Barry Joe Stull 10852 SE Stark Street Unit $ Portland Oregon 97216 503-421-4969 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF OREGON PORTLAND DIVISION BARRY JOE STULL, Complaint for a Civil Case -against- Case No, JURY TRIAL REQUESTED JAKOB BUETLER, ARIC JOHNSON, AMERICAN MEDICAL RESPONSE, MULTNOMAH COUNTY OREGON, BRYAN A. WELLS, GERALD A. FINK, RYAN S. KLOSTERMAN, NEILL F. MARTIN, CITY OF PORTLAND OREGON, LEGACY EMANUEL HOSPITAL, DAVID GRIFFITHS DAVIES, MARIO GOCHEZ-CHINCHILLA, TRI MET. UNIDENTIFIED TRI MET PERSONNEL, WEST HELFRITCH, G4S, JAMES WOOD, UNIDENTIFIED G48 PERSONNEL, ROGER S. AXTHELM, TODD ENGSTROM, JEREMY D. PRICE, BRYANT ENGE, UNIDENTIFIED MULTNOMAH COUNTY, SHERIFF OFFICE PERSONNEL, UNIDENTIFIED PORTLAND POLICE BUREAU PERSONNEL, UNIDENTIFIED TRI MET PERSONNEL, KYLE DEAN SHEPPARD, JOSEPH JAMES WITT, DANIEL D. NIPPER, GABRIEL M. MALDONADO, CITY OF TIGARD OREGON, ROBERT STEWART, CLACKAMAS COUNTY OREGON, HEARING! OFFICER DE ARMOND-REID, PORTLAND ADVENTIST HEALTH, MARIO LARA, UNIDENTIFIED ADVENTIST HOSPITAL SECURITY OFFICERS, SCHERISE HOBBS, THOMAS CLARK, KEIKO EGUCHI, STATE OF OREGON, THOMAS CLEARY, KELLY DOYLE COMPLAINT —PAGE 11 The Pai ies to This Complaint A. The Plaintiff Name Street Address City and County State and Zip Code Telephone Number Email Address Barry Joe Stull 10852 SE Stark Street Unit 5 Portland, Multnomah County Oregon 97216 503-421-4969 cannabisboo@yahoo.com Page | - COMPLAINT B. The Defendants Defendant No.1 Name Job or Title Street Address City and County State and Zip Code Telephone Number Defendant No. 2 Name Job or Title Street Address City and County State and Zip Code ‘Telephone Number Defendant No. 3 Name Street Address City and County State and Zip Code ‘Telephone Number Defendant No. 4 Name County Attomey Street Address City and County State and Zip Code Telephone Number COMPLAINT —PAGE 2 Jakob Buetler American Medical Response Paramedic 1 SE 2" Avenue Portland, Mulinomah County Oregon 97214 503-239-0389 Aric Johnson American Medical Response Paramedic 1 SE2™ Avenue Portland, Multnomah County Oregon 97214 503-239-0389 American Medical Response 1 SE 2™ Avenue Portland, Multnomah County Oregon 97214 503-239-0389 Multnomah County Oregon Multnomah County Attorney 301 SE Hawthome Blvd. Suite 500 Portland, Multnomah County Oregon 97214 503-988-3138Defendant No. 5 Name Job or Title Sireet Address City and County State and Zip Code Telephone Number Defendant No. 6 Name Job or Title Street Address City and County State and Zip Code ‘Telephone Number Defendant No. 7 Name Job or Title Street Address City and County State and Zip Code Telephone Number Defendant No. 8 Name Job or Title Street Address City and County State and Zip Code Telephone Number Defendant No. 9 Name City Attorney Street Address City and County State and Zip Code Telephone Number Defendant No. 10 Name Street Address City and County State and Zip Code COMPLAINT PAGE 3 Bryan A. Wells Portland Fire Bureau Firetighter / Paramedic Portland, Multnomah County Oregon 503-823-4000 Gerald A. Fink Portland Fire Bureau Firefighter / Paramedic Portland, Multnomah County Oregon 503-823-4000 Ryan S. Klosterman Portland Fire Bureau Firefighter / Paramedic Portland, Multnomah County Oregon 503-823-4000 Neill F. Martin Portland Fire Bureau Firefighter / Paramedic Portland, Multnomah County Oregon 503-823-4000 City of Portland Oregon City Attorney 1221 SW 4" Avenue Room 400 Portland, Multnomah County Oregon 97204 503-823-4000 Legacy Emanuel Hospital 2801 N. Gantenbein Avenue Portland, Multnomah County Oregon 97227‘Telephone Number Defendant No. 11 Name Job or Title Street Address City and County State and Zip Code Telephone Number Defendant No. 12 Name Job or Title Street Address City and County State and Zip Code Telephone Number Defendant No. 13 Name Street Address City and County State and Zip Code Telephone Number Defendant No. 14 Name Job or Title Street Address City and County State and Zip Code ‘Telephone Number Defendant No. 15 Name Job or Title Street Address City and County State and Zip Code Telephone Number Defendant No. 16 Name Street Address City and County State and Zip Code COMPLAINT =PAGE 4 503-413-2200 David Griffiths Davies Legacy Security Officer 2801 N. Gantenbein Avenue Portland, Multnomah County Oregon 97227 503-413-2200 Mario Gochez-Chinchiilla Legacy Security Officer 2801 N. Gantenbein Avenue Portland, Multnomah County Oregon 97227 503-413-2200 Tri Met 4012 SE 17" Avenue Portland, Multnomah County Oregon 97202 503-238-7433 Unidentified Tri Met Personnel ‘Tri Met Bus Operator 4012 SE 17" Avenue Portland, Multnomah County Oregon 97202 503-238-7433 West Helfritch Portland Police Bureau Officer 1111 SW 2nd Avenue Portland, Multnomah County Oregon 97204 503-823-3333 Gas 5100 SW Macadam Avenue, Suite 550 Portland, Multnomah County Oregon 97239Telephone Number Defendant No. 17 Name Job or Title Street Address City and County State and Zip Code Telephone Number Defendant No. 18 Name Job or Title Street Address ty and County State and Zip Code Telephone Number Defendant No. 19 Name Job or Title Street Address City and County State and Zip Code Telephone Number Defendant No. 20 Name Job or Title Street Address City and County State and Zip Code Telephone Number Defendant No. 21 Name Job or Title Street Address City and County State and Zip Code Telephone Number Defendant No. 22 Name Job or Title Street Address COMPLAINT —PAGE 5 503-291-1005, James Wood GAS City Hall Security Officer 5100 SW Macadam Avenue, Suite 550 Portland, Multnomah County Oregon 97239 503-291-1005 Unidentified G4S Personnel GAS City Hall Security Officer 5100 SW Macadam Avenue, Suite 550 Portland, Multnomah County Oregon 97239 503-291-1005 Roger S. Axthelm Portland Police Bureau Sergeant 1111 SW 2nd Avenue Portland, Multnomah County. Oregon 97204 503-823-3333 Todd Engstrom Portland Police Bureau Officer 1111 SW 2nd Avenue Portland, Multnomah County Oregon 97204 503-823-3333 Jeremy D. Price Portland Police Bureau Sergeant 1111 SW 2nd Avenue Portland, Multnomah County Oregon 97204 503-823-3333 Bryant Enge Director, City of Portland Bureau of Internal Services 1120 SW Sth Avenue Room 1250City and County State and Zip Code Telephone Number Defendant No. 23 Name Job or Title Street Address City and County State and Zip Code ‘Telephone Number Defendant No. 24 Name Job or Title Street Address City and County State and Zip Code Telephone Number Defendant No. 25 Name Job or Title Street Address City and County State and Zip Code ‘Telephone Number Defendant No, 26 Name Street Address and County State and Zip Code Telephone Number Defendant No. 27 Name Job or Title Street Address City and County State and Zip Code Telephone Number Defendant No. 28 Name Job or Title COMPLAINT ~PAGE 6 Portland, Multnomah County Oregon 97204 503-823-6962 Unidentified Multnomah County Sherifff Office Personnel Corrections Deputies Portland Multnomah Oregon Udentified Portand Police Bureau Personnel Office Staff 1111 SW 2nd Avenue Portland, Multnomah County Oregon 97204 503-823-3333 Unidentified Tri Met Personnel Bus Operator 4012 SE 17" Avenue Portland, Multnomah County Oregon 97202 503-238-7433 Kyle Dean Sheppard 3500 NE 17th St. Apt. 1168 Gresham, Multnomah County Oregon 97030 503-980-5136 Joseph James Witt Tri Met Bus Operator 4012 SE 17" Avenue Portland, Multnomah County Oregon 97202 503-238-7433, Daniel D. Nipper #57091 Portand Police OfficStreet Address City and County State and Zip Code Telephone Number Defendant No. 29 Name Job or Title Street Address City and County State and Zip Code Telephone Number Defendant No. 30 Name eet Address City and County State and Zip Code ‘Telephone Number Defendant No. 31 Name Job or Title Street Address City and County State and Zip Code ‘Telephone Number Defendant No. 32 Name County Counsel Street Address City and County State and Zip Code Telephone Number Defendant No. 33 Name Job or Title Street Address City and County State and Zip Code Telephone Number Defendant No. 34 COMPLAINT ~PAGE 7 1111 SW 2nd Avenue Portland, Multnomah County Oregon 97204 503-823-3333 Gabriel M. Maldonado #47256 Tigard Police Officer / Portand Police Bureau Transit 1111 SW 2nd Avenue Portland, Multnomah County Oregon 97204 503-823-3333 City of Tigard Oregon 13125 SW Hall Blvd. ‘Tigard, Washington County Oregon 97045 503-742-5397 Robert Stewart #52271 Clackamas County Sheriff Sergeant / Portand Police Bureau Transit 1111 SW 2nd Avenue Portland, Multnomah County Oregon 97204 503-823-3333 Clackamas County Oregon Office of County Counsel 2051 Keen Road Oregon City, Clackamas County Oregon 97045 503-742-5397 Hearings Officer De Armond-Reid MCSO MCDC Hearings Officer Portland, Multnomah County Oregon 503-823-4000Name Job or Title Street Address City and County State and Zip Code ‘Telephone Number Defendant No. 35 Name Job or Title Street Address City and County State and Zip Code Telephone Number Defendant No. 36 Name Job or Title Street Address City and County State and Zip Code ‘elephone Number Defendant No. 37 Name Job or Title Street Address City and County State and Zip Code Telephone Number Defendant No. 38 Name Job or Title Street Address City and County State and Zip Code Telephone Number Defendant No. 39 Name Job or Title Street Address City and County State and Zip Code Telephone Number COMPLAINT PAGE 8 Portland Adventist Health Adventist Hospital 10123 SE Market St Portland, Multnomah County Oregon 97216 503-257-2500 Mario Lara Adventist Hospital Security Officer 10123 SE Market St Portland, Multnomah County Oregon 97216 503-257-2500 Unidentified Adventist Hospital Security Officer Adventist Hospital Security Officer 10123 SE Market St. Portland, Multnomah County Oregon 97216 503-257-2500 Unidentified Adventist Hospital Security Officer Adventist Hospital Security Officer 10123 SE Market St. Portland, Multnomah County Oregon 97216 503-257-2500 Scherise Hobbs #30864 Portand Police Officer 1111 SW 2nd Avenue Portland, Multnomah County Oregon 97204 503-823-3333 ‘Thomas Clark #50706 Portand Police Officer 1111 SW 2nd Avenue Portland, Multnomah County Oregon 97204 503-823-3333Defendant No. 40 Name Keiko Eguchi Job or Title Investigator, Multnomah County Mental Health and Addiction Services Street Address City and County Portland Multnomah State and Zip Code Oregon Telephone Number 503-823-4000 Defendant No. 41 Name State of Oregon Job or Title Attorney General Ellen F, Rosenblum Street Address Justice Building 1162 Court Street City and County Salem Marion State and Zip Code Oregon 97301-4096 Telephone Number 503-378-4400 Defendant No. 42 Name ‘Thomas Cleary Job or Title Multnomah County Deputy District Attorney Street Address 1200 SW Ist Avenue Suite 5200 ity and County Portland Multnomah State and Zip Code Oregon 97204 Telephone Number 503-988-3162 Defendant No. 43 Name Kelly Doyle Job or Title Indigent Defense Counsel Street Address 117 Sixth Street City and County Oregon City State and Zip Code Oregon 97045 Telephone Number 503-657-2948 IL. Basis for Jurisdi on ‘The basis for federal court jurisdiction is a Federal question. Title 42, Chapter 126, Sections 12203, 12133 and 12188 provide remedies for enforcement of the Americans With Disabilities Act of 1990 ( ADA ), as amended by the ADA Amendments Act of 2008. Plaintiff also alleges federal court jurisdiction under 42 USC Section 1983 and alleges the actions of the various defendants were against plaintiff's civil rights guaranteed under the First, Fourth, Sixth and Fourteenth Amendments of the United States Constitution. COMPLAINT PAGE 9IIL. Statement of Claim Barry Joe Stull (Stull) has long endured a progressive chronic pain condition caused by damage to Stull’s neurological system following an accident in 1976, surgery in 1980, and the passing of time. Stull was first diagnosed with central pain syndrome in 2002, According to the National Ins {tute of Health National Institute on Stoke and Neurological Disorders, central pain syndrome "is a neurological condition caused by damage to or dysfunction of the central nervous system. (CN' |, which includes the brain, brainstem, and spinal cord.” In February 2002, Dr. Robert J. Grimm M.D. charted, "2-15=02 On this date, I spoke to an administrator associated with the Oregon Medical Marijuana Act, who reported that some physicians, would preseribe cannabis, for chronic pain, if in considering all of the issues bearing ona particular case, it was warrantable. On this date, in consideration off Mr. Stull's long experience and use of cannabis, that he is working, his economic circumstances, and the nature of the problem, vis a chronic neuropathic, central (de-afferentiation) pain disorder of 2nd order dorsal horn neurons of lumbar cord~a disorder for which conventional meds are not very effective, and that opiates similarly are not very effective, I shall provide this Mr. Stull with a prescription to obtain an Oregon Medical Marijuana Act license, Additionally, I have written a small prescription for propranalol, to see if it effectively blocks the flares of his acute, severe pain when confronted by emotionally trying periods of his life. He has no asthma history." (Multnomah County Circuit Court Case 0310-35386 exhibit) Central pain syndrome is both chronic and episodic and causes in Stull severe pain and severe nausea, among other episodic conditions such as disorganization and inability to verbalize. COMPLAINT —PAGE 10‘Owing to Stull’s robust physical appearance arising trom exercise as a coping mechanism, Stull’s disability is ordinarily invisible to the casual observer, and Stull catties documentation which identifies Stull as a person with a disability Stull knows central pain syndrome can be life-threatening due to Stull’s neurological condition failing to respond to the usual controls. Emotionally stressful events ean trigger an inappropriate response to stress hormones and produce circulatory failure. Stull was awake and lucid on October 15, 2011 after having been assaulted, which triggered a rise in Stull’s pulse from an elevated 90 beats per minute while Stull was in the ambulance to an uncontrollable abnormal pulse of over 170 beats per minute in the Emergency Department at Legacy Emanuel Hospital. (Exhibit A attached) Stull knew from repeated experiences how after a stressful event triggered Stull’s central pain syndrome into a flare, repercussions would affect Stull for up to a month and leave Stull vulnerable to additional exacerbations, On Friday, November 20, 2015, Stull reported to Legacy Emanuel Hospital Emergency Department (Emanuel Hospital Emergency Department) for a flare of Stull’s central pain syndrome, which Stull recognized from experience and realized had been triggered at an event for which Stull called the Portland Police to the "Hazelnut Grove” homeless community the evening of Wednesday, November 18, 2015. The initial response from the triage nurse on duty November 20, 2015, was that Stull pulse of 80 beats per minute (b:p.m.) was "normal." Once Stull reported that for Stull, any resting pulse rate over 60 b.p.m. is high and a resting pulse rate of 80 b-p.m. indicates a flare of Stull’s central pain syndrome has been triggered Stull was seen by the physician on staff. After COMPLAINT PAGE 11reviewing medical records of the treatments Stull received in that same emergency department, which included treating Stull’s extraordinary heart rate October 15, 2011, Stulll was afforded a safe space in a dimly-lit room, For the most part, Emanuel Hospital Emergency Department personnel recognized Stull’s best treatment was to be left alone in a quiet room, and, depending on the circumstances, given atavan, a mild tranquilizer used in treating Stull by neurologist Dr. Robert J. Grimm, MD, with the understanding Stull’'s condition is worsened by emotional stress. Dr. Grimm treated Stull for many years and those chart notes were scanned into Stull's medical files at Emanuel Hospital Emergency Department by Dr. Cook. On November 20, 2015, in a safe and dimly-lit room, Stull was able to effect techniques lowering his pulse down to around 65 b.p.m., and Stull was discharged. Stull's exit paperwork included the diagnosis "central pain syndrome" and the description of the diagnosis as "central pain syndrome," with instructions to return if the condition worsens. For about a decade, from around 2000 through 2010, Stull was under the treatment of Dr. Robert J. Grimm, M.D., a board certified neurologist with advanced degrees in Neurology and Neurophysiology who operated a brain research laboratory and maintained a practice specializing in diagnosing and treating chronic pain. In 2004, Dr. Grimm's sworn court testimony in Multnomah County Circuit Court Case 0310-35386 included the characterization that Stull's condition is a whole new disease on a molecular level following the rewiring of the spinal cord pain relay by another nerve, and the condition is second only to cancer pain in its difficulty to manage because the usual control mechanisms aren't available. Dr. Grimm testified how while operating a brain research laboratory, he found that once ulated by stress COMPLAINT ~ PAGE 12if the person had epilepsy because those pain hormones, the rewired pain relay "sounded’ relays fired uncontrollably Stull was informed by Dr. Grimm's office visits and court testimony on Stull's behalf of the nature of Stull's central pain syndrome. In Stull, once triggered, a flare of central pain syndrome can reverberate for a month because Stull's physiology includes a spinal cord messenger designed to report pain for a nerve which is now dead at the root, which has been infiltrated and rewired by an unrelated nerve: so that unrelated nerve's signal gets inappropriately reported to the brain, where the signal is decoded and registered as pain originating at the site governed by the dead nerve. ‘This chronic neuropathic pain condition is known as "central pain" because it is a product of damaged nerves in the central nervous system, which consists of the brain and spinal cord, It is also known as "dysesthesia” and "dysthetic pain." Stull's central pain was diagnosed by neurologist Dr. Rosenbaum June 22, 2015 Late afternoon November 20, 2015, Stull contacted the staff at the Portland Police Bureau East Precinct a few blocks from where Stull lives to obtain contact information for the Portland Police Officer Stull had interacted with at Hazelnut Grove Wednesday evening previous, Stull wanted to obtain that officer’s full name and DPSST number, and the number of the police report. At the scene, Stull had requested the officer's business card, and being out, he borrowed one from his partner, wrote his name on in ink pen, which was blurred in the rain. The staffer knew the officer Stull asked about and said his records weren't available since the officer was dispatched out of Central Precinet. On the evening of Sunday, November 22, 2015, Stull called the Portland Police Bureau via the non-emergency number, 503-823-3333, to obtain the contact information for the COMPLAINT ~PAGE 13officer. Stull became frustrated when what Stull had previous experience obtaining with little efffort was being thwarted and again not provided, which sickened Stull Stull broke off with the nonemergency number and called back on 911 for emergency medical assistance. Defendant American Medical Response was dispatched per contract with defendant Multnomah County Oregon When the American Medical Response ambulance arrived, Stull exited his home and said to the paramedic, defendant Jakob Beutler, "Let's get going out of here," and presented the exit instructions with the diagnosis of "central pain syndrome" from the November 20, 2015 Emanuel Hospital Emergency Department visit, which contained its instruction to return if the condition worsened Stull stated he needed transport back to Emanuel Hospital Emergency Department for central pain syndrome. Defendant Beutler asked Stull what central pain syndrome was, and Stull said he'd save that explanation for the doctor and again expressed the need to get traveling to the hospital. ‘The defendant Beutler responded with, "No, I'm calling the police." Defendant Beutler did not know what central pain syndrome was and without training or experience diagnosed Stull as having a psychiatric condition and refused to transport Stull and locked the door of the ambulance to keep Stull out. Neither defendant Beutler nor defendant Aric Johnson made any effort to contact Emanuel Hospital regarding the nature of Stull’s medical condition and both refused to abide by the exit instructions that Stull should return to Emanuel Hospital Emergency Department because neither understood what "central pain syndrome" was. Stull knew what they were doing was ination on the basis of Stull's disability and told them he would see them in court. illegal diser COMPLAINT PAGE 14Defendant Beutler and defendant Johnson refused to transport Stull because they didn't know what central pain syndrome was when Stull described Stull's medical condition as being "central pain syndrome." Defendant Beutler and defendant Johnson made no effort to understand how Stull could die from Stull’s medical condition or Stull’s urgency when they decided not to transport Stull. The American Medical Response ambulance was still on the scene when joined by Portland Fire Bureau and Portland Police Bureau vehicles and personnel. sanding in a semi-circle Within minutes there were approximately ten "first responder around Stull in the main driveway of the Stark Fits Mobile Home Park outside Stull's home. In addition to the two AMR paramedics, there were four Portland Fire Bureau Firefighters and several Portland Police Bureau Officers. Defendant Bryan A. Wells, defendant Gerald A. Fink, defendant Ryan S. Klosterman, and defendant Neill F, Martin were each licensed emergency medical technicians and each failed to make any inquiry regarding Stull’s central pain syndrome although each was aware Stull ‘was wearing a hospital wrist bracelet, had exit instruetions from Emanuel Hospital Emergency Department with the diagnosis "central pain syndrome" and stating Stull should return if conditions worsened, even as and after Stull repeatedly stated to them how Stull could die from Stull’s condition, Neighbors gathered to watch as Stull pled for twenty minutes to be given the medical transport. and later reported to Stull they couldn't believe those professionals all stood around after hearing Stull say to the police, "I could die from this.” The Portland Fire Bureau, Portland Police Bureau and American Medical Response personnel present made various comments amongst themselves while they continued to refuse any COMPLAINT PAGE 15transport or assessment on the scene regarding Stull's medical condition, any inquiry with Emanuel Hospital regarding Stull’s condition although Stull still bore the wrist bracelet from the visit there two days earlier, and refused to transport Stull while it became evident Stull's condition was worsening, evidenced by Stull's ability to communicate being reduced to repeatedly shouting "central pain syndrome." ‘A Portland Fire Bureau Firefighter wearing a name tag "Sampson" said aloud, "He needs a knuckle sandwich.” After being on the scene with Stull for fifteen minutes, one of the Portland Police Officers told Stull he would give Stull a ride to the Emergency Department in the back of his police car provided Stull let him put handcuffs on Stull first. Stull agreed and allowed handcuffs to be placed on his wrists behind his back. Once the handcuffs were locked behind Stull's back, one of the two American Response Paramedics, either defendant Beuter or defendant Johnson injected Stull in first one then the a drug designed to act as a chemical restraint. other upper arm Defendant Beutler and defendant American Medical response had an ongoing practice of first refusing to transport individuals requesting emergency medical transportation and then drugging those individuals in an effort to effect a chemical restraint because those denied the ‘emergency medical transport became upset from being mistreated by American Medical Response. Because Stull does not have a normal neurological system, Stull did not respond to the sedative administered by defendant American Medical Response in the predicted way, which defendant Beutler observed and discovered enroute to Emanuel Hospital Emergency Department. COMPLAINT PAGE 16y how it Without regard to Stull's disability, central pain syndrome, or understandi limited Stull, defendant Beutler informed medical personnel and security staff at Emanuel Hospital Emergency Department Stull was uncooperative. (Exhibits B AMR Report and B Portland Fire Bureau Report attached.) senses in the treatment room in Emanuel Hospital Emergeney Department, and Stull came to hi ‘was informed by a nurse he had been discharged, and again was provided exit instructions with the diagnosis and description as "central pain syndrome" by the same doctor who had seen Stull there on November 20, 2015. Stull exited the defendant Legacy Emanuel Hospital Emergency Department and was shortly encountered by two Emanuel Hospital Security Guards, defendant David Griffiths Davies and defendant Mario Gochez-Chinchilla. Stull heard one say to the other that Stull had a trespass exclusion. Stull informed them how Stull had just been discharged from the Emergency Department, was leaving the hospital, was a person with a disability and was headed toward the main exit where the bus schedules were displayed. Defendant Gochez-Chinchilla blocked Stull's path down the hallway. After Stull turned and headed back toward the Emergency Department saying, "I'll just get them to call Tri Met from the Emergeney Department Desk," defendant Davies and defendant Goche-Chinchilla effected a citizen's arrest and arrested Stull for Criminal Trespass, Defendant Davies reported to the Portland Police Bureau how Stull had been arrested for trespassing at Emanuel Hospital on October 14,2011. On that date, Stull was arrested by four Emanuel Hospital Security staff who falsely claimed Stull smelled of alcohol, after Stull had exited the Emergency Department following treatment. At the time Stull invoked the ADA and COMPLAINT —PAGE 17was then arrested. Although the arrest couldn't be prosecuted by the Multnomah District Attomey, Stull’ tip to jail after exiting the hospital Stull had arrived at by ambulance was a contributing factor to Stull's return to Emanuel Hospital Emergency Department less than a day later with the extraordinary and life-threatening heart rate Stull survived on October 15,2011 Legacy Security personnel had a practice of arresting Stull for trespassing, to which Stull claimed was fraud by Legacy Security personnel in Legacy’s ongoing practice of unlawful discrimination and retaliation, and after Legacy Security arrested Stull on November 22, 2015, and while Stull was defending the charge of criminal trespass, Legacy Security destroyed the security footage which would have proven Stull’s encounter with Legacy Security defendant jinchilla was the result of an intentional and an ongoing Davies and Defendant Gochez- unlawful practice by Legacy Security. Legacy Hospital has a security policy which unlawfully discriminates against persons with disabilities in violation of the ADA and ORS 659A.142 (4). (Exhibit D Attached Legacy Health Policy # 300.06.01) Portland Police responded to the citizen arrest effected by the Legacy Security staff and based that police arrest on the statements of Legacy Security pursuant to policy without consideration of Stull’s status as a person with a disability as or after Stull was taken into custody. Portland Police Bureau handcuffs were applied and the Legacy Security handcuffs were removed and retumed to Legacy Security, and Stull was transported in handeuffs by Portland Police to the Multnomah County Detention Center (MCDC). Emanuel Hospital did not preserve the security video of Stull's arrest. (Exhibit E attached) COMPLAINT ~ PAGE 18Stull was interviewed and e! and sat and watched the clock until Stull realized the last bus to Stull’s house had passed through downtown Portland scheduled for 1:55 AM. Stull was released at approximately 3AM into the 39 degree F weather when no public transit was operating. At the time Stull was drugged into an unconscious state outside Stull's home hours earlier, Stull was wearing only sneakers, socks, ‘gym shorts .and a tee shirt, and was wearing that same light clothing when Stull was released into the cold weather from Multnomah County Detention Center. Stull was issued @ citation to appear in court on Tuesday November 24, 2015. On the morning of Tuesday November 24, 2015, while Stull was leaving home for court, Stull observed a white sedan bearing a decal on the door identifying it as Multmonah County Health Department Medical Transport, which arrived to transport Stull's neighbor. Stull advised the female driver how there had been an event the prior Sunday evening which may have been a triggering event for her client because of the police, fire and ambulance response and Stull yelling when they interfered with and refused the medical transportation Stull had requested and which was dispatched. Stull asked the driver to relay that that event may have been a triggering event to the medical staff treating her client; she told Stull she'd get them that message and thanked Stull. November 24, 2015, Stull was aware of his continuing fragile medical condition might cause Stull to become disorganized or unable to vocalize and prepared by bringing a 18" x 24" combination cork board and white board to help Stull organize court papers. The front side of the small, wooden framed bulletin board was divided into a white board and a corkboard for accepting thumbtacks, Stull knew going to court would likely involve handling paperwork Stull ion caused disorganization. Stull had prepared and would need to manage at a time his condi COMPLAINT ~ PAGE 19pinned to the corkboard a card with identifying information and a request to telephone 911 for transport to Emanuel Hospital Emergency Department. Stull exited the Stark Firs Mobile Park complex and left the sidewalk northbound to eross SE Stark Street in the crosswalk formed where the sidewalk of SE 109th Avenue ends on the north side of SE Stark Street. Although westbound traffic was several blocks east when Stull the five lanes with a speed limit posted as 35 m.p.h., westbound traffic far in started to eros stark Street excess of that speed refused to yield or even slow for Stull to complete crossing § Although some drivers yielded for Stull others didn't, and Stull was stranded. Stull found himself writing down the license plate and description of a car as the driver of that car was pressing the front bumper against Stull's legs while the driver was still talking on his cell phone. Stull could see the driver through the windshield was a black male and noted the car was black, possibly a BMW, and was licensed in Washington. Stull wrote "081 FKB" in marker on the back of an 18" x 24" bulletin board Stull carried in case Stull’s central pain condition prevented Stull from vocalizing. In the seconds it took Stull to jot down the license plate, Stull heard a man on the sidewalk on the north side of SE Stark Street say into his cell phone, "There's a homeless man out in traffic and it isn't a crosswalk." Stull noted as that man locked up a ear parked in the lot of Gateway Sports Medicine how that car also bore a Washington license plate, and while still talking on his telephone as he entered the building then turned and told Stull, "They told me I ‘was the third call they got about you.” Stull did not want to leave the scene if police were being dispatched. Stull faced the \dictment predicament of a felony warrant for Stull's arrest being issued for failure to appear for imofa on a misdemeanor or leaving the scene and thereby validating the bogus cla COMPLAINT —PAGE 20Washingtonian who was both unware Stull was in a crosswalk as defined by Oregon law, that Oregon has a mandate drivers yield to pedestrians even waiting to cross a crosswalk and that Stull was already in a crosswalk leaving Stull's home where Stull had resided for years. Stull awaited a police response to the scene and watched as first the Tri Met #20 bus Stull crossed SE Stark Street to catch to downtown Portland to go to court passed and a second #20 Stull decided at that point no police were going to respond to those cell phone calls reporting Stull, and Stull boarded what was for Stull the third #20 bus. Shortly after boarding at SE 106th and SE Stark Street as Stull had, a female passenger began vocalizing about Stull and the trailer court where Stull lived being populated by thieves. Stull informed the driver that Stull's Honored Citizen ID Stull presented was for a neurological condition and wanted the driver to address that passenger's abuse of Stull, The driver remained mute. ‘As Stull was preparing to disembark at West Burnside near NW Sth Avenue, the woman who had boarded at the same stop as Stull started screaming about Stull again, tried to wrestle and then kicked Stull, stating, "He's Stull’ bulletin board by grabbing and tugging on i crazy. He says the police are trying to kill him." Stull told the bus driver to call the police. ‘Three Transit Police personnel were dispatched, Stull explained the facts and Stull obtained their business cards identifying them as assigned to the Portland Police Bureau. Stull asked the Hillsboro Police Officer to hand a slip of paper with Stull's name and email address written on it to a woman Stull had seen was particularly shocked while witnessing the unprovoked attack on Stull. ‘The officer asked the woman, "Do you know him?" referencing Stull, and when the woman nodded no, didn't give her COMPLAINT PAGE 21the paper from Stull, Stull observed how the other bus passengers were shocked by how the responding police acted as if Stull was the problem after that audience of bus passengers had witnessed the woman's unprovoked attack on Stull. Stull exited the bus to get to court No police report was taken by defendant West Helfritch and the security audio and video recording were destroyed by Tri Met implementing its policy and practice of only securing video footage on request of law enforcement. Portland Police Bureau continued their practice of not investigating crimes when Stull was the vietim, and not securing security video containing evidence Stull was a crime victim, Although Stull was the victim of an unprovoked attack on camera on Tri Met Bus #20 November 24, 2015, in full view of witnesses, and the police responded, the Multnomah County District Attorney refused to prosecute the case where Stull was a crime victim, while simultaneously prosecuting Stull Stull was still concemed with a felony warrant being issued if Stull failed to appear in court and the unresolved matter of the calls made to police regarding Stull crossing SE Stark Street earlier that morning. A block or two after exiting the #20 bus, Stull asked a stranger for the favor of calling 911, letting them know Stull intended to walk south on SW Sth Avenue to SW Madison Street, where Stull planned to walk east to the Justice Center and to go to court, Stull wanted to clear up any confusion generated by the various incidents, gave the prepared card to that fellow who made the 911 call as Stull asked, and Stull made way to court Stull entered the SW 3rd Avenue entrance of 1120 SW 3rd Avenue where Stull placed his items on the conveyor rollers for the security screening and began taking off wraps. When the Facilities Security Officer (FSO) didn't screen the items, Stull reported being late for court, being experienced in preparing for security, and informed the FSO Stull would be finished COMPLAINT ~PAGE 22SO start processing Stull's property. Stull finished before before the FSO was and requested the the FSO began, walked through the metal detector without a hitch, and from the other side of the metal detector said, "You keep it," and bounded up the steps. Stull was chased by a second FSO as Stull heard the one operating the screening equipment lie, "He just threw his stuff down here and left it.” Stull retrieved the goods, which had all cleared security, and the second FSO began grabbing and pushing Stull towards the door. Within seconds Stull had neutralized the physical attack, faced about six Multnomah County Sheriff Corrections Deputies, identified one of them as one Stull recognized from 2012, whereupon Stull and Corrections Deputy Regehr de-escalated the entire situation with Stull saying it would be best if they all just let Stull get up, walk out the door and go the the federal courthouse next door. Stull pointed out that had he pushed over the FSO standing by Stull whose foot Stull was sitting on, it would have broken his ankle, and he didn't even know Stull was sitting on it, Stull lefi, went next door to the Mark Hatield Courthouse, and after that to Portland City Hall. Stull entered City Hall and the Office of Neighborhood Involvement, which contains, among other offices, an information and referral office for both Multnomah County and City of Portland. Stull asked at the desk where Stull knew they answer the telephones with "City County Information" to the number Stull knows is on the sides of both City of Portland and Multnomah County vehicles, 503-823-4000. On many occasions over years, Stull has walked into the office for information about city and county staff or bureaus, and that information has always been provided without complication. (On Tuesday, November 24, 2015, Stull went to the counter and said to the woman on duty, "I need a Multnomah County Health Department Medical Transport ride to my home, just COMPLAINT ~PAGE 23like | saw my neighbor get this morning." The staffer replied to Stull, "We don't provide ride service here," and Stull repeated he sought information on how to get Multnomah County Health Department Medical Transport, a service Stull saw his neighbor get that same morning, to give Stull a ride to Stull's home because Stull is a person with a disability. The staffer told Stull, "You're going to have to make that call yourself,” and handed Stull a courtesy telephone. Stull called 503-823-4000 and the telephone was answered by the same woman across the counter who handed Stull the phone, and Stull asked to be transferred to Marco Circosta. Marco Circosta, as aide to Multnomah County Chair Deborah Kafoury, knew Stull for s such as Stull being a Veteran Survey Volunteer for A Stull's advocacy and participation activiti Home For Every Veteran, a project of A Home For Everyone, and for Stull's ongoing complaint PCRI was keeping the entire Kafoury Court five-apartment affordable housing property vacant while partnering with and being funded by the City of Portland during a housing crisis. Stull. told Marco Circosta how Stull wanted a Multnomah County Health Department Medical Transport ride from Portland City Hall, where Stull was, to Stull’s home, asked if Marco could help with that and rang off. Stull noticed defendant G4S employee defendant James Wood completely change in demeanor. Wood's complexion changed and Stull could see Woods was seething. Upon leaving the Office of Neighborhood Involvement accompanying Stull, James Wood began to tell Stull how Wood was imposing a twenty-four hour notice of trespass exclusion, to which Stull replied to Wood that what Wood was telling Stull wasn't legal, a point Stull knew from being repeatedly found not guilty of charges Stull knew were without legal foundation from the start. COMPLAINT ~PAGE 24Stull went upstairs to exit City Hall onto SW Sth Avenue. and stopped by Commi joner Amanda Pritz's Office and asked the receptionist Jasmine Wadsworth for a lollipop. as an opposite to James Wood and his hostility, and in thanking her as she refilled her candy dish, reminded her of how Stull’s father framed a photograph of Stull with one of her lollipops Wadsworth had given Stull, Stull left City Hall after a brief discussion with the security staff, where Stull asserted the trespass exclusion issued by Woods when Stull was already on the agenda the next day was illegal and Stull had no intentions of obeying an illegal warning, Defendant Woods and other defendant unidentified G4S personnel sought to prevent Stull from continuing to expose misdeeds of City agents and employees of the City of Portland through public testimony at City Hall, and gathered information on Stull's activities and distorted that information on Stull’s activities to further the effort to silence Stull. Defendant G4$ personnel knew Stull bad specifically requested information regarding Multnomah Health Department Medical Transportation at the time defendant Bryant Enge promulgated the December 1, 2015 notice of exclusion based on Stull asking for the City to provide a ride home, repeated that conflation regarding Stull’s interaction with Jasmine Wadsworth as Stull exited, rather than lingered, and claimed Stull would not follow a lawful exclusion when Stull accurately identified the City policy was illegal At the time Stull told the G4S staff their efforts against Stull were illegal, Stull was scheduled on the agenda for each of the two following Wednesday City Council Meetings, including the subject "Portland's Criminal Partners" on December 1, 2015. Stull had signed up November 16, 2015 to be on the November 25, 2015 City Council Meeting agenda for a three minute "Communication" under the topic of the free music zone in Waterfront Park, which the City, including Charlie Hales and Gretchen Kafoury, promised in COMPLAINT -PAGE 251994 but didn't deliver. In conjunction with Stull’s Communication, Stull included a copy of a news photograph of Multnomah County Chair Deborah Kafoury presenting an award to PCRI, at a time PCRI was still keeping five affordable housing apartments vacant at Kafoury Court, which had been named in honor of Gretchen Kafouty. Stull had repeatedly testified over many years about how PCRI was keeping Kafoury Court vacant and how PCRI destroyed Stull’s musical instruments and other goods in two episodes in 2006 as Stull appealed a no-cause mn from one of those five Kafoury Court apartments. In preparation for the November 25, 2015 Communication, Stull had repaired a guitar which Stull had stored on request ofa young man experiencing homelessness, and had composed the lyrics Stull planned to sing. Stull intended the lyrics to be legal, and was assured those lyrics ‘were within the limits of expression protected by the Oregon Constitution. Stull checked his lyrics with an attorney in a private conversation on Monday November 23, 2016, after Stull was passing through and met that attorney outside a public hearing in City Hall the attorney was attending, Stull's statements and aets were toward Stull's intent not to do anything illegal, but defendant G48 and defendant Bryant Enge instead characterized Stull's acts to the contrary in an ongoing effort to silence Stull, with Enge claiming how on November 23, 2015 Stull "stated in hearing of City staff {Stull} desired to get arrested at City Hall." (Exhibit F Notice of Exclusion from City Property attached) When Stull entered the Council Chambers in City Hall prior to the hearing on Wednesday November 25, 2015, Stull could tell from the frantic manner James Wood quickly began entering into his cell phone how Wood and other City Hall security staff had decided to enforce what Stull knew and had told them the day before was an illegal policy. COMPLAINT PAGE 26Stull recognized that Wood must have concocted some bogus scheme against Stull's interest, and sensitive to the additional emotional stress. informed City staff how Stull had central pain syndrome, could die from it, and Stull needed emergeney medical transportation to Emanuel Hospital Emergency Department. An ambulance was summoned on Stull's behalf, and dispatched to Portland City Hall, but Stull was denied access to that emergency medical treatment and transport Although Stull had identified himself'as a person with a disability, and specifically further clarified Stull's disability as "central pain syndrome” and it could be fatal to Stull, Portland Police Bureau Sergeant Roger S. Axthelm lied to Stull about an ambulance being available for Stull. Stull had ridden enough gurneys out of buildings into ambulances to know the paramedics announce the ambulance arrived by reaching the person needing treatment. Sergeant Axthelm shoved Stull in the chest. Stull reasonably and accurately predicted another episode of Portland Police interfering with Stull obtaining medical treatment while uultaneously exacerbating Stull's condition and the need for emergency medical treatment, through excessive force, after which medical treatment would be denied, Defendant Portland Police Officer ‘Todd Engstrom approached as if preparing for grabbing for Stull, although no one told said to Stull they wanted to arrest Stull, and defendant Engstrom said to Stull, "When you get out of jail you're going to be arrested for assault on a police officer," as he reached out and grabbed Stull’s hand, Over decades, Stull has endured inappropriate treatment and excessive force in custody and has nerve damage in both hands from the repeated application of handcuffs and damage caused by Portland Police Bureau personnel carrying Stull by the elbows face down while the handeuffs and wrists serve as "links in the chain", or by putting handcuffs on too tight. Stull COMPLAINT ~PAGE 27also bears scars. pain, and other evidences of in-custody abuse, and is wary of having fingers bent if only for being a composer and musician, Stull interpreted Officer Engstrom’s knowing placement of his Tazer so it blocked the mandatory display of Engstrom’s name tag as intentionally intimidating and Engstrom's shaved head was indicative that Engstrom was prone to use excessive force and used excessive force with impunity, and Stull interpreted Engstrom's grabbing Stull's hand after telling Stull Stull would be arrested again upon release as an illegal attack on Stull's protected interests and pulled away from Engstrom, which resulted in a scuffle and Stull's arrest. Stull advised Portland Police Officer Singh of Stull's having neuropathy from handcuts, which informed the placement of handcuffs on Stull, but once Stull effected passive resistance, Portland Police Officer Todd Engstrom applied pain compliance through a wrist lock on Stull's right wrist to such an excessive extent Stull continues to experience pain. Defendant Engstrom did not give Stull any verbal instructions or commands and instead used only the wrist lock which defendant Engstrom applied arbitrarily in Engstrom’s practice of applying a wrist lock to his prisoner to direct the route of travel Engstrom intended but did not otherwise communicate all the time defendant Engstrom and defendant Price escorted Stull from the Council Chambers on the second floor of City Hall out of the room, into then out of the elevator and out of the building to the patrol car parked on SW 4th Avenue. Stull was not given medical attention nor examined by paramedics present and who had arrived on the scene at Stull's request, although another individual who had been arrested contemporaneous to Stull was taken to the paramedies for examination, PPB Sergeant Axthelm emptied Stull's pockets as Stull was handcuffed and partially in the police vehicle parked on SW 4th Avenue in front of City Hall. Because of Stull’s practice of COMPLAINT PAGE 28guarding against disorganization caused by dysesthesia by keeping lanyards run through belt loops to hold keys and Tri Met information, on November 25, 2015, Sgt. Axthelm removed two lanyards from Stull's clothing; one, containing Stull’s Tri Met Honored Citizen ID and November 2015 pass, was returned to Stull upon Stull’s release from MCDC on February 9, 2015; the second, containing keys to Stull’s front door, back door and mail box, and a flash data storage drive containing Stull's intellectual property and legal research, was removed and never returned to Stull nor logged on any Portland Police Bureau Property Receipt. As Stull was transferred from PPB Officer Engstrom's custody to Multnomah County Sheriff Corrections staff in Multnomah County Detention Center (MCDC), staff observed and commented on the damage caused to Stull's wrists when Engstrom and Portland Police Sergeant Jeremy D. Price transported Stull. Multnomah County Sheriff Office personnel in MCDC have a practice of not documenting the damage to prisoner wrists observed when prisoners enter MCDC custody from Portland Police Bureau custody. Both the Criminalist and Corrections Deputy on duty upon Stull's entry into MCDC November 25, 2015 discovered how Stull's birthdate, height, and weight provided by defendant PPB Officer Engstrom were not Stull’s. PPB Officer Engstrom provided instead the birthdate of August 13, 1962, which was one assigned to Stull in 2009 after PPB Officer Stegemeyer created aka "Barry Joe Stully" as Stull pursued justice for PCRI's criminal acts in 2006. Stull wa clearly neither as tall nor weighed as much as the police claimed. Since telephones in MCDC operate using a prisoner's birthdate, assigning Stull the wrong birthdate upon booking was akin to denying Stull access to telephone calls. On November 25, 2015, although Stull was visibly injured in custody as observed by staff upon arrival into MCDC, PPB Ofc. Engstrom wrote in his report to the United States COMPLAINT —PAGE 29Department of Justice how neither Stull nor Engstrom were injured. PPB Of. Engstrom subsequently appeared before the Multnomah County Grand Jury and testified how he had been “intentionally injured" by Stull. Stull's property seized by the Portland Police on November 25, 2015, included a backpack containing Stull’s wallet of over 30 years and its contents, Stull’s identification, personal documents, and various means of obtaining access to resources provided Stull by various government agencies, including account cards. Stull's keys, and with them Stull's data storage drive, which were seized by defendant Axthelm and not returned to Stull, were not recorded or documented, and Stull was not provided areceipt. Among the keys seized by defendant Axthelm on November 25, 2015, were Stull's means to access Stull's housing which is funded by a Housing and Urban Development grant because Stull is a person with a disability, and Stull was denied the use and enjoyment of that property. Stull’s personal property was destroyed by Portland Police Bureau Personnel on February 4, 2016, Stull was never delivered a copy of the notice warning Stull's property would be destroyed prior to its destruction by Portland Police Bureau staff on February 4, 2016, although the yellow copy with that notice including language "this is your only notice" was presented to Stull upon release fom MCDC on February 9, 2016. Stull’s goods as listed in PPB Ofe. Engstrom's property report #A000086 were destroyed without prior notice to Stull on February 4, 2016, while Stull was held in custody on a felony indictment produced by PPB Ofe. Engstrom’s perjured testimony although the deputy district attorney realized the felony charge couldn't be successfully prosecuted as a felony a month earlier. COMPLAINT ~PAGE 30Stull possessed identification and documentation of Stull! medical condition at the time police arrived at Portland City Hall November 25. 2015 with their unfounded notion Stull was a “transient” and their conflation Stull's neurological condition, central pain, is some form of mental illness. Portland Police perpetuate their rumors to Stull's damage in the After Action Report promulgated on November 25, 2015, which states both "known history of mental illness by responding officers" and no "medical needed,” where Stull specifically requested medical treatment for central pain syndrome prior to the misguided actions of the Portland Police Bureau which first worsened Stull’s medical condition by interfering with medical treatment, and then were used as justification to deny medical treatment after, even though Stull carried medical records, had been treated at the emergency department twice within the previous week and paramedics were available on the scene with an ambulance parked on SW 4th Avenue directly behind the patrol car Stull was placed in instead. From November 25, 2015 through release on February 9, 2016, Stull was never given any form of medical treatment for Stull’s well-documented central neuropathic pain syndrome while in custody of the Mutinomah County Sheriff in MCDC. Sometime in the more than 24 hours of November 25 and 26, 2015 while Stull was kept in an isolation cell, Multnomah County Corrections Health did give Stull a drink of Gatorade to prevent Stull's death from potasium depletion caused by the over-firing of Stull's nervous system staff witnessed. Stull was denied access to a telephone following arrest and booking into MCDC at approximately 9:30 am Wednesday November 25, 2015, until approximately 9:30 pm November 27, 2015. COMPLAINT PAGE 31On December 8, 2015, Jane Fox, an attorney appointed to represent Stull informed Stull that staff at the law firm were told when they called MCDC that Stull wasn't allowed to accept attorney calls, Stull learned MCDC staff also told Kasia Rutldge, another attorney appointed to represent Stull, that Stull could neither have attorney visits and could not accept attorney telephone calls. February 5, 2016, MCDC staff refused to accept a Cashier's Check delivered to pay Stull’ bi Defendant State of Oregon, via defendant Multnomah County District Auomey and Multnomah County Circuit Court Case 15CR52961, prosecuted Stull for events on November 23, 2015, in 2016. At trial before Multnomah County Circuit Court Judge Julie E. Franz, Stull sought to argue that Emanuel Hospital's 2011 exclusion order and 2015 trespass order based on it were unlawful because they violated the ADA and ORS 659A.142, the applicable public~ accommodation and disability laws. ‘The trial court barred Stull from arguing the lawfulness of the 2011 order and Stull’s evidence to support it, including Stull's medical records for having been treated for central pain syndrome at Emanuel Hospital Emergency Department on November 20, 2015 and November 22, 2015. Stull was convicted of criminal trespass based on violating the 2011 exclusion order Stull exited Emanuel Hospital Emergency Department. Stull appealed to the Oregon Court of Appeals in CA A164155, and the court affirmed the trial court without a written opinion. The Oregon Supreme Court denied Stull’ Petition for Review. COMPLAINT PAGE 32Defendant State of Oregon. via defendant Multnomah County District Attorney and Multnomah County Circuit Court Case 15CRS3749, prosecuted Stull for events on November 25, 2015. in 2016. Stull appealed to the Oregon Court of Appeals, On June 14, 2018 Stull had an accident while bicycling. Months later, Stull made arrangements for a companion to accompany Stull to the Emanuel Hospital Emergency Department because Stull's ankle injury and an emotionally stressful event triggered Stull's central pain syndrome into a flare. The early hours of November 6, 2018, Stull was examined, x- rays were taken, and Stull was advised the options were surgery or time to allow the injury to heal. Stull was informed the injury was serious enough to warrant the medical diagnosis and Stull's decision to visit the Emergency Department was appropriate. Stull's companion noted the treatment room Stull had been sent to was not a normal room. Instead of Stull being escorted to an x-ray machine, as Stull had experienced on previous visits to Emanuel Hospital Emergency Department, an x-ray machine was wheeled into the room. Following Stull's examination and diagnosis, Stull and companion exited Emanuel Hospital Emergency Department, and defendant Davies followed a few steps behind, and although Stull's companion was still in the process of unlocking the bicycle parked where Security said to park it, defendant Davies took out a pair of handcuffs and brandished them toward Stull, Stull ran and left the property. ‘Stull walked and boarded a Tri Met #20 bus home from a stop on W. Bumside Street in Downtown Portland. Stull presented Honored Citizen ID and paid the fare. ‘The bus driver began to berate Stull, and said to no one in particular the obsolete Tri Met patches Stull had on COMPLAINT - PAGE 33were illegal. Stull's jacket also displayed a patch from Standard TV and Appliance, Stull knew the patches were purchased by Stull’s friend who discovered them for sale in a thrift store and gave them to Stull. Stull explained that the patches were not illegal and Stull just wanted to ride the bus home without hearing the driver say Stull was doing something wrong but the driver insisted on continuing to berate Stull and Stull got off the bus at SE 12th Avenue. Approximately 5:04 AM November 6, 2018, Stull telephoned 911, reported Stull was sickened and requested an ambulance for return to Emanuel Hospital Emergency Department No ambulance was dispatched to where Stull waited at SE 12th Avenue and E. Burnside. Stull got on the next #20 bus an hour later, and after presenting the same Honored Citizen ID and transfer, and wearing the same obsolete ‘Tri Met patches, rode home without incident. ‘The afternoon of November 6, 2018, Stull went to the Portland Police Bureau East Presinct to follow up on the matter of an ambulance not being dispatched for Stull which Stull wanted to clear up by reporting that Stull had made it home safe. Staffon duty told Stull that Stull didn’t know what Stull was talking about and closed the blinds to the service window. November 9, 2018, Stull purchased an Honored Citizin fare with an expiration time of 7:44 PM. Stull boarded a Tri Met #12 bus in Downtown Portland and got off at the east end of Burnside where Stull intended to the Burnside Bridge. Stull walked east on the sidewalk of Ei catch a #20 bus home, As Stull walked east on the sidewalk on the south side of E. Burnside Street Stull was approached by a man so intoxicated he almost fell down then advanced on Stull in an attack so serious Stull fled into a nearby business where that stranger followed Stull and left when an COMPLAINT ~PAGE 34employee yelled at him. Stull obtained a business card from the employee who wrote his name Dylan" on it, Stull left the store. Stull boarded a Tri Met #20 bus; bus 3620. Stull had endured an attack earlier that afternoon, by a stranger in Pioneer Courthouse Square, and having just been attacked a second time, Stull asked for an Honored Citizen seat rather than endure the social and physical contact necessary to get to the back of the bus where there was an empty seat Stull said there was plenty of room in the back of the bus. ‘A man standing as he rode on the bus stated that Stull didn't look like Stull needed an Honored Citizen seat, and Stull engaged in banter as Stull sorted through paperwork, then produced Stull's Honored Citizen ID. ‘A man Stull didn’t know then swiftly walked up to where Stull was seated, positioned himself in front of Stull, and grabbed the overhead strap in a manner so he was facing Stull rather than the front of the bus as most riders do, and bent over to Stull and said, "I don't want to hear any more about your Honored Citizen status." He then said to Stull, in a tone Stull took serious and as a threat, "I'm getting off at your stop!” Stull was concerned that stranger, a man who was clearly not in his right mind, had a knife, and had no reason to even interact with Stull but was standing up in front of Stull’s seat, blocking Stull Stull knew that stranger's language was specifically addressed to Stull’s status as a person with a disability and his threat was a crime, so Stull effected a citizen's arrest of defendant Kyle Dean Sheppard. COMPLAINT PAGE 35Defendant Tri Met bus driver. defendant Joseph James Witt, took no action to investigate ull held Sheppard awaiting the nature of the matter or communicate with Stull in any way the police to take Sheppard into custody. Defendant Witt, according to defendant Portland Police Bureau Officer Daniel D. Nipper #57091, “had the passengers exit," when in fact Witt gave no directions to any passengers, made no announcements, and remained seated in his seat until Officer Nipper boarded. The passengers were told to get off the bus by a female passenger, who said the police arrived and the police said for everyone to get off the bus prior to the police arriving on the scene, ‘A second time, as Officer Nipper was present, that female passenger told the remaining passengers to exit the bus, although they were the best available witnesses to the acts as they occurred to Stull rather than viewed by other passengers farther away; including placing her hand on the woman seated next to Stull when Sheppard came up to where she was seated next to Stull in the Priority Seating Area. Defendant PPB Officer Nipper made no effort to investigate the matter prior to placing, Stull in handcuffs and separating Stull from Stull’s witnesses. Defendant Tigard Police Officer Gabriel M. Maldonado #47256, assigned to Portland Police Bureau Transit Division, while transporting Stull from the bus to Multnomah County Detention Center, told Stull of the various forms of punishment he was setting out for Stull, including a probation hold, a transit exclusion, and criminal charges. Stull responded Stull ‘would win in court, as Stull was about to win in the Oregon Court of Appeals “after punching a cop in Portland City Hall.” COMPLAINT PAGE 36Defendant Maldonado parked the patrol car on SW 3rd Avenue, outside the entrance to Portland Police Central Precinet. Stull told Defendant Maldonado it wasn't a good idea to keep Stull Jong in the police car since Stull’s central pain syndrome had been triggered, Stull scar in informed Defendant Maldonado Stull had done over $500 damage to Officer Pa five minutes in 2012. Defendant Maldonado opened the back door of his patrol car, grabbed Stull’s feet, and pulled Stull out until the seat belt caught around Stull's neck and kept pulling as Stull exclaimed. Defendant Maldonado then pushed Stull back until the seatbelt cleared from under Stull's chin where it had choked Stull, then pulled Stull back out saying, "Get on the ground," which Stull thought meant to stand on the pavement since defendant Maldonado still had Stull’s feet in his hands, Defendant Maldonado then threw Stull down to the sidewalk and jumped on Stull's b right shoulder which Stull landed on. wrists, and especially Stull!’ causing injuries to Stull’s bac! while handcuffed behind the back. Those in-custody injuries were so obvious and so serious photographs were taken by defendant Clackamas County Sheriff Sergeant Robert Stewart #52271, at a time defendant Sgt. ined. Stewart knew Stull had done nothing to merit the response experienced nor injuries Defendant Stewart and defendant Maldonado then concocted a cover-up, and defendant Stewart said there were no photographs of Stull’s shoulder although photographs were taken on November 9, 2018 along with the other photographs of Stull's injuries. Defendant Multnomah County Sheriff Mike Reese kept Stull in custody in the same cell, 4 F14 from November 10, 2018 through November 29, 2018, until Stull's visible wounds: healed. COMPLAINT ~PAGE 37November 19, 2018. Stull refused to participate in a Misconduct Hearing (Report #34696) because Stull was too ill with central pain syndrome. Stull disability Stull had reported to staff'and which Stull knew was documented in Multnomah County Corrections Health chart Stull was notes Stull viewed in 2016. Stull could not appeal the adverse decision becaus locked in cell 4 F 14 and could not access forms to appeal or file a Grievence about not being let out for walk time, On November 20, 2018, Stull was housed in custody of defendant Multnomah County Stull had been continuously since the early hours of Sheriff Mike Reese in MCDC cell 4 F 14, a November 10, 2018. Corrections Deputies had turned off Stull’s drinking water, refused to facilitate toilet flushing, and fed Stull sack lunches without the milk which others in MCDC Unit AF received routinely. Although Stull's disciplinary status afforded Stull walk time out of the cell to take showers, obtain inmate communication forms, and make telephone calls, Stull was not allowed out of cell 4 F 14 from November 10, 2018 to November 29, 2018, On November 20, 2018, Multnomah County Sheriff Sergeant Roldan entered Unit 4 F and rectified the situation of there being no water to Stull's sink and toilet and provided Stull with hygienic soap and toilet paper Stull did not have. Sergeant Roldan opened the port to cell 4 F 14 so Stull could pass through what had been a lunch bag Stull improvised to contain Stull's feces because staff would not afford Stull a toilet flush for days. Stull received a receipt from Corrections Deputy MeDonald for "feces stored in cell.” COMPLAINT PAGE 38Stull could not flush the toilet in cell 4 F 14 because it had either been shut off intentionally or because staft lacked the training, sophistication, and interest in operating the plumbing controls, which resulted in Stull not having water to drink, bathe with, or flush the toilet. On November 21, 2018, Stull was issued a Misconduct Issuance (Report ID #34733) claiming Stull said sexually explicit things to a female inmate who was on the telephone, when Stull had not. Any investigation would have exposed her telephone conversation at the time and her unanchored flights of fancy in her scheme to use her accusation against Stull to get transferred out of Unit 4 F November 26, 2018, defendant Hearings Officer De Armond-Reid completed a Misconduct Hearing Report wherein he falsely reported Stull as saying, "I have kyted the facility Commander,” when Stull instead reported having been locked in the cell continuously without an opportunity to communicate with anyone. Stull was intentionally kept in ecll 4 F 14 continuously from November 10, 2018 through November 29, 2018, and was subjected to torture, denied medical treatment for central pain syndrome, prevented from communicating by mail or telephone, was not transported fo court, or contacted by Multnomah County Community Corrections regarding Stull’s probation which otherwise expired November 16, 2018, completing the sentence imposed by Multnomah County Circuit Court Case 15CR53749. All convictions in Case 15CRS3749 were reversed by the Oregon Court of Appeals on April 24, 2019, based on the brief on file with the court since January 2018. COMPLAINT ~PAGE 39April 1. 2019. Stull used a sledge hammer to enter three of five vacant PCRI Kafoury Court Apartments located at 4066 NE Grand Avenue, Portland, which were vacant although they were listed on the Oregon Housing and Community Services inventory of affordable housing as five "family apartments,” and after the City of Portland declared then renewed a Housing State of Emergency. The City of Portland had funded PCRI while Kafoury Court was vacant and at the time Stull entered the vacant apartments the City of Portland was partnering with PCRI Multnomah County Circuit Court Case 19CR21313 was issued in April 2019 but never brought to the trail after Stull informed the Multnomah County District Attorney Stull intended to use a choice of evils defer In January 2020, Stull filed motions to dismiss the Multnomah County Cases 15CR53749 and 18CR75140 because they violated the ADA and ORS 659A.142 because the prosecution of those cases aided those who had violated Stull's civil rights as a person with a disability. Stull's motions were denied after a hearing. May 22, 2020, Stull was arrested by Portland Police Bureau personnel and Stulls keys ‘were taken and not retumed. Stull was booked into MCDC and released on May 26, 2020, after Multnomah County Cireuit Court Case 20CR28449, for Disorderly Conduct was a "no complaint.” While in MCDC, Stull endured the experience of having a Corrections Deputy stand with his foot on Stull's neck after Stull was taken to the cell floor by two Corrections Deputies, May 26, 2020, Stull walked to defendant Adventist Health Portland (Adventist Hospital) Emergency Department experiencing a flare of central pain syndrome triggered by the physical abuse in MCDC. Stull was booked in as a patient, and related to staff'a previous experience of having a central pain flare which resulted in the doctor telling Stull that doctor had never heard COMPLAINT ~PAGE 40of central pain syndrome, Stull told staff he'd give them some time to access Stull's medic records and would return shortly. Stull left his paperwork with the Adventist Hospital Emergency Department staff. As Stull returned and approached the building, Stull encountered three Adventist Hospital id to the others he knew Stull from defendant Emanuel Security Guards, and one of the three Hospital. The three Security Guards approached Stull and said Stull had to leave the property, and over Stull's objections, walked Stull to the public sidewalk on SE Main Street The third time Stull went to the Adventist Hospital Emergency Department May 26, 2020, where Stull's paperwork still was and where Stull had been admitted as a patient, the three defendant Adventist Hospital Security Guards again approached Stull in the lobby of the Emergency Department, and one of them issued Stull a Trespass Exclusion Notice. Stull said to the Security Guards that Stull was already registered as a patient. ‘The three Security Guards stayed close as Stull was again registering as a patient in the Adventist Hospital Emergency Department when Stull told the three Security Guards to leave Stull alone. They did not, but all three instead continued to crowd Stull, further worsening Stull’s central pain syndrome. Afier Stull cla jed matters at the triage window and was again admitted to defendant Adventist Hospital Emergency Department as a patient, Stull asked defendant Mario Lara, "Can Ipunch you in the nose now?" Defendant Lara answered, "Yes," and Stull did, with three quick jabs since Lara was so close, which stunned Lara and gave Lara a bloody nose. COMPLAINT-PAGE 41The three Security Guards then did a take down and when Stull was on the floor of the lobby of the Adventist Hospital Emergency Department. Stull was handcuffed in front of the doctor. Stull was taken outside, and defendant Portland Police Officer Scherise Hobbs #30864 and defendant Portland Police Officer Thomas Clark #50706 responded to the scene as dispatched. ‘The Security Guards explained to defendant Hobbs and defendant Clark how Stull had first asked defendant Lara if he could punch him in the nose, and after Lara said "Yes," Stull did. Defendant Hobbs replied, with defendant Clark present, that since Stull had first asked Lara and gotten permission, what Stull did wasn't illegal. Although Stull was registered as an Adventist Hospital patient and had not yet received emergency medical treatment for central pain syndrome, Stull was taken into custody by defendant Clark and booked into Multnomah County Detention Center, where Stull did not receive medical treatment for Stull's central pain syndrome. Defendant Hobbs produced Portland Police Bureau Report #20-173507, which included how Stull had asked Lara permission to punch Lara in the face, but which failed to include that Lara had given Stull verbal consent by answering "Yes." According to defendant Hobbs’ report, defendant Lara said Stull had been checked in as a patient at the time Stull left Adventist Hospital then returned, and how "The first time was between 1600-1700 hours. During that time Stull got checked in and wanted an x-ray and to be able to leave with that x-ray in hand.” Defendant Lara's statement regarding Stull's reason to seek treatment at Adventist Hospital Emergency Department was not true, and even if true could COMPLAINT -PAGE 42not be shared without defendant Adventist Hospital violating Stull's rights as protected by the Health Insurance Portability and Accountability Act of 1996 (HIPAA). According to defendant Hobbs’ report. defendant Lara said Stull had been issued a sion notice on Stull’s return to Adventist Hospital Emergency Department, Stull's second visit, although in fact, Stull was walked to the sidewalk by the three Security Guards who prevented Stull from access to Adventist Hospital, and once Stull returned the third time, they presented Stull with a trespass exclusion notice in the lobby of Adventist Hospital Emergency Department. May 27, 2020, Multnomah County District Attorney, acting through Deputy District Attorney Nelson, OSB #161463 filed an information to initiate Multnomah County Cireuit Court Case 20CR28838, which charged Stull with Harrassment and Assault IV. Stull was released from MCDC on Case 20CR28838 May 27, 2020, and the Multnomah County Circuit Court Release Order and Agreement listed Stull's address as 650 NW Irving, Street Portland Oregon 97209, which is Transition Projects Bud Clark Commons, although Stull has resided at 10852 SE Stark Street Unit 5 Portland Oregon since 2013. Stull’s court date to appear on Case 20CR28838 was July 3, 2020. Stull was released at 8:56 PM. May 28, 2020, around noon, Stull’s neighbor called the police, and Portland Police Officer Delong #52979 was dispatched to Stull's home to conduct a welfare check. Officer Delong arrived at 12:17 PM and at 12:30 PM ordered an ambulance. Stull was taken to Adventist Hospital, drugged, and transported to Legacy Unity Center for Behavioral Health (Unity), COMPLAINT —PAGE 43Stull was discharged from Unity June 2. 2020, and Stull went home. Stull was unable to sleep due to the flare of central pain syndrome. Stull decided to produce an event in the area grassy area of Floyd Light Park over the fence at the back end of the Stark Firs Mobile Home Park where there was plenty of room for people to social distance. Stull approached a Portland Police Bureau Patrol Car parked in the parking lot of Floyd Light Middle School and spoke with Sergeant Robb about it, and Sergeant Robb told Stull he thought that was a good idea and gave Stull his business card. Stull purchased a wheelbarrow and two extension cords. When Stull discovered the extension cords weren't long enough, a neighbor loaned one. Stull used the wheelbarrow to haul musical instruments and other equipment. Stull was getting pranked by someone who would wait until Stull reached the park to unplug one of the extension cords from the other. When Stull returned and found Stull's two extension cords were missing but the neighbor's was not, Stull knew someone was intentionally tormenting and targeting Stull and Stull got to the bottom of it. As Stull subsequently paid one of several checks for the damage Stull had promised to pay for at the time, around 1:30 AM June 4, 2020, the man explained, "That Cuban stole from you and you took it out on us." Stull's neighbors knew Stull had been driven to madness and had been getting sicker and sicker and settled for Stull paying the damages. Stull still lives at the same place. June 4, 2020, Stull went to retrieve the various musical instruments and equipment from Floyd Light Park, which included a Yamaha electronic keyboard, an Epiphone mandolin in a case with a sign with Stull's name on it, a FreePlay portable PA, a 24” television, a DVD player, a small amplifier, a Silvertone banjo, an A frame chalkboard, and a DVD of Alien Boy, The Life and Death of James Chase Junior, a movie which featured Portland Police Sergeant Kyle Nice, COMPLAINT—PAGE 44who was placed on desk duty after pulling a gun during an off-duty road rage incident, but was reinstated 10 patrol and was a supervisor in Stull's neighborhood. Around 10:00AM June 4, 2020, four Portland Police Bureau Officers arrived on the scene and Stull was arrested and transported to MCDC by two of them. Enroute, the driver drove off the curb then drove over speed bumps in the Floyd Light Middle School parking lot with such intensity the backsides of Stull’ legs were bruised, as Stull had documented and photographed by medical staff at Unity. ‘None of Stull's property was secured as Prisoner Property, and instead the Portland Police Bureau left it in Floyd Light Park, where it was stolen while Stull was in custody in MCDC without access to a telephone, June 5, 2020, Stull’s Properety Manager, checking after Stull’s interests, found Stull's Yamaha electronic keyboard where Stull had left it in Floyd Light Park but the other items were gone. Stull was housed in MCDC 4 D 10 and on June 5, 2020 Stull’s water was tumed off. Stull had no hot or cold potable water, no hygienic soap, no towells and no flushable toil Stull was released on recognizance on June 5, 2020 for Case 20CR30812, but was transferred from MCDC to Unity. Unnecessary rigor was used to transport Stull from cell 4 D 10 to the garage bay for transport to Unity June 5,2020. When Stull remarked to the driver of the medical transport, "These guys are animals," the Corrections Deputy remarked, "We prefer 'savages." Stull was a Unity patient from June 5, 2020 until discharged on July 20, 2020. COMPLAINT -PAGE 45Stull was discharged from Unity with a referral to Dr. Phebe Matsen M.D... who ordered an MRI of Stull’s brain at the request of Unity physician Jordan P. Anderson D.O. to check if'a brain tumor or other disorder led to Stull’s condition, since it is rare that a man would first have an episode of bipolar mania Stull had been diagnosed as having at the age of 61. ‘The MRI Stull had August 25, 2020 was normal While Stull was in Unity the Multnomah County Circuit Court issued Case 20CR30812, which was assigned to Hershall Brown, Stull's court appointed defense lawyer on Case 20CR28838, and legal advisor on Stull's cases pending in Multnomah County Circuit Court, Defendant Multnomah County Mental Health and Addiction Services Investigator defendant Keiko Eguchi produced a Hearing Report for Multnomah County Circuit Court Case 20CC03412 which contained a number of falsehoods, including Stull had thrown rocks at cars, used racial slurs toward Unity personnel, Stull described his disease involved peripheral nerves, Stull's relationships with other Unity patients were inappropriate, and Stull was from Saxony, Pennsylvania. Stull is trom Saxonburg, Pennsylvania Defendant Eguchi wrote that when Stull explained central pain syndrome, "AMIP {Alleged Mentally Ill Person] appeared manic with psychotic features, though adamantly denied that he has any mental health conditions other than central pain, which he explained in a fashion that sounds like a somatic delusion." Defendant Eguchi did not conduct any investigation to correctly understand that central pain syndrome was Stull's well-diagnosed neurological disease. Defendant Fguchi wrote, "On June 6, 2020, returned to Unity on Director's Designee hold from jail because AMIP [Alleged Mentally Ill Person] was acutely psychotic, inability to care for self, inability to provide for basic needs due to disturbance in thought and perception, is COMPLAINT - PAGE 46grossly disoriented, cannot communicate, nonsensical speech, severe paranoid causing aggressive behaviors and ideation which is. further exacerbated by chronic methamphetamine use per Corrections Health Mental Health Consultant." (italics as in original) There is no chronic methamphetamine use,” while Multnomah County foundation for any claim of Stull's Corrections Health records include Dr. Grimm’s charts diagnosing Stul’s central pain syndrome, including a sketch mapping Stull's nerve damage. Stull was a patient of Dr. Patsy Kullberg at the Multnomah County Health Department Westside Clinic who had Dr. Grimm's medical charts, scanned into Stull's records. (Exhibits G and H attached) Defendant Eguchi wrote, "Per Corrections Health (503-312-9221) AMIP was placed on Director's Designee hold due to concern that he was unable to meet his basic needs, danger to self and others because he presents with psychotic symptoms and possible under the influence of substance causing gross disorientation and thought disturbance resulting in inability provide for his needs and inability to appropriately interpret social cues and benign events. Also, AMIP was making unspecified threatening comments. AMIP was unable to answer a single question due to constant nonsensical screaming but he appeared to be attending to internal stimuli." Dr. Grimm testified in Multnomah County Circuit Court Case 0310-35386, in response to a question by Multnomah County Deputy District Attorney Travis Sewell, that it would be a matter of hours or pethaps days before Stull's neurological disease caused severe pain without "a pharmaceutical clamp." Stull received no treatment for central pain syndrome while in the care of Multnomah County Corrections Health. At some point a warrant for Stull's arrest was issued in Case 20CR28838 for Stull's failure to appear. Stull was in Unity on July 3, 2020, the court date Stull was told on May 27, 2020. Stull and Hershall Brown appeared in person before Judge Cheryl A. Albrecht on August COMPLAINT ~PAGE 472020, and Stull's motion to vacate the warrant for Stull’s arrest for failure to appear in Case 20CR28838 was granted. That same day. Hershall Brown was substituted out for another attorney that would be appointed on August 25,2020. ‘That substituted in attorney would replace Hershall Brown as legal advisor in the 2015, 2018, and 2019 cases Stull was pro se, and would be defense attomey on the May and June 2020 cases, August 21, 2020, Judge Albrecht appointed Kelly Doyle to replace Hershall Brown, August 25, 2020, Stull dialed the court at the time and number provided by Judge Albrecht on August 18, 2020. Stull was informed Stull's next court date was call on November 20, 2020, for trial on November 23, 2020. Stull knew from Multnomah County Circuit Court Presiding Judge Stephen Bushong that Stull's pending criminal cases would be scheduled for tr with the oldest one fi , so Stull was prepared to defend Multnoamh County Cireuit Court Case 15CR53749, from Stull’s 2015 arrest at Portland City Hall, on remand from the Oregon Court of Appeals. Stull was informed Kelly Doyle was appointed to represent Stull in the capacity Hershall Brown had, At the time of the substitution, Hershall Brown had obtained court permission for Stull to be evaluated by Dr. True as a defense expert witness for the two 2020 cases, and Mr. Brown informed Stull Dr. True's report should be completed by the end of September 2020. Stull telephoned Kelly Doyle August 25, 2020 and left a voice mail message 3 min. 20 sec. long. Mr. Doyle called back and lefi a 23 see. voice mail message to contact him. Stull dialed out again on August 26, 2020 for 2 min. 37 sec. Stull received a call from Kelly Doyle on August 27, 2020. Stull spoke with Mr. Doyle for 22 min, and 2 sec. and when the call dropped, Mr. Doyle called back and spoke with Stull for another 4 min. and 22 see. Stull COMPLAINT -PAGE 48informed Mr. Doyle that Hershall Brown had made arrangements for Stull to be evaluated by Dr True. and Stull was seeking a transeript of Dr. Grimm's testimony from the Appellate Records Section as the best evidence documenting Stull’s central pain syndrome. Mr, Doyle ended the conversation by saying he'd speak with Stull the next week. then didn't September 28, 2020, Stull sent an email to Kelly Doyle and Deputy Dis ‘ct Attorney ‘Thomas Cleary informing them Stull had not yet received discovery in Multnomah County Circuit Court Cases 20CR288380 or 20CR30812. Mr. Doyle replied September 28, 2020, "I wiil sce what I have and either mail or discuss with you next week." October 2, 2020, Deputy Di ‘et Attorney Thomas Cleary replied with, "Mr. Doyle- The defense should have all of this Ii mater appears that something is missing we will certainly provide it immediately Regards, Tom" Weeks later, Stull still had not received discovery in the two cases assigned to Kelly Doyle, so Stull reviewed previous email messages and discovered that Hershall Brown's assistant had forwarded discovery in Case 20CR288380 while Stull was a patient in Unity and could not open attachments. October 15, 2020, Stull wrote an email to Mr. Cleary and Mr. Doyle, "Mr. Clearly and Mr. Doyle: The forwarded message from Mr. Hershall Brown's assistant contains a police report which is missing a page. I still have not received any copies of discovery for Multnomah County Circuit Court Case 20CR30812. For your information, | am in the process of obtaining the transcript of Multnomah County Cireuit Court Case 0310-35386 from appellate records because it contains the expert witness testimony of Dr. Robert J. Grimm, which cleared my felony charge of possession of 1.1 ounce of marijuana and describes the particular physiology of my central pain syndrome and how flares are triggered. Dr. Grimm's COMPLAINT ~ PAGE 49qualifications were the subject of Jennings v. Baxter Healthe: Thank you to your attention to these important maiters. Sincerely. Barry Joe Stull" October 15, 2020, Kelly Doyle responded, am aware of these issues. I will try and teleconference with you next week on some matters.” October 16, 2020, Mr. Cleary responded, "Mr. Stull: First please let me know which page you are missing and J will make sure you get it. Second - 20CR30812 is in warrant status you will need to clear the warrant and then discovery will be provided. Please consult with Mr. Doyle for guidance on how to proceed.” On October 26, 2020, Stull contacted Hershall Brown via email to clarify that an arrest ‘warrant had been vacated in August. Mr. Brown responded August 26, 2020 that a warrant was sued for Stull’s failure to appear in court on October 9, 2020 for Case 20CR30812. Stull was sickened by the news. Stull received no notice of any court appearances after Stull was told in August to appear ‘on November 20, 2020. At the time a warrant was issued for Stull’s failure to appear in court for case 20CR30812 October 9, 2020, Stull was represented by defendant Kelly Doyle, and both Mr. Doyle and the court had Stull’s telephone number. It has been a matter of record in the Multnomah County ‘cuit Court Stull is a person with a disability, and the Multnomah County District Attorney Office and defendant Deputy District Attorney Thomas Cleary were aware Stull is a person with a disability at the time an arrest warrant was issued for Stull’s failure to appear without first making a reasonable inquiry into Stull’s whereabouts and wellbeing. Stull made a personal court appearance on Case 20CR30812 August 18, 2020, and appeared in Case 20CR30812 by COMPLAINT—PAGE 50telephone on August 25. 2020.Although Stull’s telephone number was on file with the court. no one telephoned Stull, who would have reported that no one told Stull about the October 9, 2020 court date. IV. Relief From defendants Jakob Buetler, Arie Johnson, American Medical Response, Multnomah County Oregon, Bryan A. Wells, Gerald A Fink, Ryan S. Klosterman, Neill F, Martin, City of Portland Oregon, American Medical Response, Legacy Emanuel Hospital, David Griffiths Davies, Mario Gochez-Chinchilla, Tri Met, Unidentified Trimet Personnel, West Helfritch, G48, James Wood, Unidentified G4S Pacronnel, Roger S. Axthelm, Todd Engsstrom, Jeremy D. Price, Bryant Enge, Unidentified Multnomah County Sheriff Office Personnel, Unidentified Portland Police Bureau Personnel, Unidentified Tri Met Personnel, Kyle Dean Sheppard, Joseph James Witt, Daniel D. Nipper, Gabriel M. Maldonado, City of Tigard Oregon, RObert Stewart,, Clackamas County Oregon, Hearings Officer DeArmond-Reid, Portland Adventist Health, Mario lara, Unidentified Adventist Hospital Security Officers, Scherise Hobbs, Keiko Eguchi, State of Oregon,, Thomas Cleary, and Kelly Doyle, plaintiff prays for: ‘Actual and punitive damages in an amount to be determined by a jury at trial; Punitive damages authorized by ORS 659.885 for violations of ORS 659A.142(4) for disability discrimination by places offering public accommodations; Injunctive relief preventing the State of Oregon, City of Portland, Multnomah County and American Medical Response, Legacy Emanuel Hospital and Portland Adventist Health from ongoing discrimination and retaliation on the basis of disability by interfering with or refusing COMPLAINT - PAGE 51emergency medical treatment or of transportation in violation of the ADA standards governing policies and practices on the basis of a "direct threat" without first affording the required interactive process and resulting reasonable modifications required by the ADA and similar Oregon statutes and Oregon Administrative Rules; Declaration that Legacy Health Policy # 300.06.01 on the subject of "Visitor Behavior Management” is unlawful discrimination in violation of the ADA, even if facially neutral, for having a disparate impact on persons with a disability; Injunctive relief preventing Legacy Security from destroying security camera footage which may serve as evidence in the defense of a person with a disability arrested for violating Legacy Health Policy # 30.06.01 on the subject of "V (or Behavior Management"; Injunctive relief prohibiting the City of Portland from enforcing its "permanent exclusion” from Portland City Hall; and Reasonable costs and attorney fees. V. Certification and Closing Under Federal Rule of Civil Procedure 11, by signing below, | certify to the best of my knowledge, information, and belief, that this complaint: (1) is not being presented for an improper purpose, such as to harass, cause unnecessary delay, or needlessly increase the cost of litigation; (2) is supported by existing law or by nonftivolous argument for extending, modifying, or reversing existing law; (3) the factual contentions have evidentiary support or, if specifically so identified, will likely have evidentiary support aftcr a reasonable opportunity for further investigation or discovery; and (4) the complaint otherwise complies with the requirements of Rule 11. A. For Parties Without an Attorney L agree to provide the Clerk's Office with any changes to my address where case-related papers may be served. I understand that my failure to keep a current address on file with the Clerk's Office may result in the dismissal of my case. COMPLAINT ~ PAGE 52Date of signing We ember 2020 Signature of Plaintiff Printed Name of Pla ff: Barry Joe Stull COMPLAINT ~ PAGE 5301/04/2012 wae 13:08 FAK 593 413 337 cegeey Boanuel RO-T. QE Jan aososase LEGACY EMANUEL MEDICAL STULLBARRY J CENTER MRN: 8000877419 2801 N Guntenbein Ave DOB: 9124/1058, Sex M Portiand, OR 97227-1623 Admn:10/15/2011, DIC:10/182011 ED Provider Notes (continued) Musculoskeletal: He exhibits no edema and no tendemess. Neurological: He is alert. Skin: Skin is warm and dry. Psychiatric: He has a normal mood and affect. PROCEDURES: Procedures MDM Labe Reviowod, ‘COMPLETE BLOOD COUNT W DIFFERENTIAL - Abnormal; Notable forthe folowing: * Auto % Lymph 18.40) ‘All other components within normal limits COMPREHENSIVE METABOLIC PANEL - Abnorm jotable for te folowing: * Sodium, 138 (*) * Potassium 239() + Glucose 219) All other components within normal fmite CREATINE PHOSPHOKINASE - Abnormal: Notable for tha following: “CK 408 () All other components within normal mits ‘CkMB - Abnormal: Notzbie forte folowing: + CKMB 40) ‘ Allothor componente within normal limits TROPONIN LEVEL, MAGNESIUM LEVEL EKG #1 Interpreted contemporaneously by me - SVT @ 175, diffuse nonspecific T wave changes, nmi axis EKG #2 Interpreted contemporaneously by me - NSR @ 69, nmi intevals, nml axis, nmi p wave, nimi QRS, nmi sT-T Critical care tima was provided for 45 minutes by the attending physician, exclusive of seperately bitabio procedures end teating other patients, This wae necessary to trest or prevent further deterioration of tha following condition(e) Circulatory failure which the pationt had andior hed a high probabiity of suddenly developing. ED COURSE / MOM: 8:02 AM - pt resting comfortably. HO stable. Remains in NSR wigoed BP. Pt presented witachycarcia although no sx’s to suggest cardiac ischemia, EKG looked like SVT. Pt converted to NSR wicarotid massage bout only remained In NSR briefly. Pt then back into SVT. Pt again converted to NSR wicaralid massage and was then given IV metoprolol. Pt has remainad in NSR since. Also af nota, pt witypokalemia, Given KDur in ED. Ptls OK fordie. Reviewed pms for RTER wipt who fs comfortable w/plan. Printed on TAZOTS 115 PHT Barry J Stal OB; 09/24/1968 CSN 41857420 Print by: KM [37695] S ann (rv \ hibit A page oF |Page 1 of 16 R AMERICAN MEDICAL RESPONSE NW - Ree EARRY ‘0B: dsz4/1958 (57) MULTNOMAH COUNTY SEX: MALE PATIENT CARE REPORT Sonia Dos: 12272015 SERVICE MODEL AGENCY AMR [DISPATCH INFORMATION TIMES FROM: COUNTY RUN NUMBER: RP1S82472 CALLRECEIVED: 2001:10 10852 SE STARK ST NTT: 343 DISPATCHED: §— 20:01:24 PORTLAND, OR 97216 RESPONSE MODE: LIGHTS AND SIREN ENROUTE: 200180 (HOMEMESIDENCE) TRANSPORT MODE: NOLIGHTS AND SIREN | AT SCENE: 200603 To: AALS ASSESSMENT: AMR PARAMEDIC ATPTSIDE: 20.0420 EMANUEL HOSPITAL DisPosimion: TRANSPORT: 2022929 2801 N GANTENBEIN AVE TRANSPORTED - TO HOSPITAL ERIED ARRIVAL: 20.4545 PORTLAND, OR 97227 AVAILABLE: 21.0047 poser en RESPONDER(S) ON SCENE: Aecuiberyen es PORTLAND FIRE RESCUE SCENE MILES: oo Frbcenpntedt ahi PORTLAND POLICE DESTINATIONMILES: 9.0 PATIENTIPAMILY REcUSST NATURE OF CALL: UG UNKNOWN PRORLEM | TOTAL MILES: ao PATIENT DEMOGRAPHICS NAME: STULL, BARRY os: 0974/1958 ‘ADDRESS: 10852 SE STARK ST AGE: 57 CiTy, STATE ZIP: PORTLAND, OR 87218 GENDER: MALE PHONE: ETHRIGITY: CAUCASIAN CELL PHONE: SSN: XXXI0C-8674 INSURANCE: OREGON DHS OMAP POLICY: VAD4589A_ GROUP: INSURANCE: OREGON DHS OMAP NON EMERGENT POLICY: VAD4S89A GROUP: RESPONSIBLE PARTY: STULL, BARRY PHONE: (603) 777-3680, NARRATIVE NARRATIVE 543 DISPATCHED TO A UNKNOWN PROBLEM. UPON ARRIVAL ON SCENE THE PT WAS WAITING ON THE FRONT STEP. HE DEMANDED TRANSPORT TO THE HOSPITAL IMMEDIATELY OR HE WAS GOING TO OIE. WHEN ASKED TO HOLD ON AND TALK ABOUT WHAT WAS GOING ON THE PT BECAME VERY AGGRESSIVE VERBALLY SAYING WE WERE GOING TO KILL HIM. HE KEPT REPEATING THAT HE HAS CENTRAL PAIN SYNDROME ANO NEEDS TRANSPORT SACK TO THE ER. PT SAID THAT THE POLICE NEEDED TO BE HERE WHILE HE WAS YELLING AT EMS. PT WAS AGGRESSIVE WITH POLICE, FIRE, AND MEDICS VERBALLY AND PHYSICALLY BY KICKING THE CARDIAC MONITOR, HE WAS CHEMICALLY RESTRAINED AS WELL AS PHYSICALLY RESTRAINED. PT WAS UNCOOPERATIVE WITH QUESTIONS ON THE EVENTS LEADING TO CALLING EMS SAYING THAT HE WAS GOING TO TALK TO THE ED MO, AND THAT HE "WOULD SEE US IN COURT." TWAS 4 POINT RESTRAINED TO A SPINE BOARD WITH PMS PRESENT, PTWAS THEN SECURED TO GURNEY. PT WAS MOVED TO ED BED VIA SPINE BOARD AND LEFT WITH RAILS UP. PT WAS LEFT IN CARE OF RN AND SECURITY. [IMPRESSION PRIMARY IMPRESSION: BEHAVIORAL / PSYCHIATRIC - MANIC EPISODE. ‘SECONDARY IMPRESSION: BEHAVIORAL / PSYCHIATRIC - “ot EPISODE Exhibit B= page | o ttps://medsviewer.amr.net/Page 2 of 16 E STULL, BARRY ob: oaraas958 (57) SEX: MALE CASE: 4877503 os: tizzrots HISTORY OF PRESENT ILLNESS CHIEF COMPLAINTIS} PPT. STATED COMPLAINT: CENTRAL PIAN SYNDROME; CHIEF COMPLAINT CATEGORY: PAIN; ONSET: CHRONIC; HOW/S COMPLAINT DIFFERENT TODAY? NOT DIFFERENT MEDICAL HISTORY HISTORY OBTAINED FROM: PATIENT MEDICAL HISTORY: OTHER AND CENTAL ALLERGIES: NOT KNOWN VITAL SIGNS ‘GLASGOW COMA 7 BLOOD SCALE __| | BLOOD | PAIN Time | PRESSURE |PULSE|RESP[E[V[M|TOTAL| EKG _|sPo2| GLUCOSE | SCALE 2024 |rsavercia) [or fas [a [5 |e [1s 100% 20:24 100% 20:30 NORMAL SINUS RHYTHM 2092 [124/95 (10 |v [re [4 |s |e [15 100% 20:35 157 2039 {115/86 [7 [1s |a [s |e | 99% | PHYSICAL FINDINGS WEIGHT: 95 KG; 210LBS (SICAL ASSESSMENT HEAD: SYHMETRICAL NECK: NO JVD (CHEST: SYMMETRIC WITH BILATERAL CHEST RISE ABDOWEN: NOT ASSESSED . PELVIS: NOT ASSESSED BACK: NOT ASSESSED EXTREMITIES: erin FUL woven L bit B- pane 2of 3 weenie J PTA TIME CAREGIVER PROCEDURE 202600 BEUTLER, JAKOB.AMR 7 . 97202016 https://medsviewer.amr.net/Page 3 of 16 ‘ STULL, BARRY (DOB: 0572411958 (57) SEX: MALE CASE #: 4877505 bos: tizan01s, PTA TIME CAREGIVER PROCEDURE - MEDICATION ADMINISTRATION - GEODON, SOV ZONG (T0/GT) ZOMG VIAL -20 1S INTRAMUSCULAR; RESULT AFTER: UNCHANGED 20:24:00 PORTLAND FIRE MEDICATION ADMINISTRATION - MIDAZOLAM HCL MG/ML VIAL (2ML) -5 MG. RESCUE _INTRAMUSCULAR; RESULT AFTER: UNCHANGED; WASTED DRUG AMOUNT: §; NAME. OF WITNESS TO DRUG WASTING: JOHNSON, ARICAMR; WITNESS TITLE: PARAMEDIC 20:24:00 BEUTLER, JAKOBAMR PULSE OXIMETRY- 100% ON ROOM AIR; CONMENTS: NIBP (FROM LIFEPAK ‘CLOUD} 20:24:00 BEUTLER, JAKOBAMR VITAL SIGNS - COMMENTS: NIBP (FROM LIFEPAK CLOUD) GLASGOW COMA SCALE - GOS EYES: 4; GCS VERGAL: 5; GCS MOTOR: 6; GCS SCORE: 18 VITALS - BP: 159/81; PULSE: 61; PULSE REGULARITY: REGULAR; PULSE STRENGTH: NORMAL; PULSE TAKEN AT: CARDIAC MONITOR; RESPIRATORY RATE: 18; RESPIRATORY DEPTH: NORMAL; RESPIRATORY EFFORT: NORMAL 20:24:00 BEUTLER, JAKOBAMR PULSE OXIMETRY - 100% ON ROOM AIR: COMMENTS: INITIAL RHYTHM (FROM LIFEPAK'CLOUD) 20:30:00 JOHNSON, ARICAMR —_EKGIECG - INDICATION: PROTOCOUSTANDING ORDER; TYPE: 4 LEAD; CLINICIAN, INTERPRETATION: NORMAL SINUS RHYTHM 20:32:00 BEUTLER, JAKOB,AMR PULSE OXIMETRY - 100% ON ROOM AIR: COMMENTS: NIBP (FROM LIFEPAK “cLoup) 20:32:00 BEUTLER, JAKOB,AMR ——_VITAL SIGNS - COMMENTS: NIBP (FROM LIFEPAK CLOUD) GLASGOW COMA SCALE - GCS EYES: 4; GCS VERBAL: 5; GCS MOTOR: 6; GCS SCORE: 15 VITALS - BP; 124/95; PULSE: 74; PULSE REGULARITY: REGULAR; PULSE STRENGTH: NORMAL; PULSE TAKEN AT: CARDIAC MONITOR; RESPIRATORY RATE: 18; RESPIRATORY DEPTH: NORMAL; RESPIRATORY EFFORT: NORMAL. 20:35:00 BEUTLER, JAKOBAMR BLOOD GLUCOSE - BLOOD GLUCOSE READINGILEVEL: 157 20:38:00 BEUTLER, JAKOBAMR. PULSE OXIMETRY - 99% ON ROOM AIR; COMMENTS: NIBP (FROM LIFEPAK‘CLOUD) 20:38:00 BEUTLER, JAKOB,AMR. VITAL SIGNS - COMMENTS: NIBP (FROM LIFEPAK CLOUD) GLASGOW COMA SCALE- GCS EYES: 4; GCS VERBAL: 5: GCS MOTOR: 6: GCS SCORE! 15 VITALS - BP: 115/86; PULSE: 71; PULSE REGULARITY: REGULAR; PULSE STRENGTH: NORMAL; PULSE TAKEN AT: CARDIAC MONITOR; RESPIRATORY RATE: 18; RESPIRATORY DEPTH: NORMAL; RESPIRATORY EFFORT: NORMAL | Extnibrt B- page 2ef 3 RUN COMPLETION PRIVACY PRACTICES: DUE TO THE PATIENT'S MEDICAL CONDITION, A PAPER VERSION OF THE NOTICE WAS LEFT AT THE HOSPITAL FOR THE PATIENT Por ID: 2015112220995294394 DEVICE: NMULTPCROI7 PRINTED: 09/20/2016 08:10:34 hittps://medsviewer.amr.net/ . . 9/20/2016TOTS Rr Page 1 OF 3 PORTLAND FIRE BUREAU oootrout: Nrsaete secret for ovasnois 606 PRE-HOSPITAL CARE REPORT PATENT: S066 PATENTANME: STULL BARRY S vou oszwisss [ME ar PTADORESS. Sansa SESTARKSTS PORTLAND, OR arate '| SKM Wirt aoa (rHoRe: RESPONSELE PARTY Praca INCIDENT ADORESS: 10882 SE STARK ST wre verateme PORTLAND, OR S716 MEDAL STUATENFOD: peveMATRIC REASONFOROSPATCH. UMS: UNKNOWNIST RESP CALRSEENED! 41 BPATEM NCOENTSTE _HOMEPERSONAL RESIDENCE wn [wwe x [ree ESPON os, eB, MOND AD EE-OREABOAL NONE ries. [osewroeo: anor —_[emovre: ana [ousone: 00s | wmvennexr oor |ocae 202 TOTASOOETHEDNIS. 49 RATION TEN rvs Teor: ves | sts LEVELOFSERIME: ALS 10 cones: Bi or CASCENE TE WINPATENT TINE TRANSORTTME TRON COMPLETE TE aoa no nox nas pera: os vena was on woven wr ENTEREOINOTIAAGYSTER wo [Twecr EN HANA: oe TAMA BEATIN Ta nN ea ORT PASTHESGALHSTOR: CENTRAL PAINSYNOROME CURRENT MEDICATONS: UNKNOWN MUERGES: UNKNOWN Evy hint C page \ o & Bremen TIME 2007;30 _. PERFORMED aaa, 1a TALERE:Y] {ORIENTANON TO EVENT: } {ORIENTATION TO PERBON:'Y} [ORIENTATION TO PLACE: Y} [ORENTATION TO ‘wer si: TARO: ROte0082H Page 2 of 3 PORTLAND FIRE BUREAU wnemenroaTe Hnanete RESPONSBLELNT. 7 ouasnnis 1606 PRE:HOSPmALCARERERORT, PATENT: 906968 COLOR: NORMAL] (HYDRATION: DRY] [ TEMPERATURE: NORMAL} TIME: 20:12:30. PERFORVED EY: — yaaa, = ee {8 SYSTOLIC: AUR OBTAINED, NOT WRITTEN DOWN] was [[SP02 SATURATION %: 100] [PULSE RATE: 76} [ PULSE RHYTHM: REGULAR] [PULSE QUALITY: STRONG] [RESP RHYTHM: REGULAR] TIME: 20:48:30. = PERFORMED BY: w3a3, ‘seoncn [AMOUNT 20] {UNIT OF MEASURE: MG [ROUTE:IM] [ REASON FOR ADMINISTRATION: CHEMICAL RESTRAINT ] TE: 20:18:90 ~_PERFORVED BY: WELLS, BRYAN ESSED ANDAzOLANN [AMOUNT: 6] [UNIT OF MEASURE: MG] [ROUTE: M1] [REASON FOR ADMINISTRATION: CHEMICAL RESTRAINT] {WHOSE DRUG?: AMR] (UNIT OF MEASURE: MG] TME:_20:28:08 PERFORMED BY: Waa, ‘aseomrnecan TRANSPORT: BEGAN] “pia. ~_PERFORNED BY: naga; ‘RANGPORT COMPLETE TRANSPORT: COMPLETE NARRATIVE ‘SUBJECTIVE: DISP TO 67 YOU CIC OF PSYCH ISSUE. PT1S VERY IRATE AND SCREAMING AT AMR. PTS YELLING THAT HE WILL DIE ‘UNLESS HE GOES TO THE ER. PT CONTINUES TO YELLIN AN AGGRESSIVE MANNER, CURSING AT CREWS, WITH AGGRESSIVE POSTURING, SUCH AS WALKING TOWARDS AMR ANO E7 WITH CLINCHED FISTS. PT CONTINUES TO YELL THAT HE WILL DIE UNLESS WE TRANSPORT Hil, THROUGHOUT CALL, PT CONTINUES TO YELL "CENTRAL PAIN SYNDROME.” PT DENIES THAT HE NEEDS TO ‘CALM DOWN AND CONTINUES TO YELL AT US UNTIL CHEMICALLY RESTRAINED, ‘OBJECTIVE: ARRIVED TO FIND PT SCREAMING AT AMR AND MOVING BACK ANO FORTH TOWARDS THEM IN AN AGGRESSIVE TONE, PTI VERY AGITATED NO TRAUMAIS NOTED. UPON REACHING PT, EY ATTEMPTS TO SPEAK WITH PT. PT STARTS OFF CALM AND ‘SHOWS E7 MEDICAL PAPERIVORK STATING HIS AILMENT. WHEN ASKED ABOUT GOING TO HOSPITAL, PT GOT VERY AGGRESSIVE IN ‘BOTH POSTURE AND VERBALLY. PT STARTED SCREAMING AT EY AND MOVING AROUND WITH CLINGHED FISTS AGAIN. UPON PPE ‘ARRIVAL, PT CONTINUES TO YELL AND THREATEN BOTH MEDICAL STAFF AND PPB, PT WAS ADVISED MULTIPLE TIMES THAT WE ‘CANNOT TRANSPORT Hist UNTIL HE CALMS DOWN, BOTH FOR HIS SAFETY AND OURS. PT WAS THEN PLACED IN HANDCUFFS BY PPB. PT CONTINUES TO BE ANGRY AND CONTINUES TO YELL. PT WAS THEN CHEMICALLY RESTRAINED FOR TRANSFORT TO ER. ‘APRK 3 MINUTES AFTER MEDS, PT WAS CALM ANO TALKING TO AMR WITHOUT ISSUE AND ANSWERING QUESTIONS. UNABLE TO GET ANY OTHER MEDICAL HISTORY FROM PT DUE TO GURRENT MENTAL STATE. PT PLACED ON BACKBOARD IN SOFT RESTRAINTS PER PROTOCOL. REST OF EXAM UNREMARKABLE, ASSESSMENT: POSS PSYCH |SSUE. Exhibit C- poye 2 & 3% pa mss tae er nan oi gate vom sit men nono r0 SoA NONEPage 3 Of 3 cunsanie 1608 PORTLAND FIRE BUREAU PRE-HOSPITAL CARE REPORT TIARUNO: RPTeOORRATE INODENTOATE: s¥22/2018 RESPONSELEUNIT: E07 PATIENT 0:_s08868 RESPONGIOLE UT PERSONNEL: FINK, GERALD A -KLOSTERMAN, RYAN 8 - MARTIN, NEILF -WELLS, BRVANA Plo: _ FINK, GERALD A TIME OFPICTRANSFER: 1720/2018 20:23 ROSCA TRANSFER OF CARE: MENER MAKING REPORT: THe FF OME syaar2018 ‘ADDTIORAL FORMATION: Tm: ATE Ewbhybit C. page Sof 8LEGACY HEALTH ADMINISTRATIVE Policy #: 300.06.01 Origination Date: 4/98 Last Revision Date: 7/2012 FACILITIES & SAFETY VISITOR BEHAVIOR MANAGEMENT _ ‘SECTION ‘SUBJECT: PURPOSE: To maintain individual rights while protecting Legacy Health patients, staff, visitors and property. DEFINITIONS: Inappropriate behavior means acting in ways contrary to the best interests of the facility and includes, but is not limited to: Public intoxication Verbal or physical threats Use of abusive, profane language Solicitation for causes which are in opposition to the health system philosophy, treatment and/or goals Refusal to comply with other policies, e., tobacco free campus, visitor hours Carrying dangerous weapons (any instrument, article or substance which is readily capable of causing death or serious physical injury) on any LH campus. Dangerous weapons of any kind are not permitted on any campus, except as follows: a) Sworn Law Enforcement Officers b) On-duty Military Personnel in the performance of their duties. ©) Armored car couriers in the performance of their job duties Safety/Security wil provide a locked storage area for any dangerous weapons confiscated by officers or tured in for safekeeping while the owner is in the hospital. The Manager and/or Lead Officer on duty will have access. A “Found Property” form shall be completed on all items placed in the secured storage area. A “Property Report” shall be completed and filed in the Safety/Security office, aeNe POLICY: ‘A. Persons may be escorted off property, arrested or criminally trespassed from Legacy Health premises if they are: 4. Committing a criminal act, ie., theft, criminal mischief, robbery, burglary, assault, criminal trespass (including violations of a restraining order), possession of alcohol, tering, unlawful possession of a controlled substance, forgery, fraud or deception, unlawful possession of a weapon of any kind, disorderly conduct, harassment, menacing, recklessly endangering, or intimidation. Individuals committing criminal acts on campus will be arrested and prosecuted, 2. Creating a disturbance. 3. Without valid business: a) Loitering anywhere on property Exlibit D page lof 23.01 Visitor Behavior ManagementPage 2 of 2 b) Removing refuse from waste containers or ash trays 4. Acting in ways contrary to the best interest of the faciity 5, Soliciting without permission of Chief Administrative Officer (CAO) or Human Resources. . 6. Unsanitary, visibly fithy, or having an offensive odor. B. Individuals may be issued a criminal trespass notice for any of the above listed offenses. C. Verbal criminal trespass warnings (CTW's) are not enforceable and will not be issued in leu of awitten CTW, Approvals: Environment of Care Committee Executive Councit Originator: Director, LH Safety/Security Exhot D- page 2o0f 2MCMAHON Eamon From: Silva, Chris C :LSO Mage Safety and Security Sen Monday, September 05, 2016 7:17 AM To: MCMAHON Eamon « Greer, Anne T:1SO Legal Services; Rosenquist, Terry -LSO Security Administration Subject: Barry Joe Stull Trial DDA McMahon, Our practice is to retain recorded video for 30 days unless we need it either internally or if there is a request from an outside party. Ifa request is made within 30 days, the video is pulled and | consult with Legacy legal counsel (Anne Greer) before releasing the video, which usually requires a subpoena. We do not pull and save all video of incidents or arrests. In this case, since it occurred on November 22 or last year there appears to be no saved video. Terry, Please confirm that you were not requested to pull video for EH15-0954 involving Dave Davies, Mario Gochez- Chinchilla and Steve Azorr. Thank you, Chris Chris Silva Safety & Security Manager|Legacy Health 2801 N, Ganenbsin Avene, Porand, OR 97227 503-413-2765] cilva@li.og Exlsbit E- page \ of \/ ye ia-lois SH AUT 2PM 4 EIS SIO Bryant Boge, Director Crry or Porttanp Baran of ternal usin Sevis = OFFICE OF MANAGEMENT AND FINANCE "95.0 BillyMemes fot Toi Charlie Hales, Mayor (608) 82.4962 Fred Miller, Chief Administrative Officer FAX (903) 823-5384 “TTY (03) 823-6868 December 1, 2015 Barry Joe Stull 10852 SE Stark Street, #5 Portland, Oregon 97216 RE: Notice of Exclusion from City Property Dear Mr, Stull: (On November 24, 2015 around noon, you entered the Office of Neighborhood Involvement (ON), located on the first floor of Portland City Hall (1221 SW 4® Avenue, Portland). You made a request for ONI staff to provide you with personal transportation to your home. ONI staff informed you that it was not an office that provided personal shuttle or passenger transport service and offered a City telephone 80 thal you could arrange for your own transportation. You disrupted and distracted City staff from City business with your agitated and belligerent demeanor at the ONI reception area that included shouting and gesticulating at City staff and/or building security. You refused multiple requests to leave, Asa result, security officers excluded you for twenty-four hours from City Hall starting at 12:45 PM. However, instead of leaving City Hall immediately, you went to Commissioner Fritz’s office.on the second floor of City Hall and made the same demand for personal shuttle service:to your home. City staff at that office again informed you that the City did not provide personal shuttle service. Security again directed you to leave City Hail pursuant to the twenty-four hour exclusion. On November 25, 2015, at approximately 9:20 AM, you entered City Hall prior to the end of the twenty- four hour exclusion issued on the previous day and proceeded to City Council Chambers on the second floor of City Hall. While in Council Chambers, you shouted and yelled at all the persons in the room. You created a disruption that caused delay in the commencement of a scheduled 9:30 AM City Council meeting. Security officers asked you to leave City Hall, but you refused and continued your disruptive behavior and shouting. Portland Police officers arrive to attempt to speak with you peacefully, to remove you from Chambers and take you into custody for criminal trespass, You were observed using your arms and body to prevent the police officers from taking you into custody and striking at least one police officer in your attempt to avoid arrest. The City Council meeting was unable to commence on time until you were removed from Chambers, ‘Your actions interfered with the City’s vital governmental operations, including its City Council meeting and other City business that was being engaged in the offices of City Hall, and are in violation of the City’s Rules of Conduct that all persons are required to observe while on City of Portland properties. The City is responsible for ensuring that employees and visitors have a safe and welcoming environment to conduct business for or with the City. Your action disrupted and impaired the’ability of City offices and City Council to carry out an orderly proceeding and created a potentially unsafe environment for City employees and visitors who wish to conduct City business peacefully and orderly, Ex hiby F-Your actions were purposeful because on November 23, 2015 you stated in hearing of City staff that you desired to get arrested at City Hall, and on November 24, 2015 you stated to security officers that you would ignore the twenty-four hour exclusion on the next day by returning to City Hall ‘As property owner, the City of Portland has the right to exclude you from its properties due to your disruptive action. Pursuant to Portland City Code Section 5.36.115, as welll as the authority from City Charter, City Code and as authorized by the City Council and the Mayor, the Office of Management and Finance has been designated to administer and enforce the rules of conduct for City properties and to issue exclusions to persons who violate the rules of conduct on City properties. On behalf of the City of Portland and as the designated person in charge, the following restrictions are imposed on your access to City properties: 1, You are excluded from the Portland City Hall located at 1221 SW 4th Ave., Portland, Oregon. Excluded areas include the loggias, and ramps or driveways leading to the City property, which for the purposes of this exclusion, is defined as anything behind the decorative fence surrounding City Hall. 2. This exclusion is permanent, and shall commence on the date of this Notice 3. This exclusion from the identified City property is in addition to any other exclusions that may have been issued to you by others, such as City parking garage manager or the courts. 4, _ if youwish to appeal this exclusion, your request for appeal must be made in writing to the Code Hearings Office (1900 SW 4th Ave, Room 3100, Portland, Oregon 97201; Phone 503-823-7307; Fax 503-823-4347; TTY 503-823-6868) within five calendar days of the date of this notice of exclusion and specifying your basis for appeal. Unless you request in writing the presence of the issuing person at the appeal hearing, the sworn statement of the person in charge who issued the notice of exclusion shall be used as evidence. Serve a copy of your request for appeal to the Director of Internal Business Services at the address below. Your request for appeal does not stay the effectiveness of this ‘exclusion, 5. You may notenter or remain on the above identified location while the exclusion is in.effect. Any Violation of this exclusion will result in your arrest for Criminal Trespass in the Second Degree. The City of Portland will vigorously prosecute you for any and all violations of the law, including criminal trespass. 6. The City of Portland reserves the right to exclude you from other City properties. 7. The City welcomes diverse viewpoints at Council meetings. However, attendance at Council meetings requires attendees to follow the rules of order and the limitations that the Council imposes so that meetings can run efficiently and orderly. During the period of exclusion, you may observe live Council meetings online. See http:/www portlandoregon.gov/28258. Any testimony you wish to provide must be submitted in writing to the City Council Clerk prior to the meeting date, Contact for the Council Clerk is: 1221 SW 4th Ave, Rm 130, Portland, Oregon 97204 or at http:/Awmw portiandonline.com/auditorfindex,cfm?c=26979. The agenda for the City Council meetings is posted by the Council Clerk on the Friday prior to the Council meetings. The Council Clerk provides links on the City's website to the various items on the Council agenda as soon as possible after the . ‘agenda is posted. Exhibit F- page 2ef 3 Lo8 During the period of exclusion, if you wish to conduct business with a City office located at the Portland City Hall, you may use other means of communication such as in writing through the mail or electronic email, by telephone of teleconference, as available and appropriate. The City office has the discretion to determine whether an in-person meeting at an alternative meeting site is required. In all cases, you are required to comply with the building rules of conduct for an alternate meeting location. The City will not tolerate abusive communication whether in person, in writing or by other means. 9. If the term of this exclusion is less than permanent, when the exclusion term expires, you will be allowed to enter City Hall to attend City Council sessions in accordance with the Rules of the Council, including such limitations as are imposed by the presiding, or visit Cty offices located at City Hall Should you engage in further disruption, you should be aware that any future exclusion is likely to be for a significantly longer period of time and the City may take any other appropriate action Questions as to this exclusion must be made in writing to the Director of Internal Business Services, Office of Management and Finance, at 1120 SW 5th Avenue, Room 1250, Portland, Oregon 97204. Sincerely, . Z PyptrE He Director, Bureau of Internal Business ServicesATTE" DING PHYSICIAN’S STATEN “NT Oreyon Medical Marijuana Program all sections of this form in order to comply with th a Act OR provide relevant portions of the patient’ of the Oregon Medical Marijuan: all information required on this form. please call (97 Ofc we ely Ie registration requirements 's medical record containing Prescription for marijuana. 1) 673-1234 PLEASE TYPE OR PRINT LEGIBLY. a = PATIENT INFORMATION - PATIENT NAME (AST, FIRST, M1) DATE OF BIRTH potull, Barry Soe et 24-\acg MAILING ADDRESS. ~ TELEPHONE & L__ PO Gox itoog {_)nene CITY, STATE AND ZIP CODE: ectland OR (IZ | a [8 PHYSICIAN INFORMATION, PHYSICIAN NAME: x “ ¢ We im atveela tlh ove nu _ MAILING ADDRESS: 2 ee ~— TELEPHONE # “ote Sw Star “SH OE BOLsse syn _ CITY, STATE AND ZIP CODE: Op Hond Ope ae — [ce PHYSICIAN'S STATEMENT _ Debilitating Medical Condition: Check appropriate boxes, {_] 4. Malignant neoplasm (Cancer) - — [_12. Glaucoma : [ ] 3. Positive status for Human Immunodeficiency Virus (HIV) or Acquired Immune Deficiency Syndrome (AIDS) _ . |[_]4. Agitation due to Alzheimer's Disease - _ 5. A medical condition or treatment for a medical condition that Produces for a Specific patient one or more of the following: (check all that apply) _ [ Ja. Cachexia - _ 2X] b. Severe pain [’c. Severenausea 1d. Seizures, including but not limited to seizures cau ] e. Persistent muscle spasms, ‘multiple sclerosis. L i L i ised by epilepsy [ including but not limited to spasms caused by | ossome PS 2008 Portland, OR 97283-0450TAM DR ROGER” GRIMM Fax Wo. $09 221 4220 ROBERT J. GRIMM, MD, F.A.GP,, PC Physica CCoorultant in Neurology Berry Sm Sex 26 Ace Zoom wis: Hamas mahi . (even a RRO OF ARON seh Samy mremnens CPiner See oy RIO tee Zan emaReprermic ComT Re PRIN SUNT Cee wule Awodyart eanplakE Sensory lore Crceame = Dosen, Pan wm Rercer FRM MD Fen. r Patsy Kull berg Stame 2485 NW Marshall - Suite 14 Portland, Oregon 97210 FAX 221-0220 + Phone (503) 221-0295, Exhibit W- page lot |