HomeMy WebLinkAbout07.17.26 Board Correspondence - FW_ FORMAL REQUEST FOR PERSONNEL INVESTIGATION_ CRIMINAL ADMINISTRATIVE FRAUD AND CONSPIRACY TO.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; Krater, Sharleen; Lee, Lewis; Little, Melissa;
Pickett, Andy; Stephens, Brad J.; Sweeney, Kathleen; Zepeda, Elizabeth
Cc:Soderstrom, Monica; Nuzum, Danielle
Subject:Board Correspondence - FW: FORMAL REQUEST FOR PERSONNEL INVESTIGATION: CRIMINAL
ADMINISTRATIVE FRAUD AND CONSPIRACY TO CONCEAL DISABLED DEPENDENT ADULT ABUSE CASE # EH-
CMP-26-00174
Date:Friday, July 17, 2026 9:23:24 AM
Attachments:FORMAL CRIMINAL COMPLAINT & POLICE REPORT - ENLOE HOSPITAL (ER).pdf
CEASE AND DESIST - PPD.pdf
FORMAL CRIMINAL COMPLAINT & POLICE REPORT - F&B.pdf
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: Friday, July 17, 2026 8:05 AM
To: dyork@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>; Clerk of the
Board <clerkoftheboard@buttecounty.ca.gov>
Cc: Sommies Brown-Coats <sommies.bc@gmail.com>
Subject: FORMAL REQUEST FOR PERSONNEL INVESTIGATION: CRIMINAL ADMINISTRATIVE FRAUD
AND CONSPIRACY TO CONCEAL DISABLED DEPENDENT ADULT ABUSE CASE # EH-CMP-26-00174
To the Director of Public Health and the Board of Supervisors:
I am filing this formal request for an immediate, high-level personnel investigation into the
conduct of Environmental Health Division Director Elaine McSpadden and Senior Program
Manager Nikolay Ostrovskiy regarding Case # EH-CMP-26-00174. My household is headed
by Sommies Brown-Coats. I reside there as a severely disabled dependent. I am facing cancer
and paraplegia with a long list of systemic illnesses. The actions of your department constitute
a calculated pattern of administrative fraud, systemic failure to investigate, and a conspiracy to
deny a severely disabled dependent access to health and safety protections.
The July 14, 2026 Interaction and the Sham "Inspection"
Director McSpadden’s appearance on July 14 was not a proactive or voluntary act of public
service; it was a reactionary measure forced by my correspondence. That morning, I sent a
formal, pointed email stating: "It's been almost a month since these violations were reported to
your office, and the trash remains. We demand someone do something about this trash and
cite DYE Hair Salon immediately!"
Only after receiving this demand did Director McSpadden come to the site. Nikolay
Ostrovskiy was not present during this site visit. When she arrived, she stood approximately
8–10 feet away from me over the fence. She took her sunglasses off, peering over the fence
directly at me, looking right into my eyes. During this 30-minute face-to-face conversation,
she adopted a persona of warmth and empathy, going so far as to explicitly use the word
"empathetic" to describe how she felt towards my household.
This was a tactical performance designed to disarm me. While she acted with this false
warmth, she was not conducting a legitimate inspection. She remained approximately 6 feet
away from the trash at all times when taking her photos. She did not open a single bag. She
did not physically inspect the waste for chemical containers or hazardous contents. She took a
few photos from a distance to create the appearance of diligence, while ignoring the festering,
non-compliant, and hazardous nature of the site.
Rationale for DOJ and Attorney General Referral
During this on-site interaction with Director McSpadden, and in my prior email
correspondence with both Director McSpadden and Mr. Ostrovskiy, I provided an explicit
instruction that this evidence be forwarded specifically to the California Department of Justice
(Division of Medi-Cal Fraud and Elder Abuse) and the California Attorney General’s Office.
I made this demand because my household is subject to systemic harassment and obstruction
by the Town of Paradise and local law enforcement. I have been effectively locked out of
standard healthcare and law enforcement protections by these municipal entities, and my civil
rights have been repeatedly violated by them. Because the local regulatory and law
enforcement landscape is irredeemably compromised by these conflicts of interest and
documented retaliatory practices, any local investigation by these parties is, by definition, a
sham. I made it clear to both Director McSpadden and Mr. Ostrovskiy that because local
agencies are conflicted and complicit in the harassment of my household, they were duty-
bound to bypass local reporting paths and escalate this to state and federal authorities to
bypass the local culture of corruption and ensure a neutral, unbiased review. Director
McSpadden looked me in the eye and acknowledged this, yet both she and Mr. Ostrovskiy
chose to bury the evidence.
The Bad-Faith Referral and Statutory Violations
Two days later, on July 16, 2026, Director McSpadden issued a closure email stating: "Butte
County Environmental Health has completed its investigation and did not identify any
violations related to hazardous materials or hazardous waste at this location... The trash
accumulation concerns are currently being addressed through an active enforcement process
by the Town of Paradise."
This is administrative fraud. By deferring this case to an agency she knew to be biased and
hostile—the same agency I warned her was complicit in the harassment of my household—she
knowingly ensured that no effective remedy would occur. Specifically, Paradise Code
Enforcement was made aware of these violations repeatedly last year; we sent them images via
email multiple times, and instead of taking action, they engaged in an adversarial pattern of
fighting with both me and Sommies via email and over the phone. Director McSpadden was
fully aware of this history of conflict and the complicity of the Town of Paradise, yet she
willfully chose to offload the case to them anyway. This referral is a violation of Government
Code § 11135, as she knowingly denied my household the "full and equal access to benefits
and services" of the county.
Furthermore, by refusing to forward the evidence of criminal chemical assault and dependent
adult abuse I disclosed to her and Mr. Ostrovskiy to the appropriate state authorities, she has
committed a willful violation of Mandatory Reporting Duties (W&I § 15630).
Chronology of Administrative Failure
February 26, 2025: Date we moved into the property. The sanitation violations have
been a persistent, systemic issue since this date.
November 2025: Date of earliest photographic evidence in their possession showing
different trash at this site, proving this is a chronic, long-term commercial sanitation
failure.
June 22, 2026: I filed a complaint regarding the ongoing sanitation violations,
providing evidence of the long-term, systemic pattern.
July 7, 2026: I reported that the large, alley-blocking trash pile had been cleared;
however, the business remained non-compliant regarding authorized containers and
secure waste storage.
July 14, 2026: The trash returned. I sent a formal demand for immediate action, stating:
"It's been almost a month since these violations were reported to your office, and the
trash remains. We demand someone do something about this trash and cite DYE Hair
Salon immediately!"
July 14, 2026: Only following this forced pressure did Director McSpadden perform the
aforementioned sham inspection.
July 16, 2026: Director McSpadden and Mr. Ostrovskiy unilaterally issued a "no
violation" closure, using the Town of Paradise as a pretext for abandonment, despite my
explicit notice of their conflict of interest and the documented history of adversarial
conduct by Paradise Code Enforcement.
I have attached my Cease and Desist notice served to Erik Reinbold, as well as police incident
reports involving Enloe Medical Center, Ferguson & Brewer Investment Co. (F&B), and
Shelby's Pest Control. These documents demonstrate that the environmental hazards on this
property are not isolated incidents; they are inextricably linked to an ongoing pattern of
targeted criminal harassment and civil rights violations.
Demands for Corrective Action
Immediate Suspension of Case Closure: I demand that Case # EH-CMP-26-00174 be
re-opened immediately under the supervision of a neutral, third-party investigator with
no prior involvement in this file.
Formal Personnel Investigation: I request that you initiate an investigation into the
conduct of Elaine McSpadden and Nikolay Ostrovskiy regarding their failure to adhere
to W&I § 15630, their violation of Government Code § 11135, and their potential
conspiracy to conceal abuse.
Production of Records: I demand the immediate release of all internal case notes, logs,
and evidence of site inspections performed in relation to this case.
I have exhausted all good-faith attempts to resolve this through internal division channels.
Your administration is now on notice that further obstruction will be documented as a
conspiracy to conceal abuse and a violation of state civil rights mandates.
ADA COMMUNICATION MANDATE: I maintain a strict "text-only" ADA mandate.
Audible voice calls cannot be accommodated. Sommies Brown-Coats is the advanced point of
contact for all legal, medical, and logistical coordination. All formal correspondence must
include both parties.
Govern yourselves accordingly,
Jeff Coats 1090 Shadowbrook Way, Unit 4, Paradise, CA 95969 (916) 905-2868 (TEXT
ONLY) | blizmare@gmail.com
Sommies Brown-Coats Head of Household, Attorney-in-Fact, Daughter, Legal Caregiver,
IHSS Provider (916) 807-6583 | sommies.bc@gmail.com
NOTICE TO THE CHIEF IS NOTICE TO THE DEPARTMENT; NOTICE TO THE
DEPARTMENT IS NOTICE TO THE CHIEF
Chief Reinbold,
This formal Cease and Desist serves as an explicit, mandatory demand that the Paradise Police
Department immediately halt its ongoing pattern of unlawful intimidation, harassment, and
discriminatory dispatch protocols directed against me. Specifically, your department must
immediately cease interjecting armed law enforcement personnel into non-criminal, ambulatory
medical transport pickups where no safety threat exists and no law enforcement function is
required.
Your department’s ongoing insistence on deploying police units to intercept my non-emergency
medical transport is a weaponized application of municipal authority. It is a documented medical
fact that forced, hostile encounters with armed police officers directly trigger severe,
life-threatening hypertensive crises given my physical and psychiatric conditions. By maintaining
a policy or practice that conditions basic, non-criminal ambulatory transport on a mandatory
police presence, your department is actively creating the exact medical emergency it purports to
monitor, escalating a private medical transfer into a hostile tactical deployment.
Your department’s actions constitute direct violations of established state and federal statutory
mandates:
1. Title II of the Americans with Disabilities Act (ADA) (42 U.S.C. 12131 et seq.) Under Title
II, public entities are strictly prohibited from discriminating against qualified individuals with
disabilities or denying them the benefits of services, programs, or activities. This mandate
requires law enforcement and emergency dispatch systems to make reasonable modifications
to policies, practices, and procedures when necessary to avoid discrimination. Forcing an
armed police presence onto an individual with documented C-PTSD, agoraphobia, and panic
disorder during a routine medical pickup—where no criminal activity is alleged—is an explicit
failure to accommodate. It systematically denies a disabled resident safe, equal access to
medical transportation services on account of their medical vulnerability.
2. The Unruh Civil Rights Act (California Civil Code 51) California law mandates that all
persons, regardless of their medical condition or disability, are entitled to the full and equal
accommodations, advantages, facilities, privileges, or services in all business establishments
and public entities. Violations of the federal ADA automatically constitute a violation of the Unruh
Act. Your department’s targeted deployment of security and police forces to interfere with an
individual's private movement and ambulatory access strips away the exact protections state
law guarantees against arbitrary institutional discrimination.
3. California Penal Code 368 (Dependent Adult Endangerment) State statutory law provides
heightened criminal and civil protections for dependent adults whose physical or mental
limitations restrict their ability to carry out normal activities or protect their rights. Any person
who willfully causes or permits a dependent adult to suffer, or inflicts unjustifiable physical pain
or mental suffering, operates in direct violation of this protective statute. Knowingly fabricating a
necessity for police intervention to intercept a vulnerable individual—fully aware that the
resulting confrontation directly causes a critical, dangerous spike in blood pressure—falls
squarely within the statutory definition of inflicting unjustifiable mental and physical suffering.
This letter puts the Paradise Police Department on formal legal notice. Should your department
choose to ignore this demand and continue deploying armed personnel to disrupt my
non-criminal ambulatory pickups, this document will be used in state and federal administrative
complaints to establish a malicious, premeditated pattern of deliberate indifference and civil
rights violations.
ADA COMMUNICATION MANDATE: I maintain a strict "text-only" ADA mandate for all direct
communication due to my medical and physical accommodations. Audible voice calls cannot be
accommodated. Sommies Brown-Coats is the advanced point of contact for all legal, medical,
and logistical coordination. All formal correspondence must include both parties.
Govern your department accordingly,
Jeff Coats 1090 Shadowbrook Way, Unit 4, Paradise, CA 95969 (916) 905-2868 (TEXT ONLY)
| blizmare@gmail.com Primary Claimant, Disabled Dependent
Sommies Brown-Coats 1090 Shadowbrook Way, Unit 4, Paradise, CA 95969 (916) 807-6583 |
sommies.bc@gmail.com Attorney-in-Fact, Daughter, Legal Caregiver, IHSS Provider
(Established January 28, 2025)
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 Stenosis, Neuropathy (affecting the hands,
alongside severe lower body Neuropathy in the legs 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:
1. 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.
2. 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 intrusion was so entirely detached from the actual
behavior inside the room that the attending 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.
3. 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.
4. 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.
5. 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. Under state law, the intentional
fabrication or alteration of a patient’s medical chart constitutes a clear criminal offense.
● 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, including Malignant Thyroid Nodules, Spinal Stenosis,
Neuropathy in his hands and legs (with the lower body neuropathy presenting an
imminent risk of paraplegia), Asthma, Complex Post-Traumatic Stress Disorder
(C-PTSD), Agoraphobia (with Panic Disorder), and Chronic Severe Hypertension.
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
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