HomeMy WebLinkAbout07.18.26 Board Correspondence - FW_ RESUBMISSION_ FORMAL CRIMINAL COMPLAINT _ POLICE REPORT (Ferguson & Brewer Investment Co. _ Shelby’s Pest Control).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; Little,
Melissa; Pickett, Andy; Stephens, Brad J.; Sweeney, Kathleen; Zepeda, Elizabeth
Subject:Board Correspondence - FW: RESUBMISSION: FORMAL CRIMINAL COMPLAINT / POLICE REPORT (Ferguson &
Brewer Investment Co. / Shelby’s Pest Control) (Original Transmission: May 28, 2026, 9:33 AM)
Date:Monday, July 20, 2026 9:50:28 AM
Attachments:signed-notarized-attorney-in-fact.pdf
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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 7:20 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>
Cc: Sommies Brown-Coats <sommies.bc@gmail.com>
Subject: RESUBMISSION: FORMAL CRIMINAL COMPLAINT / POLICE REPORT (Ferguson & Brewer
Investment Co. / Shelby’s Pest Control) (Original Transmission: May 28, 2026, 9:33 AM)
NOTICE OF RESUBMISSION: This document constitutes a formal resubmission of the
original Formal Criminal Complaint / Police Report transmitted on May 28, 2026, at 9:33 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 and
the Office of the Clerk of the Board of Supervisors for Butte County: Please provide formal
written acknowledgment of receipt of this filing and confirm that it has been logged into the
official record for the Town of Paradise and Butte County, respectively.
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 Entities:
1. Ferguson & Brewer Investment Co. (7052 Skyway, Paradise, CA 95969)
2. Shelby’s Pest Control (1829 Mangrove Ave, Chico, CA 95926)
Complainant/Incident Location: 1090 Shadowbrook Way, Unit 4, Paradise, CA 95969
Incident Date: November 24, 2025
Incident Narrative: On November 24, 2025, property management (Ferguson & Brewer
Investment Co.) conspired with Shelby’s Pest Control to conduct an un-notified, non-
consensual chemical saturation of my private patio without my knowledge or consent. This act
occurred in direct violation of the 24-hour notice requirement mandated by California
Business and Professions Code § 8538 and 16 CCR § 1970.4. Furthermore, Shelby’s Pest
Control failed to post any mandatory notice at the site of the application identifying the
chemicals used, as required by California Food and Agricultural Code § 12978, a deliberate
omission intended to conceal the use of toxic agents rather than the disclosed "IC3."
Specifically, the applicator did not enter the secured patio enclosure; instead, the agent
sprayed the chemical agent directly over the 6-foot patio fence, indiscriminately saturating the
entirety of the enclosed private space. The application was not mere overspray, but a total,
pervasive saturation extending from the gutters to the ground. Every square inch of the patio
was compromised, including the entire concrete slab, my personal belongings stored within
the enclosure, and the full extent of the patio sliding glass door and screen, which were coated
from top to bottom. Furthermore, the chemical agent heavily coated my metallic therapy chair,
which is utilized for critical Agoraphobia exposure therapy. The photographic evidence
documents extensive chemical residue, clearly characterized by distinct liquid pooling and
bead formation across the metallic surfaces, rendering this essential piece of therapeutic
medical equipment hazardous and unusable.
Critically, this saturation occurred 10–15 minutes prior to my planned use of the patio space
with my daughter, Sommies Brown-Coats (who is also my IHSS provider and Attorney-in-
Fact), and my dependent companion cat, Cuddles. This un-notified, non-consensual chemical
saturation constituted a direct, immediate, and lethal threat to the lives and health of myself,
my daughter, and my companion cat.
I am a medically fragile individual with documented ADA limitations on file. Management’s
refusal to mitigate the hazard forced me, under extreme physical and emotional duress, to
attempt to address the chemical saturation myself. To wash down the toxic chemicals, I was
compelled to connect two 100-foot hoses, attach them to a spigot across the street, and drag
the connected length approximately 150 feet back to my patio. I was forced to handle this hose
bare-handed, directly exposing my skin to the chemical residue while dragging it across the
saturated surface. This occurred while I was suffering from a hypertensive crisis, severe
neuropathy in my hands and legs, and excruciating pain from cervical and thoracic spinal
stenosis. The panic induced by this hazardous environment, combined with Ferguson &
Brewer’s absolute refusal to mitigate the toxic exposure, exacerbated my medical distress.
Subsequently, Kim Eriksen engaged in minimizing this formal complaint, further obstructing
the path to safety and justice.
Furthermore, this unauthorized chemical saturation created a severe and lethal hazard for my
dependent companion cat, Cuddles. Feline behavioral patterns necessitate regular grooming of
the paws, which would have inevitably led to the direct ingestion of any chemical residues
present on the patio. Feline physiology lacks the essential hepatic enzymes required to
metabolize such compounds; consequently, any exposure would be processed as a systemic
toxicant, resulting in irreversible respiratory or neurological failure, or death. Even if the
substance applied were the disclosed "IC3"—a claim I contest—it remains lethal to feline
physiology due to these specific metabolic limitations. I was forced to maintain strict, vigilant
containment of Cuddles to prevent her entry into the hazardous area, but the threat to her life
and safety was imminent, direct, and created entirely by the management's reckless conduct.
It is imperative to note that the filing of this report was not immediate. The delay is the direct
result of two factors: (1) a history of documented, ongoing harassment and intimidation by
local law enforcement, which has created a well-founded and reasonable fear that seeking
assistance would trigger further victimization, and (2) the severe, debilitating nature of my
ongoing medical condition, which renders the process of interacting with local law
enforcement channels physically and psychologically hazardous.
Evidence of Criminal Fraud & Legal Immateriality of Substance: Management and their
agents (Shelby’s Pest Control) explicitly represented to the Butte County Agricultural
Commissioner that the substance used was "IC3." This is a demonstrable falsehood. As a
professional Aquaculturist with over 30 years of experience, I possess specific, extensive
training in the detection, chemical properties, and ecosystemic impact of hazardous
substances, as well as deep knowledge of the microbiology of aquatic systems. Based on this
professional expertise, I can state with certainty that the substance applied was not IC3. IC3 is
a product formulated with essential oils known for a distinct, strong odor. I was physically
present in the saturated area within 10–15 minutes of the application; despite the extensive
liquid pooling on all surfaces, I detected zero chemical odor—a physical impossibility for a
legitimate IC3 application.
Furthermore, let it be explicitly understood that the chemical composition of the substance is
secondary to the criminal act itself. Whether the substance applied was the disclosed "IC3" or
an unidentified toxin is legally immaterial to the core offenses of trespass, battery, and
regulatory non-compliance. The non-consensual, unauthorized saturation of a private
residential patio, coupled with the failure to provide the mandated 24-hour notice (B&P §
8538; 16 CCR § 1970.4), constitutes a criminal violation regardless of the substance used. The
perpetrators cannot utilize the identity of the chemical—even if the substance were entirely
innocuous—as a defense or mitigating factor to minimize the severity of this unprovoked
battery and conspiracy. The representation made to the Agricultural Commissioner, combined
with the willful failure to post mandatory notices of the chemicals used (a violation of B&P §
8538 and Cal. Food & Ag. Code § 12978), was a calculated, fraudulent misrepresentation
intended to obstruct a government investigation and minimize the perceived danger of an
illegal chemical battery.
III. DOCUMENTED OFFENSES: This incident constitutes the following criminal acts:
Criminal Conspiracy (PC 182): Coordinated effort between Ferguson & Brewer
Investment Co. and Shelby’s Pest Control to apply restricted chemicals without notice
and subsequently conceal the nature of the substance from state investigators.
Battery (PC 242) and Assault with Chemicals (PC 244.5): Intentional contamination
of a private dwelling surface with hazardous substances, directly endangering the lives
of the residents.
Elder/Dependent Adult Abuse (PC 368): Reckless endangerment of a medically
fragile individual and his caregiver.
Animal Cruelty (PC 597): Willful exposure of a dependent animal (Cuddles) to toxic,
hazardous chemical agents without notice or safety precautions, creating a lethal hazard.
Obstruction of Justice / Fraud: Providing false information to the Butte County
Agricultural Commissioner and failing to post required chemical disclosure notices
(B&P § 8538; 16 CCR § 1970.4; Cal. Food & Ag. Code § 12978) to conceal the nature
of a hazardous substance.
IV. EVIDENCE EXHIBITS: Please refer to the attached photographic evidence
documenting the total saturation of the patio surfaces, the liquid residue, the contamination of
my metallic therapy chair (showing distinct pooling and beading of the substance), and the
written admission of the chemical application (refuting claims of mere overspray).
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, Daughter/IHSS Provider/Attorney-in-Fact (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 (Daughter, IHSS Provider, and
Attorney-in-Fact) is the designated 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