencies must be executed electronically and concurrently delivered to
both parties at the verified digital addresses listed below.
Failure by public or state-funded entities to adhere to these explicit, text-based communication
parameters during the handling of this complaint will be documented as an intentional,
separate violation of Title II of the Americans with Disabilities Act and California
Government Code Section 11135.
Verified Digital Correspondence Routing: Complainant (Jeff Coats): (916) 905-2868
(TEXT ONLY) | blizmare@gmail.com Legal Representative (Sommies Brown-Coats): (916)
807-6583 | sommies.bc@gmail.com