PRETRIAL CONFERENCE ORDER
JOHN A. MENDEZ, District Judge.
Pursuant to court order, a Pretrial Conference was held on March 31, 2017 before Judge John Mendez. Dan Stormer and Joshua Piovia-Scott appeared as counsel for plaintiff James Joshua Mayfield; John Whitefleet appeared as counsel for defendant Ivan Orozco; Van Longyear and Nicole Cahill appeared as counsel for defendants County of Sacramento and Scott Jones. Defendants University of California Davis Health System, Inc. Dr. Gregory Sokolov and Dr. Robert Hales entered into a conditional settlement prior to the pretrial conference and were not required to participate in the conference. After hearing, the Court makes the following findings and orders:
I. JURISDICTION/VENUE
Jurisdiction is predicated upon 28 U.S.C. §§ 1331 and 1343, and has previously been found to be proper by order of this court, as has venue. Those orders are confirmed.
II. JURY/NON-JURY
All parties have demanded a jury trial.
III. STATEMENT TO BE READ TO JURY
Seven (7) days prior to trial the parties shall E-file a joint statement of the case that may be read to the jury at the beginning of jury selection.
IV. UNDISPUTED FACTS
While Plaintiff was a pre-trial detainee at the Jail, Defendant Sheriff Scott Jones was the Sheriff of the County.
V. DISPUTED FACTUAL ISSUES
A. Plaintiff
Plaintiff's disputed factual issues include the following:
1. Whether Plaintiff was scared of the officers in the Jail and did not like to interact with the deputies and other inmates.
2. Whether Defendant Orozco told Plaintiff that he was "going to beat your ass" when Plaintiff was having psychotic episodes and screamed at night.
3. Whether, after Defendant Orozco opened the door between himself and Plaintiff on November 22, 2012, Orozco initiated the altercation when he threw Plaintiff's food into Mayfield's face.
4. Whether Plaintiff hit or struck Defendant Orozco on November 22, 2012.
5. Whether Defendant Orozco knocked Plaintiff unconscious during the November 22, 2012 incident and continued to kick and strike Plaintiff even though he was unconscious.
6. Whether Defendant Orozco continued to hit and strike Plaintiff on November 22, 2012 even after Plaintiff was handcuffed.
7. Whether Defendant Orozco used excessive force against Plaintiff on November 22, 2012 and whether the County and Defendant Jones are responsible for this use of force.
8. Whether Defendant Orozco's use of force against Plaintiff on November 22, 2012 amounted to unlawful assault or battery.
9. Whether Defendants responded appropriately to identify, assess, evaluate and/or treat any potential head injury suffered by Plaintiff in connection with the November 22, 2012 use of force.
10. Whether there was an adequate medical assessment done in connection with any potential injury to Plaintiff's head as a result of the November 22, 2012 incident.
11. Whether the video recording of the November 22, 2012 incident contradicts Defendant Orozco's version of the Incident and whether the County and/or the Sheriff's Department and Defendant Jones acted appropriately with regard to this possibility.
12. Whether the County and Defendant Jones responded appropriately to the November 22, 2012 incident, including the decision to exonerate Defendant Orozco and discipline Plaintiff.
13. Whether Defendant Orozco was trained that strikes to the head, neck or throat "may be fatal" and whether he was trained not to strike people in these areas.
14. Whether inmate Russell aggressively approached and hit the officers, including Defendant Orozco, on December 3, 2011, or whether Russell retreated away from the officers and was not a threat to them at the time they used force against him.
15. Whether Defendant Orozco's attack on Russell on December 3, 2011 and his attack on Plaintiff on November 22, 2012 were similar incidents.
16. Whether the video recording of the December 3, 2011 incident contradicts Defendant Orozco's version of the incident and whether the County and Defendant Jones acted appropriately with regard to this possibility.
17. Whether the County and Defendant Jones responded appropriately to the December 3, 2011 incident.
18. Whether the County and/or the Sheriff's Department's use of force policy is adequate and appropriate.
19. Whether the County and/or the Sheriff's Department has an unwritten "intent" requirement in its use of force policy.
20. Whether the County and/or the Sheriff's Department's use of force policy, and its investigations into its officers' use of force, appropriately consider the mental health status of the inmates against whom force is used.
21. Whether Defendants' disciplinary policies and procedures appropriately consider the mental health status of inmates.
22. Whether the County and/or the Sheriff's Department trains its custody officers regarding use of force against mentally ill inmates.
23. Whether the County and/or the Sheriff's Department effectively and/or appropriately trains its custody officers regarding use of force against mentally ill inmates.
24. Whether Defendants train custody officers regarding effective communication with mentally ill inmates, and/or whether that training is effective or appropriate.
25. Whether the County and/or the Sheriff's Department has a tracking system to determine whether particular officers have a history of use of force or excessive force.
26. Whether the directives contained in the corrective actions that the County and/or the Sheriff's Department takes against its officers for using force are actually followed.
27. Whether the County and/or the Sheriff's Department and Defendant Jones appropriately review and evaluate their officers' performance and actions, including the performance and actions of Defendant Orozco.
28. Whether officers at the Jail regularly took inmates to areas of the Jail where there are no cameras and beat them up, particularly if an inmate had had an altercation with an officer or was mentally ill.
29. Whether the County and/or the Sheriff's Department should have disciplined officers, including Defendant Orozco and Deputy Pietrek, for filing false and/or incomplete reports.
30. Whether the County and/or the Sheriff's Department's investigations into the December 3, 2011 and November 22, 2012 incidents were appropriate.
31. Whether the County and/or the Sheriff's Department and Defendant Jones' actions and/or inactions in connection with the December 3, 2011 incident had any impact on the November 22, 2012 incident.
32. Whether the County appropriately identified, assessed, monitored and treated Plaintiff's diabetes and medical needs.
33. Whether the County appropriately identified, assessed, monitored and treated Plaintiff's schizophrenia and mental health needs.
34. Whether the County appropriately considered, monitored and treated the impact of Plaintiff's diabetes on his mental illness and/or mental health condition.
35. Whether the County had appropriate policies and procedures for addressing situations in which inmates, including Plaintiff, refused medication.
36. Whether the County appropriately housed Plaintiff during his time at the Jail.
37. Whether the County appropriately classified Plaintiff during his time at the Jail.
38. Whether the County sufficiently and/or appropriately cooperated, coordinated and/or communicated regarding Plaintiff and his medical and mental health care.
39. Whether the County sufficiently and/or appropriately cooperated, coordinated and/or communicated regarding Plaintiff and his Jail housing, classification, and conditions of confinement.
40. Whether the County subjected Plaintiff to unduly restrictive conditions of confinement.
41. Whether it was appropriate to house Plaintiff in a classroom and/or his cell after he had been identified as needing admission to 2P.
42. Whether it was appropriate to house Plaintiff in the cell he was housed in when he attempted to commit suicide.
43. Whether the County appropriately responded to Plaintiff's suicide attempt and the injuries he suffered as a result of the attempt.
44. Whether the County was on notice of inadequacies in the provision of medical and mental health care at the Jail.
45. Whether the County was on notice of the insufficient beds in 2P.
46. Whether the County housed Plaintiff in inappropriate settings while he was on the 2P pre-admit list because there were insufficient beds in 2P.
47. Whether the County took appropriate action regarding the number of beds in 2P.
48. Whether the County provided mental health treatment to Plaintiff outside of 2P.
49. Whether there were sufficient locations and circumstances for the provision of appropriate, confidential mental health care in the Jail.
50. Whether the County's failure to provide a single confidential mental health contact to Plaintiff at the Jail violated the standard of care.
51. Whether the County and Defendant Jones appropriately supervised JPS, including in connection with their responsibility to provide constitutionally adequate care.
52. Whether the County had appropriate quality assurance or review policies, procedures or practices.
53. Whether the County responded appropriately to Plaintiff's repeated reports of suicide and self-harm and/or appropriately addressed these issues.
54. Whether the County had sufficient staffing.
55. Whether the County's policies, procedures and/or practices regarding isolation and segregation of inmates, including mentally ill inmates and Plaintiff, were appropriate.
56. Whether the County's policies, procedures and/or practices for suicide prevention were adequate.
57. Whether the County's policies, procedures and/or practices for provision of mental health treatment were adequate.
58. Whether the County's policies, procedures and/or practices for admission and discharge to the 2P unit were appropriate.
59. Whether the County's policies, procedures and/or practices for mental health treatment following discharge from 2P were appropriate.
60. Whether the County had sufficient policies, procedures and/or practices for mental health screening and monitoring of inmates in segregated and/or restricted housing settings
61. Whether the County responded appropriately to Plaintiff's reports that he was being sexually assaulted.
62. Whether the County implemented the requirements of the Prison Rape Elimination Act in a timely and appropriate manner.
63. Whether the deputies at the Jail were aware that the inmates they were responsible for supervising, including Plaintiff, had mental health issues and whether they incorporated this information into their supervision and interactions with the inmates.
64. Whether the medical and mental health care that the County provided to Plaintiff met the standards of care and contributed to Plaintiff's attempted suicide and resulting physical injuries.
65. Whether the County responded appropriately to Plaintiff's repeated statements and actions reflecting suicidal ideation.
66. Whether Plaintiff's suicide attempt was foreseeable.
67. Whether Plaintiff's suicide attempt was preventable.
68. Whether the County took adequate and/or appropriate actions to protect Plaintiff from harm, include self-harm.
69. Whether the County conducted adequate and/or appropriate suicide risk assessments of Plaintiff.
70. Whether the County conducted adequate and/or appropriate medical or mental health assessments of Plaintiff.
71. Whether the County adequately considered Plaintiff's conditions of confinement in connection with their provision of medical and/or mental health care.
72. Whether the County utilized appropriate criteria for admitting and/or discharging Plaintiff from 2P.
73. Whether the County appropriately followed up with inmates, including Plaintiff, after they were discharged from 2P.
74. Whether the County failed to incorporate Plaintiff's specific risk factors into his treatment planning.
75. Whether the County appropriately reviewed and incorporated Plaintiff's mental health treatment at Napa State Hospital into his treatment plan at the Jail.
76. Whether the County appropriately treated Plaintiff in the time period leading up to his suicide attempt and resulting injuries.
77. Whether the County's assessments of Plaintiff in connection with prescription of medication and/or changes to medications met the standard of care.
78. Whether the County engaged in adequate treatment planning for Plaintiff.
79. Whether Plaintiff's mental health condition deteriorated during the time period he was in Jail and whether the County is responsible for that deterioration.
80. Whether the County's actions and omissions exacerbated Plaintiff's mental health condition.
81. Whether the County failed to provide Plaintiff with appropriate medical or mental health care and/or failed to protect him from harm.
82. Whether the County discriminated against Plaintiff on the basis of his disability.
83. Whether the County failed to furnish required medical or mental health care.
84. Whether the County was negligent, or negligently supervised, trained, hired or retained anyone, in connection with their actions regarding Plaintiff.
85. Whether the County provided meaningful mental health treatment, including anything other than isolation, observation and/or medication.
B. County Defendants
First Claim
1. Whether Orozco's use of force violated James Joshua Mayfield's Fourteenth Amendment rights.
2. Pursuant to Monell, did the County violate James Joshua Mayfield's Fourteenth Amendment rights.
3. If the use of force by Defendant Ivan Orozco violated James Joshua Mayfield's Fourteenth Amendment Rights, whether Sheriff Scott Jones ratified the violation.
4. If James Joshua Mayfield's Fourteenth rights were violated, what is the nature and amount of damages suffered as a result of that violation.
5. Whether Defendant Scott Jones is entitled to qualified immunity.
Third/Fourth Claim
1. Pursuant to Monell, did the County of Sacramento violate James Joshua Mayfield's Fourteenth Amendment rights to medical care?
2. Pursuant to Monell, did the County of Sacramento violate Plaintiff's Fourteenth Amendment rights by failing to protect him from self-harm and/or assault from other inmates?
Sixth Claim
1. Whether or not the County violated Mayfield's rights under the Americans with Disabilities Act (ADA).
Eighth Claim
1. Whether the County of Sacramento is liable pursuant to Government Code § 845.6.
C. Defendant Orozco
Defendant OROZCO'S Disputed Factual Issues:
1. Whether Plaintiff James Joshua Mayfield can establish that Deputy OROZCO violated the Fourteenth (Fourth) Amendment pursuant to 42 U.S.C. section 1983.
2. Whether Defendant Orozco is entitled to qualified immunity.
3. Whether Plaintiff James Joshua Mayfield can establish the elements of a claim of assault/battery under state law.
4. Whether Plaintiff James Joshua Mayfield can establish the elements of a claim for violation of Civil Code section 52.1.
5. Whether Plaintiff James Joshua Mayfield can establish the elements of a claim for negligence
6. Whether Plaintiff James Joshua Mayfield can establish the elements of a claim for IIED.
7. Whether the deputy acted in defense of self or others under state law.
8. Whether Plaintiff acted in a matter that assumed the risk, consented to the conduct or contributed to his injuries under state law
9. The extent of any claimed injuries and/or damages to Plaintiff.
10. Whether Plaintiff can establish punitive damages.
VI. DISPUTED EVIDENTIARY ISSUES
A. Plaintiff
Whether the testimony and/or the reports of County consultants Vail and Gage are admissible at trial. Plaintiff believes this issue should be resolved by motion in limine.
B. County Defendants
County Defendants anticipate moving in limine to exclude specific evidence, including testimony by Plaintiff's experts. Defendants intend to move to preclude:
1. Plaintiff from offering evidence and/or argument regarding opinions of Dr. Bruce Gage.
2. Plaintiff from offering evidence and/or argument regarding opinions of Eldon Vail.
3. Plaintiff from offering evidence and/or argument regarding opinions based on reports generated by Dr. Bruce Gage.
4. Plaintiff from offering evidence and/or argument regarding opinions based on reports generated by Eldon Vail.
5. Plaintiff from offering evidence and/or argument regarding opinions based on conduct and/or conditions of the Sacramento County Jail after July 17, 2013, including suicide or suicide attempts.
6. Plaintiff's expert from making factual determinations.
7. Plaintiff's expert from offering legal opinions or argument.
8. Plaintiff from offering evidence of investigation or lack thereof regarding allegations of sexual assault of Plaintiff for purposes of arguing liability for failure to protect JJM from sexual assault.
C. Defendant Orozco
Defendant OROZCO anticipates the following evidentiary issues will be in dispute and respectfully request they be addressed by pretrial rulings and/or motions in limine to the extent the parties are unable to reach an agreement:
1. Exclusion of any reference, testimony or questions to or by witnesses listed by Plaintiff from commentating on the video of the incident on November 22 2012
2. Exclusion of any reference, testimony or questions to Defendant Orozco's performance review(s) or evaluations
3. Exclusion of any reference, testimony or questions to Defendant Orozco's academy test sheet (Arrest Control Techniques Quiz, taken by Ivan Orozco, dated August 9, 2007)
4. Exclusion of any reference, testimony or questions of prior incidence of uses of force by Defendant with other inmates, including any internal affairs investigation or disciplinary actions or results from prior actions
5. Exclusion of any reference, testimony or questions any internal affairs investigation or post incident review by the County, and any disciplinary or corrective actions. Defendant may also seek a limiting instruction regarding his post-incident interview.
6. Exclusion of any reference, testimony or questions regarding Defendant Orozco's Worker's Compensation claim form
7. Defendant will seek to exclude any live testimony by Plaintiff as incompetent and/or mentally infirm.
8. Exclusion of any reference, testimony or questions regarding statements by Deputy Pietrek to Inmate Mayfield over the intercom prior to Orozco entering
9. Exclusion of any reference, testimony or questions regarding the charges or prosecution of charges against Plaintiff arising from the incident on November 22 2012.
10. To exclude Plaintiffs' retained police practices expert Jeffrey A. Schwartz from testifying at trial, or in the alternative, from testifying regarding ultimate facts, disputed facts, the credibility of witnesses, legal conclusions, and improper opinions without factual support or foundation.
11. Limitation on playback of video request
VII. RELIEF SOUGHT
A. Plaintiff
Plaintiff seeks through this action compensatory, general and special damages, punitive damages, as well as reasonable costs and attorneys' fees, to be determined through a motion for attorneys' fees to be filed subsequent to any entry of final judgment in Plaintiff's favor.
B. County Defendants
None by County Defendants. Plaintiffs seeks compensatory, general and special damages according to proof. Plaintiffs also seek punitive damages and reasonable attorneys' fees pursuant to 42 U.S.C. § 1988. Defendants pray that Plaintiff take nothing by way of his complaint, and that Defendants be awarded attorneys' fees and cost of suit, and for such other relief as the Court deems just and proper.
C. Defendant Orozco
Defendant OROZCO request that Plaintiffs take nothing in this action, that Defendant be awarded his attorney fees and cost of suit, and for such other and further relief as the Court deems just and proper.
VIII. POINTS OF LAW
Trial briefs shall be E-filed with the court no later than seven (7) days prior to the date of trial, i.e., April 24, 2017. Any points of law not previously argued to the Court should be briefed in the trial briefs.
IX. ABANDONED ISSUES/REMAINGING CLAIMS
Following the Court's Orders on Defendants' Motions for Summary Judgment, all claims have been abandoned or dismissed other than the following Causes of Action:
Cause of Action Claim Defendant
1st Claim Excessive Force Orozco, Jones,
County
9th Claim Assault Orozco
10th Claim Battery Orozco
11th Claim Bane Act Orozco
12th Claim Negligence Orozco
15th Claim Intentional Interference Orozco
with Emotional Distress
Cause of Action Claim Defendant
3rd Claim Deliberate Indifference County
(14th Amendment)
4th Claim Failure to Protect from County
Harm (14th Amendment)
6th Claim Disability Discrimination County
(ADA; Rehabilitation Act)
8th Claim Failure to furnish/summon County
medical care
12th Claim Negligence (Failure to County
summon medical care)
13th Claim Negligent Supervision, County
Training, Hiring (Failure
to summon medical care)
All claims filed by Plaintiffs James Allison Mayfield, Jr. and Terri Mayfield have been dismissed. The sole remaining plaintiff is James Joshua Mayfield. All claims against defendants James Lewis and Rick Pattison have been dismissed or abandoned.
X. WITNESSES
Plaintiff's witness list is attached to this Pretrial Conference Order as Exhibit A.
Plaintiff intends to call as trial witnesses two inmates who witnessed the November 22, 2012 use of force incident involving Plaintiff and Orozco, Nathaniel Carter and Nicholas Newsome. It is Plaintiff's understanding that these two witnesses are currently incarcerated in the Salinas Valley State Prison located in Soledad, California. As requested by Plaintiff, a writ of habeas corpus ad testificandum has been issued by the Court in order to compel their appearance to testify at trial. This Court has also signed a writ of habeas corpus ad testificandum in order to compel the appearance of CDCDR Inmate Quentin Carthen, North Kern State Prison as requested by Defendant Orozco.
County Defendants' witness list is attached to this Pretrial Conference Order as Exhibit B.
Defendant Orozco's witness list is attached to this Pretrial Conference Order as Exhibit C.
Each party may call a witness designated by the other.
A. No other witnesses will be permitted to testify unless:
(1) The party offering the witness demonstrates that the witness is for the purpose of rebutting evidence which could not be reasonably anticipated at the Pretrial Conference, or
(2) The witness was discovered after the Pretrial Conference and the proffering party makes the showing required in "B" below.
B. Upon the post-Pretrial discovery of witnesses, the attorney shall promptly inform the court and opposing parties of the existence of the unlisted witnesses so that the court may consider at trial whether the witnesses shall be permitted to testify. The evidence will not be permitted unless:
(1) The witnesses could not reasonably have been discovered prior to Pretrial;
(2) The court and opposing counsel were promptly notified upon discovery of the witnesses;
(3) If time permitted, counsel proffered the witnesses for deposition;
(4) If time did not permit, a reasonable summary of the witnesses' testimony was provided opposing counsel.
XI. EXHIBITS, SCHEDULES AND SUMMARIES
Plaintiff's witness list is attached to this Pretrial Conference Order as Exhibit D.
County Defendants' witness list is attached to this Pretrial Conference Order as Exhibit E.
Defendant Orozco's witness list is attached to this Pretrial Conference Order as Exhibit F.
Each party may use an exhibit designated by the other.
A. No other exhibits will be permitted to be introduced unless:
(1) The party proffering the exhibit demonstrates that the exhibit is for the purpose of rebutting evidence which could not be reasonably anticipated at the Pretrial Conference, or
(2) The exhibit was discovered after the Pretrial Conference and the proffering party makes the showing required in paragraph "B," below.
B. Upon the post-Pretrial discovery of exhibits, the attorneys shall promptly inform the court and opposing counsel of the existence of such exhibits so that the court may consider at trial their admissibility. The exhibits will not be received unless the proffering party demonstrates:
(1) The exhibits could not reasonably have been discovered prior to Pretrial;
(2) The court and counsel were promptly informed of their existence;
(3) Counsel forwarded a copy of the exhibit(s) (if physically possible) to opposing counsel. If the exhibit(s) may not be copied, the proffering counsel must show that he has made the exhibit(s) reasonably available for inspection by opposing counsel.
As to each exhibit, each party is ordered to exchange copies of the exhibit not later than fourteen (14) days before trial. Each party is then granted five (5) days to file and serve objections to any of the exhibits. In making the objection, the party is to set forth the grounds for the objection. The parties shall pre-mark their respective exhibits in accord with the Court's Pretrial Order. Exhibit stickers may be obtained through the Clerk's Office. An original and one (1) copy of the exhibits shall be presented to Harry Vine, Deputy Courtroom Clerk, at 8:30 a.m. on the date set for trial or at such earlier time as may be agreed upon. Mr. Vine can be contacted at (916) 930-4091 or via e-mail at: hvine@caed.uscourts.gov. As to each exhibit which is not objected to, it shall be marked and may be received into evidence on motion and will require no further foundation. Each exhibit which is objected to will be marked for identification only.
XII. DISCOVERY DOCUMENTS
Plaintiff's list of discovery documents (portions of deposition, interrogatories, and responses and requests for admission) they intend to use at trial is attached to this Pretrial Conference Order as Exhibit G.
County Defendants' list of discovery documents (portions of deposition, interrogatories, and responses and requests for admission) they intend to use at trial is attached to this Pretrial Conference Order as Exhibit H.
Defendant Orozco's list of discovery documents (portions of deposition, interrogatories, and responses and requests for admission) they intend to use at trial is attached to this Pretrial Conference Order as Exhibit I.
XIII. FURTHER DISCOVERY OR MOTIONS
Pursuant to the court's Status Conference Order, all discovery and law and motion was to have been conducted so as to be completed as of the date of the Pretrial Conference. That order is confirmed. The parties are free to do anything they desire pursuant to informal agreement. However, any such agreement will not be enforceable in this court.
XIV. STIPULATIONS
None.
XV. AMENDMENTS/DISMISSALS
A. Plaintiff
Plaintiff has amended the complaint on several occasions and does not anticipate seeking leave to amend it any further. Plaintiff dismissed Defendant Dr. Charles Scott from the action and does not anticipate dismissing the action as to any other Defendants.
As noted above, at the March 8 and 9, 2017 hearing on Defendants' respective motions for summary judgment, the Court dismissed the claims of then-Plaintiffs James Allison Mayfield and Terri Mayfield from the action.
B. The County Defendants
As noted above, Defendants James Lewis and Rick Pattison are dismissed, as no claims against these two defendants remain after summary judgment.
C. Defendant Orozco
All claims by Plaintiffs JAMES ALLISON MAYFIELD, JR. and TERRI MAYFIELD against Defendant Orozco are dismissed.
XVI. FURTHER TRIAL PREPARATION
A. Counsel are directed to Local Rule 285 regarding the contents of trial briefs. Such briefs should be E-filed seven (7) days prior to trial, i.e., April 24, 2017.
B. Counsel are further directed to confer and to attempt to agree upon a joint set of jury instructions. The joint set of instructions shall be lodged via ECF with the court clerk seven (7) calendar days prior to the date of the trial, i.e., April 24, 2017, and shall be identified as the "Jury Instructions Without Objection." As to instructions as to which there is dispute the parties shall submit the instruction(s) via ECF as its package of proposed jury instructions three days before trial, i.e., April 28, 2017. This package of proposed instructions should not include the "Jury Instructions Without Objection" and should be clearly identified as "Disputed Jury Instructions" on the proposed instructions.
The parties shall e-mail a set of all proposed jury instructions in word format to the Court's Judicial Assistant, Jane Klingelhoets, at: jklingelhoets@caed.uscourts.gov.
C. It is the duty of counsel to ensure that any deposition which is to be used at trial has been lodged with the Clerk of the Court pursuant to Local Rule 133(j). The depositions shall be lodged with the court clerk seven (7) calendar days prior to the date of the trial. Counsel are cautioned that a failure to discharge this duty may result in the court precluding use of the deposition or imposition of such other sanctions as the court deems appropriate.
D. The parties are ordered to E-file with the court and exchange between themselves not later than one (1) week before the trial a statement designating portions of depositions intended to be offered or read into evidence (except for portions to be used only for impeachment or rebuttal).
E. The parties are ordered to E-file with the court and exchange between themselves not later than one (1) week before trial the portions of Answers to Interrogatories and/or Requests for Admission which the respective parties intend to offer or read into evidence at the trial (except portions to be used only for impeachment or rebuttal).
F. Each party may submit proposed voir dire questions the party would like the court to put to prospective jurors during jury selection. Proposed voir dire should be submitted via ECF one (1) week prior to trial.
G. Each party may submit a proposed verdict form that the party would like the Court to use in this case. Proposed verdict forms should be submitted via ECF one (1) week prior to trial.
H. In limine motions shall be E-filed separately no later than April 14, 2017. Opposition briefs shall be E-filed no later than April 25, 2017. No reply briefs may be filed.
XVII. SETTLEMENT NEGOTIATIONS
No further formal Settlement Conference will be set in this case at this time.
XVIII. AGREED STATEMENTS
See paragraph III, supra.
XIX. SEPARATE TRIAL OF ISSUES
None. Defendants request to bifurcate this trial is denied.
XX. IMPARTIAL EXPERTS/LIMITATION OF EXPERTS
None.
XXI. ATTORNE YS' FEES
The matter of the award of attorneys' fees to prevailing parties pursuant to statute will be handled by motion in accordance with Local Rule 293.
XXII. MISCELLANEOUS
None.
XXIII. ESTIMATE OF TRIAL TIME/TRIAL DATE
The parties estimate eighteen (18) to twenty (20) court days for trial. Trial will commence on or about May 1, 2017, at 9:00 a.m.
Counsel are to call Harry Vine, Courtroom Deputy, at (916) 930-4091, one week prior to trial to ascertain the status of the trial date.
XXIV. OBJECTIONS TO PRETRIAL ORDER
Each party is granted seven (7) days from the date of this Pretrial Order to object or respond to it via ECF.
IT IS SO ORDERED.
EXHIBIT "A"
Mayfield v. Orozco, et al./Case No.: 2:13-cv-02499-JAM-AC
PLAINTIFF'S WITNESS LIST
No. Witness Name Witness Address Brief Description of Testimony
1 Avila, Ricardo Sergeant in the Jail, deposed May 3,
(Sergeant) 2016. Participated in and witnessed an
incident occurring 6/13/13 at the Jail
during which Plaintiff was forcibly
extracted by Jail custody personnel
from his cell.
2 Black, Dylan (Deputy) Deputy, deposed May 5, 2016.
Participated in and witnessed an
incident occurring 6/13/13 at the Jail,
during which Plaintiff was forcibly
extracted by Jail personnel from his
cell.
3 Brewer, Aaron Chief of Correctional Health Services
for the Sacramento County Sheriff's
Department, deposed February 10,
2016. Designated by the County as a
30 (b) (6) witness to testify concerning
contracts between Defendants UCDHS
and the County for the provision by
JPS of mental health services at the
Jail; the County's oversight of the
contracts and personnel performing
various tasks pursuant to the contracts;
the County's policies, practices,
procedures and protocols regarding
provision and administration of
medication at the Jail; the Program
Director position from the point of
view of County Health Services as it
relates to the contracts with UCDHS;
and invoicing to and payment by the
County to UCDHS for health services
provided.
4 Burton, Amy, LCSW Outpatient Clinician for JPS, deposed
September 2, 2016. Was involved in
the care and treatment, or lack thereof,
to Plaintiff; communicated with
Defendant Sokolov regarding Plaintiff;
has knowledge regarding Jail
protocols, policies and procedures and
their impact on the Plaintiff.
5 Carter, Nathaniel Salinas Valley State Prison As of the date of his deposition, an
31625 Hwy 101 inmate at Salinas Valley State Prison,
Soledad, CA 93960 deposed October 3, 2016. Witnessed
Tel: (831) 678-5500 the beating of Plaintiff by Defendant
Orozco, and has information about the
behavior of Plaintiff and the
conditions of confinement in the
pod(s) of the Jail where Plaintiff was
housed.
6 Catingub, Edgar, M.D. Chief Inpatient Psychiatrist,
Sacramento County JPS, deposed
August 10, 2016. Has knowledge
regarding: the mental health of
Plaintiff while in the Jail; the care and
treatment provided him or lack
thereof; clinical assessments of
Plaintiff and admission and discharge
summaries concerning Plaintiff;
paperwork seeking 72 hour detention
for evaluation and treatment of
Plaintiff; supervision of JPS staff
charged with providing care and
treatment to Plaintiff; communications
and meetings with Defendant Dr.
Sokolov and other mental health staff
regarding JPS and Jail protocols,
policies and procedures and their
impact on the Plaintiff.
7 Chaffin, Jennifer, M.D. P.O. Box 2570, San Ramon, CA
94583; Tel: (925) 803-7906, who
conducted a court-ordered evaluation
of Plaintiff James Joshua Mayfield and
who is likely to have information
regarding Plaintiff's mental health
while incarcerated in the Sacramento
County Jail. (Non-retained expert for
JPS)
8 Cortez, Steve, LCSW Licensed Clinical Social Worker for
JPS, deposed February 9, 2016.
Involved in the mental health
treatment, or lack thereof, provided
Plaintiff at the Jail, including
observing Plaintiff and conducting
mental health status examinations and
assessing whether Plaintiff was a
Danger to Self or Gravely Disabled on
various dates including in July and
August 2011, March and October
2012, and January 2013 and referring
Plaintiff to 2P. Cortez also testified
about Jail protocols, policies and
procedures and their impact on the
Plaintiff.
9 Cozzolino, Anthony, M.D. 614 Tully Rd, San Jose, CA 95111;
Tel: (408) 494-1561, who conducted a
mental health examination of Plaintiff
James Joshua Mayfield and who is
likely to have information regarding
Plaintiff's mental health while
incarcerated in the Sacramento County
Jail. (Non-retained expert for JPS)
10 Cully, Raylene Lieutenant, PREA Coordinator,
(Lieutenant) deposed September 8, 2016.
Designated by Defendant County as a
30 (b) (6) witness to testify concerning
County policies, procedures, practices
and protocols related to sexual assault
prevention, monitoring, handling
complaints, reporting, review and
investigation, disciplinary or
corrective action at the Jail and Prison
Rape Elimination Act; and
investigation, disciplinary and
corrective action taken regarding
incidents of violence or potential
violence or threats involving inmate
on inmate sexual assault in the Jail.
11 Damien, Deepthy, M.D. Tracy Family Practice, 730 N. Central
Avenue, Tracy, CA 95376; Tel: (209)
820-1500, who is likely to have
information regarding the mental
and/or physical health and condition.
treatment, diagnosis, prognosis, likely
future treatment and costs thereof for
Plaintiff James Joshua Mayfield,
subsequent to his release from
Sacramento County Jail.
12 Daw, Phillip (Deputy) Deputy, deposed June 2, 2016.
Designated by Defendant County as a
30 (b) (6) witness to testify concerning
the County's policies, procedures,
practices and protocols relating to:
safety and welfare checks and
custodial rounding; classification and
housing at the Jail, including for all
cells and units in which Plaintiff was
housed at any time; use of a classroom
in connection with the housing,
confinement and/or treatment of
mentally ill or potentially suicidal
inmates, including Plaintiff; inmate on
inmate violence including prevention,
monitoring, handling complaints,
reporting, review, investigation,
disciplinary or correction action; and
notification to relatives and family
regarding medical or mental health
treatment provided to persons housed
in the Jail, including informing them
of medical or mental health
emergencies.
13 Delgado, Lynn, LCSW Licensed Clinical Social Worker for
JPS, deposed February 12, 2016.
Involved in the mental health
treatment provided Plaintiff, or lack
thereof, at the Jail, including observing
Plaintiff and conducting mental health
status examinations and assessing
whether Plaintiff was a Danger to Self,
Gravely Disabled or should be on
suicide watch, on various dates
including in June 2011, May and
October 2012, and January 2013 and
referring Plaintiff to 2P. Delgado also
testified about Jail protocols, policies
and procedures and their impact on the
Plaintiff.
14 Emmanuel, Lorilene Hadsell Stormer & Renick LLP Biological mother of Plaintiff, deposed
128 N. Fair Oaks Ave. July 20, 2016. Visited and
Pasadena, CA 91104 communicated with Plaintiff while he
Tel: (626) 585-9600 was held in Jail as a pre-trial detainee,
and can testify concerning the
deterioration in her son's mental and
emotional condition.
15 Evans, Linda Hadsell Stormer & Renick LLP Aunt to Plaintiff, James Joshua
128 N. Fair Oaks Ave. Mayfield, deposed July 22, 2016. Can
Pasadena, CA 91104 testify concerning Plaintiff's behavior
Tel: (626) 585-9600 leading to his diagnosis as a paranoid
schizophrenic. Evans visited and
communicated with Plaintiff while he
was held in Jail as a pre-trial detainee,
and can testify concerning the
deterioration in her nephew's mental
and emotional condition and her
attempts to communicate her concerns
to Defendants' personnel.
16 Faidi, Anan, M.D. 930 N. Center Street, Stockton, CA
95202; Tel: (209) 948-3000, who is
likely to have information regarding
the mental and/or physical health and
condition, treatment, diagnosis,
prognosis, likely future treatment and
costs thereof for Plaintiff James
Joshua Mayfield, subsequent to his
release from Sacramento County Jail.
17 Fitch, Rachel (Deputy) Deputy, deposed February 22, 2016.
Found Plaintiff on floor of his Jail cell
7/17/13 during a cell check and
witnessed Plaintiff's statement that he
had attempted suicide by jumping
from the top bunk bed, as a result of
which Plaintiff sustained injuries
resulting in quadriplegia.
18 Fitzgerald, Marcella, LVN for JPS, deposed September 2,
LVN 2016. Has information regarding the
mental health of Plaintiff while in the
Jail, the care and treatment provided
him or lack thereof, Jail protocols,
policies and procedures, including
admission to 2P and wait lists, and
their impact on the Plaintiff.
19 Gonzalez, Benjamin Sheriff's Deputy, deposed May 5,
(Deputy) 2016, and involved in an incident
occurring 6/13/13 at the Jail, during
which Plaintiff was forcibly extracted
from his cell.
20 Grgich, Nate JPS officer, deposed September 8,
2016. Designated by Defendant
County as a 30 (b) (6) witness to
testify concerning various Topics
identified in the deposition notice:
Topics 2, 3, 9 (as it relates to out of
cell time provided inmates housed
where Plaintiff was housed in 2011
and 2013 and practices and procedures
for tracking and monitoring out of cell
time), 10, and 11 (as it relates to
placement of inmates in a classroom,
including limits on the length of
placement, whether inmates could be
housed overnight, average length of
stay, provision of mattresses or
blankets and tracking of that
information).
21 Hales, Robert, M.D. Defendant, Chair of the Department of
Psychiatry and Behavioral Services for
the University of California, Davis,
deposed February 25, 2016.
Designated by Defendant UCDHS as a
30 (b) (6) witness on its behalf.
22 Ho, Drew, MSN, FNP-C 500 San Pablo Ave., Ste. 300, Albany,
CA 94706; Tel: (510) 204-8130, who
is likely to have information regarding
the mental and/or physical health and
condition, treatment, diagnosis,
prognosis, likely future treatment and
costs thereof for Plaintiff James
Joshua Mayfield, subsequent to his
released from Sacramento County Jail.
23 Javist, Andrea, LCSW LCSW Supervisor for JPS during
relevant time period, currently
Program Director; deposed July 12,
2016. Supervised JPS mental health
staff in their provision of mental health
services to inmates of the Jail,
including Plaintiff, or lack thereof.
Communicated with Defendants
Sokolov and Hales and other JPS staff
concerning policies and procedures;
has knowledge concerning the
maintenance of a Self-Inflicted Injury
Log on which Plaintiff's name appears
and completed documentation
regarding Plaintiff's suicide attempt of
7/17/13. Has knowledge concerning
another inmate's suicide attempt on
the same day as Plaintiff's attempt.
Designated by JPS Defendants as a 30
(b) (6) witness to testify concerning
JPS's: supervision and training of staff
providing mental health care at the
Jail; oversight of the personnel
assigned to carry out each contract's
terms and conditions and oversight of
services provided; administration and
supervision of JPS services at the Jail,
including organizational structure and
supervision; formulation,
implementation and review of policies,
procedures, practices and protocols
used by JPS; and quality assurance
assessment, reporting and auditing
procedures.
24 Jones, Scott (Sheriff) Defendant, Sheriff for the County of
Sacramento, deposed August 1, 2016.
Served as Sheriff during Plaintiff's
incarceration and was the policymaker
for the County with regard to the
Sheriff's Department and ultimately
responsible for the conditions in the
Jail and the treatment of and care for
the inmates, including Plaintiff.
Personally reviewed the IA
investigations and discipline
recommendations for Defendant
Orozco's uses of force, including his
use of force against Plaintiff, and
made the final decision on what the
findings and discipline would be for
Defendant Orozco.
25 King, Michelle, M.D. Plaintiff James Joshua Mayfield's
current treating psychiatrist, San
Joaquin Mental Health, 121 N.
California Street, Stockton, CA 95220.
Plaintiff's may call Dr. King, non-retained
expert witness, concerning
her treatment of James Joshua
Mayfield. She will provide rebuttal to
the opinions expressed by Defendants'
experts as to the amount of care and/or
treatment that Plaintiff James Joshua
Mayfield would have needed for the
remainder of his life had he not
suffered the injury to his neck and/or
spine on July 17, 2013.
26 Kolb, Robin Lieutenant, deposed May 6, 2016.
(Lieutenant) Responsible for investigating the
11/22/12 incident involving Plaintiff
James Joshua Mayfield, Defendant
Ivan Orozco, Deputy Michael Pietrek
and others, occurring at the
Sacramento County Main Jail. Kolb
also investigated Defendant Orozco's
earlier use of force and testified
concerning the two internal affairs
investigations into the conduct of
Defendant Orozco.
27 Lewis, James Sacramento County Chief of
(Chief of Corrections) Corrections, deposed October 12,
2016. Served as Chief Deputy of
Corrections during Plaintiff's
incarceration. In this position, Lewis
was responsible for the conditions in
the Jail and the treatment and care for
the inmates, including Plaintiff. Lewis
reviewed the IA investigations into
Defendant Orozco's uses of force,
including his use of force against
Plaintiff, and made recommendations
for the findings and discipline that
should be given to Orozco as a result
of those incidents.
28 McNary, Jessica, LVN employed by or otherwise affiliated
with Sacramento County Jail
Psychiatric Services or other Jail or
County unit, who is likely to have
information regarding the mental
health of Plaintiff James Joshua
Mayfield while incarcerated in the
Sacramento County Jail, the care and
treatment provided him or lack
thereof, Jail protocols, policies and
procedures and their impact on the
Plaintiff.
29 McNett, Thomas, M.D. 500 W. Hospital Rd., French Camp,
CA 95231; Tel: (209) 468-6820,
affiliated with the San Joaquin General
Hospital, who conducted a mental
health examination of Plaintiff James
Joshua Mayfield and who is likely to
have information regarding Plaintiff's
mental health before his incarceration
at the Sacramento County Jail.
30 Mayes, Orlando Sergeant, Sacramento County Sheriff's
(Sergeant) Department, deposed February 10,
2016, designated by Defendant County
as a 30 (b) (6) to testify concerning
County policies, procedures, practices
and protocols as they relate to
standards, training and supervision for
use of force by staff at the Jail.
31 Mayfield, Jr., Hadsell Stormer & Renick LLP Father of Plaintiff James Joshua
James Allison 128 N. Fair Oaks Ave. Mayfield, deposed August 3, 2016.
Pasadena, CA 91104 Can testify concerning his son's
Tel: (626) 585-9600 physical, mental and emotional state
prior to and during his admission as a
pre-trial detainee at the Jail. Has
provided primary care for his son, who
lives with him and Plaintiff's step-mother
since Plaintiff's release from
the Jail in September 2013, and can
testify concerning his son's condition,
his need for round the clock care and
the nature, extent and cost of that care.
32 Mayfield, James Joshua Hadsell Stormer & Renick LLP Plaintiff, deposed July 26, 2016.
128 N. Fair Oaks Ave.
Pasadena, CA 91104
Tel: (626) 585-9600
33 Mayfield, Terri Hadsell Stormer & Renick LLP Stepmother of Plaintiff, deposed July
128 N. Fair Oaks Ave. 25, 2016. Has assisted her husband in
Pasadena, CA 91104 providing care for her stepson, who
Tel: (626) 585-9600 lives with her and Plaintiff's father
since Plaintiff's release from the Jail in
September 2013. Can testify
concerning her stepson's condition, his
need for round the clock care and the
nature, extent and cost of that care.
34 Munn, Charles, R.N. Staff Nurse, Sacramento County
Sheriff's Department, deposed
February 27, 2016. Observed Plaintiff
on the floor of his Jail cell on 7/17/13,
and witnessed Plaintiff's statement
that he had attempted suicide by
jumping from the top bunk bed.
Observed that Plaintiff was unable to
move and summoned paramedics.
Also involved in care and treatment of
Plaintiff while a pre-trial detainee in
the Jail.
35 Nakagawa, Janice, 1409 28th St., Ste. 100, Sacramento,
Ph.D. CA 95816; Tel: (916) 452-3756, who
conducted a mental health examination
of Plaintiff James Joshua Mayfield and
who is likely to have information
regarding Plaintiff's mental health
while incarcerated in the Sacramento
County Jail, the care and treatment
provided him or lack thereof, Jail
protocols, policies and procedures and
their impact on the Plaintiff.
36 Newsome, Nicholas Salinas Valley State Prison As of the date of his deposition,
31625 Hwy 101 inmate at Salinas Valley State Prison,
Soledad, CA 93960 deposed October 3, 2016. Witnessed
Tel: (831) 678-5500 the Orozco beating of Plaintiff, and
has information about the behavior of
Plaintiff and the conditions of
confinement in the pod(s) of the
Sacramento County Jail where
Plaintiff was housed.
37 Orozco, Ivan (Deputy) Defendant, Deputy, deposed March 1
& November 30, 2016. Defendant
Orozco used force against Plaintiff
during the 11/22/12 incident and used
force against another mentally ill
inmate on 12/3/11. Both of these
incidents were investigated by Internal
Affairs.
38 Pattison, Rick Sacramento County Commander of the
(Commander of the Main Jail Division, deposed May 26,
Sacramento County 2016. Served as Commander of the
Mail Jail Division) Jail during Plaintiff's incarceration. In
this position, Pattison was responsible
for the conditions in the Jail and the
treatment and care for the inmates,
including Plaintiff. Pattison reviewed
the IA investigations into Defendant
Orozco's uses of force, including his
use of force against Plaintiff, and
made recommendations for the
findings and discipline that should be
given to Orozco as a result of those
incidents.
39 Perez, Robert, Ph.D. 1777 Hamilton Ave, Ste. 2040, San
Jose, CA 95125; Tel: (408) 266-5800,
who conducted a mental health
examination of Plaintiff James Joshua
Mayfield and who is likely to have
information regarding Plaintiff's
mental health before his incarceration
at the Sacramento County Jail. (Non-retained
expert for Orozco, JPS)
40 Pham, Doan-Trinh, 1521 Bessie Avenue, Tracy, CA
DPM 95376; Tel: (209) 835-4276, who is
likely to have information regarding
the mental and/or physical health and
condition, treatment, diagnosis,
prognosis, likely future treatment and
costs thereof for Plaintiff James
Joshua Mayfield, subsequent to his
release from Sacramento County Jail.
41 Pietrek, Michael Deputy, Sacramento County Sheriff's
(Deputy) Department, deposed June 1, 2016. A
participant in aspects of the 11/22/12
incident involving Plaintiff, Defendant
Ivan Orozco and others, occurring at
the Sacramento County Main Jail.
42 Ramireddy, Salman, 730 N. Central Avenue, Tracy, CA
M.D. 95376; Tel: (209) 820-1500, who is
likely to have information regarding
the mental and/or physical health and
condition, treatment, diagnosis,
prognosis, likely future treatment and
costs thereof for Plaintiff James
Joshua Mayfield, subsequent to his
release from Sacramento County Jail.
43 Razi, Salman, M.D. 2160 W. Grantline, Ste. 140, Tracy,
CA 95377; Tel: (209) 833-3449, who
is likely to have information regarding
the mental and/or physical health and
condition, treatment, diagnosis,
prognosis, likely future treatment and
costs thereof for Plaintiff James
Joshua Mayfield, subsequent to his
release from Sacramento County Jail.
44 Roof, Jason, M.D. Associate Professor of Psychiatry for
UC Davis & Staff Psychiatrist for JPS;
deposed June 24, 2016. Provided
mental health treatment to Plaintiff at
the Jail, including completing clinical
assessments and acute inpatient
admission and discharge summaries
regarding Plaintiff; recommended
involuntary administration of
medication through utilization of the
court process and completed required
paperwork to obtain a 5250 for same;
supervised various JPS mental health
staff charged with providing treatment
to Plaintiff; communicated with
Defendants Sokolov and Hales and
other JPS mental health staff
concerning various policies and
procedures such as 2P placement and
wait lists for admission to 2P; testified
concerning Jail protocols, policies and
procedures and their impact on the
Plaintiff.
45 Rosete, Rollie, M.D. 4600 S. Tracy Avenue, Ste. 107,
Tracy, CA 95376; Tel: (209) 836-4920,
who is likely to have
information regarding the mental
and/or physical health and condition,
treatment, diagnosis, prognosis, likely
future treatment and costs thereof for
Plaintiff James Joshua Mayfield,
subsequent to his release from
Sacramento County Jail.
46 Saleem, Hala, M.D. 1811 Santa Rita Rd, Pleasanton, CA
94566; Tel: (209) 835-4043, who is
likely to have information regarding
the mental and/or physical health and
condition, treatment, diagnosis,
prognosis, likely future treatment and
costs thereof for Plaintiff James
Joshua Mayfield, subsequent to his
release from Sacramento County Jail.
47 Scott, Charles, M.D. Former defendant in this matter.
48 Scott, David, M.D. Formerly Plaintiff's treating
psychiatrist at San Joaquin County
Behavioral Health Services. 241 E.
10th St., Ste. D, Tracy, CA 95376;
Tel: (209)831-5941, who is likely to
have information regarding the mental
and/or physical health and condition,
treatment, diagnosis, prognosis, likely
future treatment and costs thereof for
Plaintiff James Joshua Mayfield,
subsequent to his release from
Sacramento County Jail. (Non-retained
expert for JPS)
49 Shahrokh, Narriman Chief Administrative Officer for the
Department of Psychiatry and
Behavioral Sciences at U.C. Davis;
deposed February 26, 2016. Shahrokh
was designated by Defendant
University of California Davis Health
Services as a 30 (b) (6) witness to
testify concerning the contract
between UCDHS and the County
regarding provision of mental health
services to the Jail, oversight of the
contract, the Program Director
position for JPS, and payment by the
County to UC Davis for the JPS
services.
50 Singer, Mike, LCSW LCSW for JPS, deposed March 9,
2016. Involved in the mental health
treatment provided Plaintiff at the Jail,
including observing Plaintiff and
conducting mental health status
examinations and assessing whether
Plaintiff was a Danger to Self or
Gravely Disabled on various dates
including August 2011, May, October
and November 2012, and referring
Plaintiff to 2P. Singer also testified
about Jail protocols, policies and
procedures and their impact on the
Plaintiff.
51 Sokolov, Gregory, M.D. Defendant and Medical Director of the
JPS, deposed June 22, 2016. Also
designated by Defendant UCDHS as a
30 (b) (6) witness on its behalf.
Sokolov was deposed as an individual,
June 27 & November 1, 2016.
52 Vizina, Rosalinda Director of Nursing for the Main Jail,
(Director of Nursing) deposed July 27 & September 20,
2017. Designated by Defendant
County as a 30 (b) (6) witness to
testify concerning the medical and
mental health care provided to
Plaintiff from the County perspective.
53 Wilson, Jeffrey Deputy, deposed May 5, 2016, who
(Deputy) was involved in an incident occurring
6/13/13 at the Jail, during which
Plaintiff was forcibly extracted from
his cell, or in investigating same.
54 Woan, Jinmei, M.D. Deposed September 7, 2016.
Plaintiff's treating neurologist
subsequent to his release from the Jail
to his parents' care, who has
information regarding Plaintiff's
condition, treatment, diagnosis,
prognosis, likely future treatment and
costs thereof for Plaintiff.
55 Yee, Ed (Lieutenant) Lieutenant, Sacramento County
Sheriff's Department, deposed May 3,
2016, designated by Defendant County
of Sacramento as a 30 (b) (6) witness
on data and information collection
regarding; suicides and suicide
attempts in the Jail; the Sheriff's
Department processes relating to staff
on inmate assaults and/or use of force
policy; procedures, policies, practices,
and protocols regarding the review and
investigation, and responses to
complaints of excessive force,
discipline and corrective action.
56 Yanez, Andrea, M.D. MS3; deposed August 31, 2016.
Testified regarding the mental health
of Plaintiff while incarcerated in the
Jail; the care and treatment provided
him or lack thereof; Jail protocols,
policies and procedures and their
impact on the Plaintiff. Completed
assessments, progress notes, admission
and discharge summaries regarding
Plaintiff across time under the
supervision of Defendant Dr. Sokolov
and other JPS mental health staff at
different points in time.
57 Custodian of Records San Joaquin County Behavioral Medical records of James Joshua
for San Joaquin County Health Services. 241 E. 10th Mayfield from San Joaquin County
Behavioral Health St., Ste. D, Tracy, CA 95376; Behavioral Health Services
Services Tel: (209) 831-5941
EXPERTS
58 Cohen, Mark Cohen/Volk Economic Consulting
Group, deposed October 21, 2016,
retained by all Defendants, will offer
testimony regarding economic
damages, interest rates and projected
inflation rates. Mr. Cohen may also
offer testimony regarding calculations
of future income reduced to present
value.
59 Gage, Bruce, M.D. Forensic psychiatric consultant,
deposed August 29, 2016, retained by
County of Sacramento who evaluated
provision of mental health care,
suicide prevention and conditions for
inmates with mental illness in
Sacramento County Jail and. Plaintiff's
intend to call Dr. Gage as a non-retained
expert witness who will
provide rebuttal to the opinions
expressed by County and UCDHS
Defendants' experts as to, among other
things: 1) the sufficiency of
Defendants' policies, procedures, and
practices for the provision of mental
health treatment and suicide
prevention at Sacramento County Jail;
and 2) the appropriateness and effects
of conditions of confinement for
persons with serious mental illness in
Sacramento County Jail.
60 Harrell, Walter, Ph.D. Hadsell Stormer & Renick LLP MediSys Rehabilitation, Inc., deposed
128 N. Fair Oaks Ave. September 29, 2016. Retained by
Pasadena, CA 91104 Plaintiff as a Life Care Plan expert
Tel: (626) 585-9600 who provided analysis and cost figures
regarding the life care needs of
Plaintiff. Dr. Harrell will also provide
rebuttal testimony on matters
addressed by Defendants' experts, Dr.
Thomas Hedge, Stacey Helvin, R.N.,
Dr. Scott Kush and Mark Cohen.
61 Hayes, Lindsay Deposed October 18, 2016. Retained
by County to offer expert testimony
regarding suicide prevention in
correctional and jail settings, the
adequacy of the suicide prevention
policies, practices and procedures
employed at the Sacramento County
Jail during Plaintiff's incarceration.
62 Hedge, Thomas, M.D. Deposed October 25, 2016, retained
by all Defendants as a Life Care Plan
expert. Testified regarding Plaintiff's
current diagnosis and prognosis and
created a Life Care Plan regarding
Plaintiff.
63 Helvin, Stacey, R.N. Quality Life Care Plans, Inc., deposed
October 5, 2016, retained by all
Defendants and provided cost data
regarding the Life Care Plan
developed by Defendants' expert, Dr.
Hedge.
64 Hislop, Jeffrey Deposed October 10, 2016, retained
by Defendant Orozco to provide
expert testimony on police and
custodial/correctional practices,
including use-of-force and working
with inmate populations, and specific
testimony regarding Orozco's actions
in this case, whether the force used
met standards and training within the
industry.
65 Kush, Scott, M.D. Life Expectancy Group, deposed
October 25, 2016, retained by all
Defendants to provide expert
testimony concerning Plaintiff's life
expectancy
66 Latorre, Juan, M.D. Hadsell Stormer & Renick LLP MediSys Rehabilitation, Inc., deposed
128 N. Fair Oaks Ave. September 30, 2016, and retained as
Pasadena, CA 91104 Plaintiff's Life Care expert, and to
Tel: (626) 585-9600 provide rebuttal testimony to
Defendants' experts Dr. Thomas
Hedge, Stacy Helvin, R.N., Dr. Gary
Vilke and Mark Cohen.
67 Ogus, Margo Hadsell Stormer & Renick LLP Deposed October 19, 2016, and
128 N. Fair Oaks Ave. designated as Plaintiff's expert
Pasadena, CA 91104 economist and as a rebuttal expert to
Tel: (626) 585-9600 any opinions expressed by
Defendants' economist, Mark Cohen.
68 Owley, Thomas, M.D. Deposed October 6, 2016. Treated
psychiatric treatment to Plaintiff while
he was being treated at Napa State
Hospital to restore mental
competency. Designated by Plaintiff
as a nonretained expert witness on
issues relating to the care provided to
Plaintiff at Napa, the
recommendations made to Defendants
upon Plaintiff's return to the Jail, and
regarding the amount of care and/or
treatment that Plaintiff would have
needed for the remainder of his life
had he not suffered the injury to his
neck and/or spine on July 17, 2013,
the need and effectiveness of various
modalities of treatment for
schizophrenia, the ability of Plaintiff
to engage in and benefit from various
modalities of treatment for
schizophrenia.
69 Patterson, Raymond, Hadsell Stormer & Renick LLP Deposed October 11, 2016.
M.D. 128 N. Fair Oaks Ave. Designated by Plaintiff as an expert
Pasadena, CA 91104 forensic psychiatrist who will testify
Tel: (626) 585-9600 concerning the mental health care and
treatment Plaintiff received in the Jail
as provided by the JPS group and
mental health staff employed or
engaged by that group, the custodial
management and housing placement
records for their potential impact on
Plaintiff's mental health care and
treatment. He will also opine on the
opinion of Defendants' expert, Dr.
Kush, regarding whether Plaintiff
would have required 24 hour care
regardless of his paraplegia because of
his schizophrenia.
70 Penn, Joseph, M.D. UTMB Correctional Managed Care,
Director, Mental Health Services,
UTMB Department of Psychiatry,
deposed November 4, 2016. Retained
by JPS Defendants to testify
concerning the mental health care
provided to Plaintiff in the Jail.
71 Schwartz, Jeffrey, Ph.D. Hadsell Stormer & Renick LLP Deposed September 27, 2016.
128 N. Fair Oaks Ave. Plaintiff's expert on use of force, law
Pasadena, CA 91104 enforcement and corrections issues in
Tel: (626) 585-9600 the Jail environment. He will testify
about the uses of force against the
Plaintiff, the Department's use of force
policies and practices, the uses of
force by Defendant Orozco against
others, Jones and the Department's
responses to Orozco's uses of force,
the use of classrooms, the County and
the Department's suicide prevention
and actions and/or inactions regarding
Plaintiff's reports that he was suicidal,
cell checks, PREA, training,
supervision and the policies and
practices at the Jail.
72 Vail, Eldon Corrections consultant retained by
County of Sacramento, who evaluated
conditions of confinement and
custodial practices in Sacramento
County Jail, including but not limited
to segregation, use of force, and
discipline relating to inmates with
mental illness. Plaintiff's intend to call
Mr. Vail as a nonretained expert
witness who will provide rebuttal to
the opinions expressed by Defendants'
experts as to, among other things: 1)
the appropriateness of conditions of
confinement for persons with serious
mental illness in Sacramento County
Jail; 2) the sufficiency of training of
Peace Officers at Sacramento County
Jail on use of force, including de-escalation
tactics; the sufficiency of
Defendants' policies, procedures, and
practices for suicide prevention at
Sacramento County Jail.
73 Vilke, Gary M., M.D. Deposed October 26, 2016. Retained
by Defendant County to testify
regarding the medical care and
treatment provided to Plaintiff, the
reasons for that treatment, the quality
of the care provided to Plaintiff,
Plaintiff's spinal cord injury and
whether that injury and resulting
paralysis could have been caused by a
jump or fall from other structures
available to Plaintiff either in his cell
and/or in the dayroom.
EXHIBIT "B"
LONGYEAR, O'DEA & LAVRA, LLP
VAN LONGYEAR, CSB NO. 84189
PETER C. ZILAFF, CSB NO. 272658
NICOLE M. CAHILL, CSB NO. 287165
3620 American River Drive, Suite 230
Sacramento, California 95864-5923
Tel: (916) 974-8500 Fax: (916) 974-8510
Attorneys for Defendants, County of Sacramento, Scott Jones,
James Lewis and Rick Pattison
UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF CALIFORNIA
Estate of JAMES JOSHUA MAYFIELD, by CASE NO. 2:13-CV-02499-JAM-AC
and through LISA BERG, as Conservator;
JAMES ALLISON MAYFIELD, JR.;
and TERRI MAYFIELD, DEFENDANTS' WITNESS LIST
Plaintiffs,
EXHIBIT "B"
vs.
IVAN OROZCO, in his individual capacity;
SHERIFF SCOTT JONES, in his individual
and official capacity; JAMES LEWIS, in his
individual and official capacity; RICK
PATTISON, in his individual and official
capacity; COUNTY OF SACRAMENTO;
UNIVERSITY OF CALIFORNIA DAVIS
HEALTH SYSTEM; DR. GREGORY
SOKOLOV, in his individual capacity; DR.
ROBERT HALES, in his individual
capacity; and Does 1-5,
Defendants.
No. Witness Name Witness Address Brief Description of
Testimony
1 Avila, Ricardo Sacramento Sheriff's Sergeant with the Department;
Department knowledge of general Jail
711 G Street procedures and supervision of
Sacramento, CA staff; interacted with Plaintiff
in June of 2013.
2 Bauer, Richard MD Main Jail Physician with CHS;
651 I Street knowledge of medical staffing
Sacramento, CA and treatment of Plaintiff in
Jail and delivery of medical
care in the Jail.
3 Black, Dylan Sacramento Sheriff's Deputy with the Department;
Department knowledge of general Jail
711 G Street procedures; interacted with
Sacramento, CA Plaintiff in June of 2013.
4 Brewer, Aron Sacramento Sheriff's County 30(b)(6) witness
Department regarding administration of
711 G Street contract between JPS and
Sacramento, CA County for mental health care.
5 Brown, Micah Deputy Sacramento Sheriff's Deputy with the Department;
Department knowledge of general Jail
711 G Street Procedures; interacted with
Sacramento, CA Plaintiff in June of 2013.
6 Cully, Raylene Sacramento Sheriff's Lieutenant with the
Department Department; County 30(b)(6)
711 G Street witness regarding PREA and
Sacramento, CA inmate-on-inmate assault.
7 Daw, Phillip Sacramento Sheriff's Deputy with the Department;
Department knowledge of general Jail
711 G Street procedures; knowledge of
Sacramento, CA classification process and
protocols.
8 Evans, Linda C/O Hadsell, Stormer, Plaintiff's aunt; can testify as
Renick to current treatment of Plaintiff
128 N. Fair Oaks Ave. and medical/mental health of
Pasadena, CA Plaintiff prior to incarceration.
9 Fitch, Rachel Sacramento Sheriff's Deputy with the Department;
Department on duty at the Jail when
711 G Street Plaintiff was injured on July
Sacramento, CA 17, 2013 and was the first to
discover he was injured;
knowledge of general practices
and policies for the Jail.
10 Gonzales, Benjamin Sacramento Sheriff's Deputy with the Department;
Department interacted with Plaintiff in
711 G Street June of 2013; knowledge of
Sacramento, CA general Jail procedures.
11 Grgich, Nathaniel Sacramento Sheriff's Deputy with the Department;
Department deposed as County 30(b)(6)
711 G Street witness regarding suicide
Sacramento, CA training and procedures;
knowledge of general
operations of the Jail;
witnessed behavior by Plaintiff
on several occasions.
12 Hales, Robert, M.D. c/o Wilke Fleury Defendant, Chair of the
400 Capitol Mall, 22nd Department of
Floor, Sacramento, CA Psychiatry and Behavioral
98831. Services for the University of
California, Davis, deposed
February 25, 2016.
Designated by Defendant
UCDHS as a 30 (b) (6) witness
on its behalf. Dr. Hales will
testify about the contours of
the JPS program, the policies,
procedures and practices of
JPS, the budgetary constraints
on JPS operations beginning in
2009 and the impact on the
delivery of JPS services after
budget cuts in 2009. Dr. Hales
will also testify about his
knowledge and involvement in
JPS quality improvement
generally, and specifically with
respect to the QI review of the
incident relating to plaintiffs'
injury on July 17, 2013.
13 Harris, B. Deputy Sacramento Sheriff's Sergeant on duty during
(#2366) Department physical altercation between
711 G Street Plaintiff and Deputy Orozco
Sacramento, CA on November 22, 2012.
13 Hoertsch, K. Sgt. (#170) Sacramento Sheriff's Sergeant on duty during
Department physical altercation between
711 G Street Plaintiff and Deputy Orozco
Sacramento, CA on November 22, 2012.
15 Hufford, Scott Sacramento Sheriff's Sergeant at the Jail;
Department information regarding general
711 G Street Jail operations and supervision
Sacramento, CA of deputies.
16 Kayode, Idowu LVN Main Jail Nurse at the Jail, has
651 I Street knowledge of incident
Sacramento, CA involving physical altercation
between Plaintiff and Deputy
Orozco on November 22,
2012.
17 Kolb, Robin Sacramento Sheriff's Former IA investigator with
Department the Department; knowledge of
711 G Street Internal Affairs investigation
Sacramento, CA regarding Deputy Orozco.
18 Lewis, James Longyear, O'Dea & Lavra Defendant, Chief Deputy of
3620 American River Corrections, Court Services,
Drive and Civil Division during
Suite 230 portions of Plaintiff's
Sacramento, CA incarceration; Undersheriff of
the Department; knowledge of
jail policies, procedures,
practices; participated in
review of altercation between
Plaintiff and Deputy Orozco
on November 22, 2012;
knowledge of provision and
administration of mental health
care in the Jail.
19 McAuliffe, D. Sgt. (#63) Sacramento Sheriff's Sergeant on duty during
Department physical altercation between
711 G Street Plaintiff and Deputy Orozco
Sacramento, CA on November 22, 2012.
20 Mayes, Orrlando Sacramento Sheriff's Deposed as County 30(b)(6)
Department witness regarding training,
711 G Street policies, procedures, and
Sacramento, CA practices for the Department.
21 Mayfield, James Alison C/O Hadsell, Stormer, Plaintiff's father; can testify as
Renick to current treatment of Plaintiff
128 N. Fair Oaks Ave. and medical/mental health of
Pasadena, CA Plaintiff prior to incarceration.
22 Mayfield, Terri C/O Hadsell, Stormer, Plaintiff's step-mother; can
Renick testify as to current treatment
128 N. Fair Oaks Ave. of Plaintiff and medical/mental
Pasadena, CA health of Plaintiff prior to
incarceration.
23 Mencias, Gladys Main Jail Current director of nursing,
651 I Street replaced Rosalinda Vizina;
Sacramento, CA knowledge of nursing
procedures and general
operation of medical staff in
the Jail and delivery of medical
care to the Plaintiff,
24 Munn, Charles Main Jail Nurse at Main Jail; responded
651 I Street to Plaintiff's cell on July 17,
Sacramento, CA 2013; knowledge of nursing
procedures and general
operation of medical staff in
the Jail and delivery of medical
care to the Plaintiff.
25 Nugent, Grant MD Main Jail Physician with CHS;
651 I Street knowledge of medical staffing
Sacramento, CA and treatment of Plaintiff in
Jail and delivery of medical
care in the Jail.
26 Orozco, Ivan C/O Porter Scott Deputy at the Jail, involved in
350 University Avenue a physical altercation with
Suite 200 Plaintiff on November 22,
Sacramento, CA 2012.
27 Pattison, Richard Longyear, O'Dea & Lavra Defendant, Commander of the
3620 American River Jail during a large portion of
Drive Plaintiff's incarceration;
Suite 230 knowledge of jail policies,
Sacramento, CA procedures, practices;
participated in review of
altercation between Plaintiff
and Deputy Orozco on
November 22, 2012.
28 Pietrek, Michael Sacramento Sheriff's Deputy at the Jail, operated
Department control booth in 8W when
711 G Street altercation between Deputy
Sacramento, CA Orozco and Plaintiff occurred
on November 22, 2012
29 Steed, R. Sgt. (#92) Sacramento Sheriff's Sergeant on duty during
Department physical altercation between
711 G Street Plaintiff and Deputy Orozco
Sacramento, CA on November 22, 2012.
30 Sokolov, Gregory, M.D. c/o Wilke Fleury Defendant and Medical
400 Capitol Mall, 22nd Director of the
Floor, Sacramento, CA JPS, deposed June 22, 2016.
98831. Also designated by Defendant
UCDHS as a 30 (b) (6) witness
on its behalf. Sokolov was
deposed as an individual, June
27, 2016 & November 1, 2016.
30 Vizina, Rosalinda 3405 Deer Park Drive SE Deposed as County 30(b)(6)
Salem, Oregon 97310-9385 witness regarding medical care
provided to Plaintiff; former
director of nursing; has
information regarding general
nursing procedures in the Jail.
31 Wilson, Jeffrey Sacramento Sheriff's Deputy with the Department;
Department knowledge of general Jail
711 G Street procedures; interacted with
Sacramento, CA Plaintiff in June of 2013.
32 Yee, Ed Sacramento Sheriff's Deposed as County 30(b)(6)
Department witness regarding Internal
711 G Street Affairs procedures, suicide
Sacramento, CA statistics; current Assistant
Commander of the Main Jail
and has information regarding
general jail procedures and
operations.
Experts
33 Cohen, Mark C/O Wilke Fleury Will offer testimony in
400 Capitol Mall, 22nd accordance with deposition
Floor testimony and Rule 26 report
Sacramento, CA regarding future economic
damages.
34 Hayes, Lindsay Longyear, O'Dea & Lavra Will offer testimony in
3620 American River accordance with deposition
Drive testimony and Rule 26 report;
Suite 230 suicide prevention expert.
Sacramento, CA
35 Hedge, Thomas C/O Wilke Fleury Will offer testimony in
400 Capitol Mall, 22nd accordance with deposition
Floor testimony and Rule 26 report;
Sacramento, CA physiastrist and physical
medicine specialist.
36 Helvin, Stacy C/O Wilke Fleury Will offer testimony in
400 Capitol Mall, 22nd accordance with deposition
Floor testimony and Rule 26 report;
Sacramento, CA life care planner.
37 Kush, Scott C/O Wilke Fleury Will offer testimony in
400 Capitol Mall, 22nd accordance with deposition
Floor testimony and Rule 26 report;
Sacramento, CA life expectancy expert.
38 Penn, Joseph, M.D. UTMB Correctional Will offer testimony in
Managed Care accordance with deposition
200 River Pointe Drive, testimony and Rule 26 report;
Ste 200, Conroe, TX psychiatrist.
77304
39 Vilke, Gary Longyear, O'Dea & Lavra Will offer testimony in
3620 American River accordance with deposition
Drive testimony and Rule 26 report;
Suite 230 emergency medicine specialist.
Sacramento, CA
Dated: March 24, 2017 LONGYEAR, O'DEA & LAVRA, LLP
By: ______________________________
VAN LONGYEAR
PETER C. ZILAFF
NICOLE M. CAHILL
Attorneys for Defendants
County of Sacramento, Scott Jones,
James Lewis and Rick Pattison
EXHIBIT "C"
DEFENDANT IVAN OROZCO'S WITNESS LIST
EXHIBIT "C"
No. Witness Name Witness Address Brief Description
1. Carter, Nathanial Salinas Valley State Prison Mr. Carter is a percipient
31625 Highway 101 witness to November 12, 2012
Soledad, CA 93960 incident.
2. Carthen, Quentin North Kern State Prison Mr. Carthen is a percipient
2737 W. Cecil Avenue witness to November 12, 2012
Delano, CA 93216-0567 incident.
3. Catingub, Edgar Dr. Wilke, Fleury, Hoffelt, Gould & Dr. Catingub has knowledge of
Birney, LLP Plaintiff's mental status prior to
400 Capitol Mall, 22nd Fl the subject incident.
Sacramento, CA 95814
4. Chueh, Colleen RN Longyear, O'Dea & Lavra, LLP Ms. Cheueh is the immediate
3620 American River Dr # 230 treating nurse after the
Sacramento, CA 95864 November 12, 2012 incident
and a percipient witness.
5. Cortez, Steve Wilke, Fleury, Hoffelt, Gould & Mr. Cortez has knowledge of
Birney, LLP Plaintiff's mental status prior to
400 Capitol Mall, 22nd Fl the subject incident.
Sacramento, CA 95814
6. Delgado, Lynn Wilke, Fleury, Hoffelt, Gould & Ms. Delgado has knowledge of
Birney, LLP Plaintiff's mental status prior to
400 Capitol Mall, 22nd F1 the subject incident.
Sacramento, CA 95814
7. Emmanuel, Lorilene Ms. Emmanuel has knowledge
of Plaintiff's mental status prior
to the subject incident.
8. Godfrey, Erin Marie 711 G Street Deputy Godfrey is a percipient
Dpt. Sacramento, CA 95814 witness to November 12, 2012
incident.
9. Harris, Brendan Dpt. 711 G Street Deputy Harris is a percipient
Sacramento, CA 95814 witness to November 12, 2012
incident.
10. Hislop, Jeffrey 2805 Rockford Avenue Retained expert by Defendant
Stockton, CA 95207 Ivan Orozco.
11. Hoertsch, R. Sgt. 711 G Street Sergeant Hoertsch is a
Sacramento, CA 95814 percipient witness to November
12, 2012 incident immediately
after Plaintiff was in restraints.
12. Kayode, Idowu 320 Bill Bean Circle Ms. Kayode is a percipient
Biola, LVN Sacramento, CA 95825 witness to November 12, 2012
incident.
13. Kolb, Robin, Lt. 711 G Street Lieutenant Kolb conducted
Sacramento, CA 95814 post incident interview with
Plaintiff.
14. Lopes, J., Dpt. 711 G Street Deputy Lopes took
Sacramento, CA 95814 photographs.
15. McAullife, D., Dpt. 711 G Street Deputy McAullife is a
Sacramento, CA 95814 percipient witness to November
12, 2012 incident immediately
after Plaintiff was in restraints.
16. Medina, G., Dpt. 711 G Street Deputy Medina is a percipient
Sacramento, CA 95814 witness to statement of Plaintiff
to Deputy Orozco.
17. Newsome, Nicholas Salinas Valley State Prison Mr. Newsome is a percipient
U.S. Highway 101 witness to November 12, 2012
Soledad, CA 96960 incident.
18. Nugent, Grant, Dr. Longyear, O'Dea & Lavra, LLP Dr. Grant has knowledge of
3620 American River Dr. # 230 Plaintiff's mental status after
Sacramento, CA 95864 incident.
19. Orozco, Ivan Porter Scott Deputy Orozco is a percipient
350 University Avenue, Ste 200 witness to the November 12,
Sacramento, CA 95825 2012 incident.
20. Pietrek, Michael, 711 G Street Deputy Pietrek is control room
Dpt. Sacramento, CA 95814 deputy and was present at post
incident interview.
21. Roof, Jason, Dr. Wilke, Fleury, Hoffelt, Gould & Dr. Roof is a psychiatrist and
Birney, LLP has knowledge of Plaintiff's
400 Capitol Mall, 22nd F1 mental status prior to incident.
Sacramento, CA 95814
22. Singer, Mike Wilke, Fleury, Hoffelt, Gould & Mr. Singer has knowledge of
Birney, LLP Plaintiff's mental status prior to
400 Capitol Mall, 22nd F1 incident.
Sacramento, CA 95814
23. Steed, R., Sgt. 711 G Street Sergeant Steed is a percipient
Sacramento, CA 95814 witness to November 12, 2012
incident immediately after
Plaintiff was in restraints.
24. Wood, S., Dpt. 711 G Street Deputy Wood is a percipient
Sacramento, CA 95814 witness to statement of Plaintiff
to Deputy Orozco.
EXHIBIT "D"
PLAINTIFF'S EXHIBIT LIST1
EXHIBIT "D"
Exh. Description Bates No(s). Intro. by Admitted
ID
1. Subpoena to Testify at a Deposition in a n/a
Civil Action to Steve Cortez, LCSW, dated
January 19, 2016
2. University of California, Davis ("UC JPS 59099-59117
Davis") Outpatient Services Staff Payroll
Attendance logs, dated September 2006-February
2008
3. UC Davis Medical Center Sacramento Jail JPS 59136-59147
Psychiatric Services ("JPS") Staff Payroll
Attendance logs, various dates 2008
4. Security Standby-Access Needs for RCCC JPS 59151-59154
JPS; JPS Staff Payroll Attendance logs,
various dates 2008
5. JPS, Outpatient Schedule, dated February 3, JPS 59214-59216
2013-March 2, 2013
6. JPS Organizational Chart Prior to JPS 58160-58165
September 2011
7. JPS Organizational Chart Prior to Sept JPS 56558-56560
2011, dated September 7, 2011
8. JPS Outpatient Progress Note re: James JPS 50771-50773
Mayfield, dated July 11, 2011
9. JPS Outpatient Progress Note re: James JPS 50759-50760
Mayfield, dated August 8, 2011
10. JPS Telephone Referral and After Hours JPS 50727-50730
Referral/Contact re: James Mayfield, dated
January 6, 2012
11. JPS Outpatient Progress Note re: James JPS 50707-50712
Mayfield, dated March 23, 2012
12. Sacramento County Sheriff's Department JPS 50082-50085
Correctional Health Services patient care
log re: James Mayfield, dated March 7-24,
2012
13. JPS Clinical Assessment re: James JPS 50515-50518
Mayfield, dated October 23, 2012
14. JPS Clinical Assessment re: James JPS 50458-50465
Mayfield, dated January 14, 2013
15. Sacramento County Sheriff's Department JM 0231-0232
Correctional Health Services patient care
log re: James Mayfield, dated January 3-15,
2013
16. Incident Report Narrative (PF10) ORZ 00084
re: James Mayfield, Report #0960304630,
dated January 14, 2013
17. Incident Report Narrative (PF10) re: ORZ 00085
James Mayfield, Report # 0960304631,
dated January 22, 2013
18. JPS, Physician's Orders and Medication re: JM 0311-0317
James Mayfield, dated June 13, 2016
19. Sacramento County Sheriff's Department JPS 50012-50015
Correctional Health Services patient care
log re: James Mayfield, dated June 9-17,
2013
20. Timeline for Patient X, ref 3952662, JPS 58877-58872
various dates
21. JPS CQI Report 4th Quarter 2012, Main Jail JPS 58868-58872
Out Patient High Risk Follow-up
22. JPS Organizational Charts, dated 2012-2015 JPS 56560,
2015 JPS 56562,
JPS 56553,
JPS 56550
23. Plaintiff James Joshua Mayfield's Notice of n/a
the Deposition of Defendant County of
Sacramento (FRCivP Rule 30(b)(6)), dated
December 16, 2016
24. Agreement between the County of JPS 56607-56626
Sacramento and Regents of the University
of California re: JPS, dated July 1, 2013-June
30, 2014
25. Agreement between the County of JPS 56627-56650
Sacramento and Regents of the University
of California for JPS, dated July 1, 2012 to
June 30, 2013
26. Sheriff's Department, County of CO_002447-CO_002450
Sacramento General Order re: Use of Force
Policy (rev 12/13)
27. Appendix A to Use of Force Policy (rev CO_002599
12/13)
28. Advanced Officer Training Arrest Control CO_002568-CO_002598
2012/2013, Authoritative Sources to Use of
Force presentation
29. Sacramento County Sheriff's Department, CO_002616-CO_002641
Defensive Tactics: Takedowns/Distractions
presentation
30. INTENTIONALLY LEFT BLANK ---
31. Subpoena to Testify at a Deposition in a n/a
Civil Action to Lynn Delgado, dated
January 20, 2016
32. JPS Organizational Chart, dated September JPS 56555-56559
7, 2011
33. JPS-Initial Clinical Assessment re: James JPS 50756-50758
Mayfield, dated June 21, 2011
34. JPS Acute Inpatient Unit Discharge JPS 50623-50626
Summary re: James Mayfield, dated May
16, 2012
35. Mental Status Examination re: James JPS 50627
Mayfield, dated May 10, 2012
36. JPS-Suicide Assessment re: James JPS 50628-50630
Mayfield, dated May 9, 2012
37. Sacramento County Sheriff's Department JPS 50063-50065
Correctional Health Services patient care
log re: James Mayfield, May 10-13, 2012
38. Application for 72-Hour Detention For CO_000288-CO_000289
Evaluation And Treatment of James
Mayfield, dated May 10, 2012
39. UC Davis, JPS Informed Consent for CO_000287
Treatment with Psychotropic Drugs for
James Mayfield, dated May 11, 2012
40. Incident Report Detail (PF10) re: James ORZ 00096-ORZ 00097
Joshua Mayfield, Report Number
0960304625, dated October 14, 2012
41. Incident Report Detail (PF10) re: James ORZ 00094-ORZ 00095
Joshua Mayfield, Report Number
0960304626, dated October 15, 2012
42. JPS Clinical Assessment re: James JPS 50527-50530
Mayfield, dated October 15, 2012
43. JPS Clinical Assessment re: James JPS 50535-50538
Mayfield, dated October 14, 2012
44. Email from Schaffer Psychiatry to Bret CO_000238-CO_000247
Butler re: James Mayfield, dated October
17, 2012
45. Sacramento County Sheriff's Department JPS 50044-50046
Correctional Health Services patient care
log re: James Mayfield, October 13-November
7, 2012
46. JPS Telephone Referral & Contact re: CO_000170
James Mayfield, dated January 22, 2012
47. JPS Clinical Assessment re: James JPS 50437-50441
Mayfield, dated January 22, 2013
48. Sacramento County Sheriff's Department JPS 50034-50036
Correctional Health Services patient care
log re: James Mayfield, January 15-24,
2015
49. Department of Psychiatry Jail Psychiatric JPS 56547-56549,
Service Organizational Charts, various JPS 56561,
dates JPS 56558,
JPS 56560,
JPS 56562,
JPS 56550
50. University of California Map Program JPS 56837
Position Description for Gregory Sokolov,
Associate Physician, dated October 9, 2003
51. Letter from Edward Callahan, Ph.D. to JPS 56901-56904
Robert Hales, M.D., dated January 1, 2013
52. Letter from Edward Callahan, Ph.D. to JPS 56916-56918
Bruce White, Ph.D., dated October 15, 2007
53. Curriculum Vitae of Charles L. Scott, M.D. n/a
54. Declaration of Charles Scott, M.D. in n/a
Support of Defendants' Opposition to
Plaintiffs' Motion Related to the Housing
and Treatment of Mentally Ill Prisoners in
Segregation in Ralph Coleman, et al. v.
Edmund G. Brown, Jr., et al., Case No.:
2:90-CV-00520 LKK JFM PC, dated July
24, 2013
55. Plaintiff James Joshua Mayfield's Amended n/a
Notice of the Deposition of Registered
Nurse Charles Munn, dated February 3,
2016
56. Sacramento County Sheriff's Department JM 2309-2318
Report re: attempted suicide of James
Mayfield, dated July 17, 2013
57. Incident Report Detail (PF10) re: James CO_000831-CO_000833
Joshua Mayfield, Report Number
0960304640, dated July 17, 2013
58. Sacramento County Sheriff's Department CO_000007-CO_00008
Correctional Health Services patient care
log re: James Mayfield, July 8-25, 2013
59. Sacramento County Sheriff Department, CO_002662
Correctional Health Services, Supervisor's
Communication Log, dated August 7, 2013
60. Self-Inflicted Injury Log, June 11, 2013-August, JPS 60162-60176
5, 2015
61. Sacramento County Sheriff Department, CO_002668
Correctional Health Services, Flex Nurse
Shift Report, dated March 22, 2012
62. Sacramento County Sheriff Department, CO_002650
Shift log for Charles Munn, R.N., dated
July 24-25, 2013
63. Sacramento County Sheriff's Department JPS 50138,
Medication Administration Report for JPS 50149,
James Mayfield, various dates between JPS 50556,
June 2 & December 1, 2012 JPS 50181,
JPS 50547;
CO_001855;
JPS 50507,
JPS 50492,
JPS 50210
64. Sacramento County Sheriff's Department JPS 50053
Correctional Health Services patient care
log re: James Mayfield, August 4-24, 2012
65. Sacramento County Sheriff's Department JPS 50057-50058
Correctional Health Services patient care
log re: James Mayfield, May 29-June 11,
2012
66. • Sacramento County Sheriff's JPS 50513,
Department Medication Administration JPS 50044;
Report, dated October 24-26, 2012 JM 0796
• Sacramento County Sheriff's
Department Correctional Health
Services patient care log re: James
Mayfield, dated October 21-November
7, 2012
• Refusal of medical services, dated
October 25, 2012
67. • Sacramento County Sheriff's JPS 50207,
Department Medication Administration JPS 50043;
Report, November 20-22, 2013 JM 0768
• Sacramento County Sheriff's
Department Correctional Health
Services patient care log re: James
Mayfield, dated November 9-22, 2012
• Refusal of medical services, dated
November 22, 2012
68. • Sacramento County Sheriff's JPS 50366,
Department Medication Administration JPS 50017;
Report, May 12-14, 2013 JM 0547
• Sacramento County Sheriff's
Department Correctional Health
Services patient care log re: James
Mayfield, dated April 18-May 21, 2013
• Refusal of medical services, dated May
13, 2013
69. Plaintiff James Joshua Mayfield's Notice of n/a
the Deposition of Deputy Rachel Fitch,
dated February 3, 2016
70. Housing Unit/ Work Station logs, dated CO_000535-CO_000541
July 16-17, 2013
71. Sacramento Sheriff's Department RMS CO_001560-CO_001571
Incident Report re: attempted suicide of
James Mayfield, dated July 17, 2013
72. Sacramento County District Attorney's JM 2308
Office, Jail Incident Report re: attempted
suicide of James Mayfield, dated July 17,
2013
73. Sacramento County Sheriff's Department JM 0482
Correctional Health Services Refusal of
medical services, dated July 16, 2013
74. UCDHS, Department of Psychiatry, Quality JPS 58998-59019
Improvement Committee Minutes, various
dates between September 6, 2012 and
December 12, 2013
75. UC Davis, JPS CQI 1st Quarter 2012-4th JPS 58850-58873
Quarter 2012 reports on Service request
time frame, Outpatient High Risk Followup,
Self-inflicted Injury Report 1st Quarter
2012
76. County of Sacramento Behavioral Health n/a
Services JPS Chart reviews, dated
September 2, 2011, August 7, 2012, and
August 5, 2013
77. JPS Statistics 2013-2014 JPS 60192
78. JPS Policy and Procedure Manual, Policy JPS 58041
#1041 — Medical Director Consult List
(Prior to 2P Admission), effective date:
June 12, 2006, revision date: October 24,
2008
79. JPS Policy and Procedure Manual, Policy JPS 57575
#1010 — Safety Suit Procedures, effective
date: April 28, 1995, revision date:
October 21, 2008
80. JPS Policy and Procedure Manual, Policy JPS 59387-59389
#805 — Discharges, Acute Inpatient Unit to
General Population, effective date: April
28, 1995, revision dates: October 22, 2007
& November 18, 2013
81. Sacramento County Sheriff's Department ORZ 000761-ORZ 000765
Performance Evaluation Report for Ivan C.
Orozco, dated September 6, 2009-January
15, 2012 (Confidential)
82. County of Sacramento Inter-Department ORZ 000154-ORZ 000176
Correspondence
to Lieutenant Russ Munn from Sergeant
Robin Kolb re: Interview With Deputy
Orozco, 2012IA-058, dated February 20,
2013 (Confidential)
83. Sacramento County Sheriff's Department ORZ 0001235-ORZ 0001250
Main Jail Division Incident Report No.:
MJD 2012-0261775, re: battery of James
Joshua Mayfield by Ivan Orozco and dated
November 22, 2012 (Confidential)
84. County of Sacramento Inter-Department ORZ 00038-ORZ 00051
Correspondence
to Lieutenant Russ Munn from Sergeant
Robin Kolb re: Case Summary; Internal
Affairs Investigation 2012IA-058, dated
January 8, 2013 (Confidential)
85. Professional Standards Division ORZ 00023-ORZ 00035
Administrative Investigation 2012IA-058 of
Deputies Ivan Orozco & Michael Dietrek,
dated April 3, 2013 and February 28, 2013 n/a
86. Video footage of the November 22, 2012
beating of James Joshua Mayfield by
Deputy Ivan Orozco (DVD-8W below TV)
87. Video footage of the November 22, 2012 n/a
beating of James Joshua Mayfield by
Deputy Ivan Orozco (DVD-8W Indoor Rec)
88. State of California Department of Industrial ORZ 0001228-ORZ 0001234
Relation Workers' Compensation Claim
Form for Ivan Orozco, dated March 1, 2013
89. Sheriff's Department County of Sacramento ORZ 01658-ORZ 01661
Operations Order — Mentally Disturbed
Person — 5150 Welfare and Institutions
Code, dated 07/11 (rev 1/04)
90. Sheriff's Department County of Sacramento ORZ 01664-ORZ 01667
Operations Order — Health Care Services,
10/01 (rev 7/07)
91. Sheriff's Department County of Sacramento ORZ 000254-ORZ 000260
Operations Order — Use of Force, 10/01
(rev 7/07)
92. Sheriff's Department County of Sacramento ORZ 01566-ORZ 01570
Operations Order — Use of Force, dated
2/01 (rev 8/15)
93. Supervising Inmates — Module 13.1 CO_002825-CO_002830
Sacramento County Sheriff's Department,
PowerPoint presentation
94. Sacramento County Sheriff's Department ORZ 0001407-ORZ 0001409
Midterm Evaluation of Ivan Orozco, dated
October 10, 2007
95. Sacramento County Sheriff's Department ORZ 0001312-ORZ 0001313
Basic Training Academy Arrest Control
Techniques Quiz, taken by Ivan Orozco,
dated August 9, 2007
96. File named "CSI Photos," containing n/a
photos of Ivan Orozco & James Mayfield,
following the November 22, 2012 incident,
produced by Defendant Orozco September
4, 2015
(DVD)
97. Subpoena to Testify at a Deposition in a n/a
Civil Action to Mike Singer, CSW, dated
February 12, 2016
98. UC Davis JPS Outpatient Schedule, various JPS 59213-59214,
dates JPS 59168,
JPS 59171,
JPS 59179
99. Incident Report Detail (PF10) re: James CO_000799-CO_000800
Mayfield, Report Number 0957915609,
dated August 15, 2011
100. Sacramento County/UCDMC JPS JPS 50751
Outpatient Progress Record, dated August
15, 2011
101. Sacramento County Sheriff's Department CO_000096-CO_000098
Correctional Health Services patient care
log re: James Mayfield, August 2-18, 2011
102. Mental Status Examination of James CO_000273
Mayfield, dated May 9, 2012
103. Incident Report Detail (PF10) re: James CO_000746-CO_000750
Joshua Mayfield, Report Number
0960304614, dated May 9, 2012
104. Incident Report Detail (PF10) re: James CO_000744-CO_000745
Joshua Mayfield, Report Number
0960304615, dated May 9, 2012
105. JPS Clinical Assessment, dated October 13, CO_000247-CO_000250
2012
106. Incident Report Detail (PF10) re: James CO_000880-CO_000881
Joshua Mayfield, Report Number
0960304624, dated October 13, 2012
107. Sacramento County Sheriff's Department CO_000045-CO_000047
Correctional Health Services patient care
log re: James Mayfield, dated September
29-October 17, 2012
108. Sacramento County Sheriff's Department CO_000043
Correctional Health Services patient care
log re: James Mayfield, dated November 9-22,
2012
109. JPS Clinical Assessment re: James CO_000225-CO_000228
Mayfield, dated November 15, 2012
110. Incident Report Detail (PF10) re: James CO_000874-CO_000875
Joshua Mayfield, Report Number
0960304627, dated November 15, 2012
111. Review of in Custody death of Robert JPS 58363
Leiske, dated October 7, 2004
112. Plaintiff James Joshua Mayfield's Notice of n/a
the Deposition of Sergeant Avila (#57),
dated April 8, 2016
113. Subpoena to Testify at a Deposition in a n/a
Civil Action to Sergeant Avila (#57), dated
April 15, 2016
114. Sacramento Sheriff's Department Open Job CO_003602-CO_003603
Announcements for:
1) Sheriff Sergeant — Narcotic
Sergeant/HIDTA (SAINT) Supervisor CO_003600-CO_003601
Impact Division, February 26, 2016; and
2) Sheriff Sergeant — People Crimes Bureau
Detective Sergeant Centralized
Investigations Division, open date March
23, 2015
115. Video footage of James Mayfield's cell CO_3485
extraction on XX DATE
116. Sheriff's Department County of Sacramento CO_001180-CO_001188
Operations Order, Custody Emergency
Response Team (C.E.R.T.) and Cell
Extraction Procedures, 2/05 (rev 8/12)
117. JPS Acute Inpatient Unit Discharge CO_000102-CO_000104
Summary, dated June 25, 2013
118. Incident Report Detail (PF10) re: James CO_003499-CO_003504
Joshua Mayfield, dated June 14, 2013
119. Custody Emergency Response Team CO_002756-CO_002760
(C.E.R.T.) and Cell Extraction Training,
PowerPoint presentation
120. Lieutenant Yee assignment history report n/a
from Sacramento Sheriff's Department
employee database, printed May 3, 2016
121. Plaintiff James Joshua Mayfield's Amended n/a
Notice of the Deposition of Defendant
County of Sacramento, (Fed. R. Civ. P.
Rule 30(b)(6)), Designee Lieutenant Lee,
dated April 8, 2016
122. Charts of Inmate Suicides/Attempts in the CO_003505-CO_003546
Sacramento County Jail, 2001-2015
123. Suicide Prevention Task Force Action CO_003395-CO_003401
Summary, date October 30, 2002
124. Handwritten document by deponent, n/a
Lieutenant, Ed Yee, May 3, 2016
125. Sheriff Sacramento County Suicide CO_001284-CO_001298
Prevention Training presentation by Deputy
Nate Grgich, Main Jail Division, dated
March 2013
126. Sheriff's Department County of CO_001113-CO_001118
Sacramento, Operations Order Suicide
Prevention Program, 10/5 (rev 7/07)
127. Sheriff's Department County of CO_003427-CO_003438
Sacramento, Operations Orders, Death or
Serious Injury of a Prisoner, 3/10 (Rev
6/08), 3/10 (Rev 2/2010) and 3/10 (Rev CO_001036-CO_001049
4/14)
CO_003439-CO_003451
128. Sheriff's Department County of Sacramento CO_003452-CO_003459
General Order, Internal Affairs/Divisional
Investigations Procedures: Interrogations,
Interviews, and Directed Reports, 3/02 (rev CO_003416-CO_003426
6/07), 3/02 (rev 4/09), and 3/02 (rev 3/15)
CO_003410-CO_003415
129. Sheriff's Department County of CO_003402-CO_003409
Sacramento, General Order, Complaints
and Disciplinary Policies and Procedures,
3/01 (rev 6/15)
130. Sheriff's Department County of Sacramento CO_001127-CO_001133
Operations Orders, Use of Force, 2/01 (rev
7/07) and 2/01
(rev 1/14) CO_001032
CO_001035
131. Sheriff's Department County of Sacramento ORZ 002296-ORZ 002300
General Order, Use of Force, 2/11 (rev
3/98)
132. Sheriff's Department County of Sacramento CO_01189-CO_001193
General Orders, Use of Force Policy, 2/11
(rev 2/12) and 2/11 (rev 12/13)
CO_002447-CO_002450
133. Use of Force — Weapons chart, 2011 CO_003461-CO_003484
134. Case Routing Process chart, undated CO_003460
135. Documents produced by Lieutenant Yee at Various un Bates-stamped
his deposition, May 3, 2016 and
Bates-stamped
documents
136. Subpoena to Testify at a Deposition in a n/a
Civil Action to Deputy Black (#2551)
137. Subpoena to Testify at a Deposition in a n/a
Civil Action to Deputy Wilson (#2609)
138. Subpoena to Testify at a Deposition in a n/a
Civil Action to Deputy Gonzales (#2578)
139. Plaintiff James Joshua Mayfield's Notice of n/a
the Deposition of Sergeant Robin Kolb,
dated April 8, 2016
140. Sacramento Sheriff's Department Open Job CO_003592-CO_003593
Announcement for Sheriff Sergeant
Detective — Internal Affairs Investigator
Internal Affairs Bureau, Open Date: April
6, 2011
141. Case Routing Process chart, undated CO_003460
142. Sacramento County Sheriff's Department, ORZ 0001-ORZ 0007
Crime Arrest Report, No: MJD 2012-0261775,
dated November 22, 2012
143. Sacramento County Sheriff's Department, ORZ 0016-ORZ 0017
Supplemental Report, No. MJD 2012-0261775,
November 23, 2012
144. Professional Standards Division ORZ 00022-ORZ 00037
Administrative Investigation, 2012IA-058,
Subject Employee: Deputies Ivan Orozco &
Michael Pietrek, April 3, 2013
145. County of Sacramento, Inter-Department ORZ 00038-ORZ 00050
Correspondence from Sergeant Robin Kolb
to Lieutenant Russ Munn re: Case
Summary; Internal Affairs Investigation
2012IA-058, dated January 8, 2013
(Confidential)
146. Investigative Chronology, 2012IA-058, ORZ 00051-ORZ 00052
November 29, 2012-February 21, 2013
147. County of Sacramento, Inter-Department ORZ 001687-ORZ 001698
Correspondence from Sergeant Robin Kolb
to Lieutenant Matt Morgan re: Case
Summary: Internal Affairs Investigation
2011IA-062, dated February 9, 2012
148. 2P Census Board/Pre Admit List, October JPS 62667-JPS 62668
20, 2012
149. Sacramento County Sheriff's Department CO_000701-CO_000706
Correctional Services Custody Log for
James Mayfield, dated October 12-14, 2012
150. Sheriff's Captain Job Description CO_001539-CO_001540
151. Agreement between County of Sacramento CO_001730-CO_001753
and the Regents of the University of
California for JPS, contract term July 1,
2012 to June 30, 2013
152. Disability Rights California, Report on CO_003812-CO_003844
Inspection of the Sacramento County Jail
(Conducted April 13-14, 2015), revised
October 15, 2015
153. Memorandum from George Anderson & CO_004571-CO_004596
Judy McGarry to: Board of Supervisors re:
Response to Phase Two of the Sheriff's
Department Programmatic Audit
Recommendations, for the agenda of
October 31, 2006
154. Correctional Health Services, Suicide CO_01013-CO_01015
Prevention 2M-Joint Policy (Administrative
Policy No. 1412), revised May 2013
155. Sheriff's Department County of Sacramento CO_004375-CO_004379
Operations Order — Preventing, Detecting,
Responding to Inmate or Detainee Sexual
Assault, 3/17 (New 12/12)
156. Sheriff's Department County of Sacramento CO_003913-CO_003917
Operations Order — Preventing, Detecting,
Responding to Inmate or Detainee Sexual
Assault, 3/17 (Rev 4/13)
157. County of Sacramento, PREA Incident CO_004035-CO_004036
Routing Sheet (blank)
158. Sheriff's Department County of Sacramento CO_003853-CO_003888
General Order — Preventing, Detecting,
Responding to Inmate or Detainee Sexual
Assault, X/XX (New 9/15)
159. Correctional Health Services, Mental CO_001010-CO_001012
Health Services, Admin. Policy
#1411, revised May 2005
160. Correctional Health Services, Decision CO_001000-CO_001001
Making — Special Needs, Admin. Policy #
1107, revised May 2005
161. County of Sacramento, Inter-Department CO_003659-CO_003673
Correspondence from Captain Dave
Torgerson to Captain Rick Pattison re: Civil
Claims Review — 2014CR-017, dated
March 12, 2014
162. County of Sacramento, Inter-Department ORZ 001882-ORZ 001897
Correspondence from Lt. Rick Pattison to
Captain Rosanne Richeal re: Findings and
Recommendations — 2011IA-062, dated
March 1, 2012
163. County of Sacramento Inter-Department ORZ 001880-ORZ 001881
Correspondence from Captain Rick Pattison
to Deputy Ivan Orozco re: Documented
Counseling (2011IA-062), dated April 4,
2012
164. County of Sacramento, Inter-Department ORZ 000023
Correspondence from Captain Rick Pattison
to Deputy Ivan Orozco re: Case Disposition
— 2012IA-058, dated April 3, 2013
165. County of Sacramento, Inter-Department ORZ 000024-ORZ 000025
Correspondence from Captain Rick Pattison
to Deputy Michael Pietrek re: Letter of
Reprimand (2012IQ-058), dated April 3,
2013
166. County of Sacramento Inter-Department ORZ 000026-ORZ 000035
Correspondence from Captain Rick Pattison
to Chief Deputy James Lewis re: Findings
and Recommendations — 2012IA-058, dated
February 28-March 22, 2013
167. Administrative Disciplinary Review Route ORZ 000036-ORZ 000037
Sheet, IA Case No. 2012IA-058, dated
February 28, 2013
168. Sacramento County Sheriff's Department, ORZ 0016-ORZ 0017
Supplemental Report, No. MJD 2012-0261775,
November 23, 2012
169. Plaintiff James Joshua Mayfield's Notice of n/a
the Deposition of Deputy Michael Pietrek,
dated April 26, 2016
170. Employee personal detail report and CO_004597-CO_004599;
training log of Deputy Michael Pietrek and CO_004606
video identified as "Mayfield Nov 22 2012"
showing the beating of James Joshua
Mayfield by Ivan Orozco, produced June I,
2016
171. Objection to Plaintiff James Joshua n/a
Mayfield's Notice of the Deposition of
Deputy Michael Pietrek, dated May 26,
2016
172. Employee personal detail report and CO_004597-CO_004599
training log of Deputy Michael Pietrek
173. County of Sacramento Inter-Department ORZ 001847-ORZ 001860
Correspondence from Sergeant Robin Kolb
to Lieutenant Matt Morgan re: Interview
With Deputy Pietrek, 2011IA-062, dated
February 7, 2012
174. Sacramento Sheriff's Department ORZ 000122-ORZ 000138
Continuation Report of November 22, 2012
Incident, dated November 23, 2012
175. County of Sacramento Inter-Department ORZ 000122-ORZ 000138
Correspondence from Sergeant Robin Kolb
to Lieutenant Russ Munn re: Interview
With Deputy Pietrek, 2012IA-058, dated
January 31, 2013
176. Plaintiff James Joshua Mayfield's Notice of n/a
the Deposition of Defendant County of
Sacramento (Fed. R. Civ. P. Rue 30(b)(6)),
dated April 25, 2016
177. Sheriff's Department County of Sacramento ORZ 002224-ORZ 002225
Operations Order — Housing Unit Checks,
6/05 (rev 7/07)
178. Sheriff's Department County of Sacramento CO_001082-CO_001084
Operations Order — Housing Unit Checks,
6/05 (rev 9/10)
179. Sheriff's Department County of Sacramento CO_001075-CO_001081
Operations Order — Counts and Lockdowns,
6/04 (rev 9/10)
180. Sacramento County Sheriff's Department CO_000045-CO_000046
Correctional Health Services patient care
log re: James Mayfield, dated October 13-17,
2012
181. Sheriff's Department County of Sacramento CO_001223-CO_001229
Operations Order — Use of Safety
Cells/Segregation Cells/Multipurpose
Rooms/North Holding #2, 4/05 (rev 7/07)
182. Sheriff's Department County of Sacramento CO_001216-CO_001222
Operations Order — Use of Safety
Cells/Segregation Cells/Multipurpose
Rooms/North Holding #2, 4/05 (rev 4/12)
183. Sheriff's Department County of Sacramento ORZ 01619-ORZ 01625
Operations Order — Use of Safety
Cells/Segregation Cells/Multipurpose
Rooms/North Holding #2, 4/05 (rev 4/14)
184. Sheriff's Department County of Sacramento CO_001134-CO_001142
Operations Order — Use Restraint Devices,
2/02 (rev 12/10)
185. 2005 Adult Title 15 Regulations, effective CO_002974-CO_002975
7/2/05
186. Sheriff's Department County of Sacramento ORZ 002003-ORZ 002006
Operations Order — Fights, Riots, Hostage
and Minor Disturbances, 3/09 (rev 8/06)
187. Inmate Movements History (PF5) for James CO_000903-CO_000917
Joshua Mayfield, July 2, 2011 to August 14,
2013
188. Sacramento County Sheriff's Department CO_000708-CO_000715
Confidential Requests for Reclassification —
James Mayfield, between June 5, 2011-June
28, 2013
189. Sacramento County Sheriff's Department CO_000718-CO_000721
Inmate Incident Reports for James Joshua
Mayfield, dated July 12, 2011 and February
18, 2012
190. Sheriff's Department County of Sacramento CO_001232-CO_001237
Operations Order — Classification Process,
6/03 (rev 7/07)
191. Sheriff's Department County of Sacramento CO_001069-CO_001074
Operations Order — Classification Process,
6/03 (rev 12/09)
192. Sheriff's Department County of Sacramento CO_001067-CO_001068
Operations Order — Housing Plan, 6/02 (rev
12/09)
193. Plaintiff James Joshua Mayfield's Amended n/a
Notice of Deposition of Defendant UCDHS
(FRCiv.P Rule 30(b)(6)), February 10, 2016
194. Types of Patients on Inpatient Unit, JPS JPS 58453-58454,
Statistics 2004-2005, PowerPoint JPS 58657
presentation
195. Email from Narriman Shahrokh to Gregory JPS 62853
Sokolov, et al. re: Meeting, dated
November 27, 2012
196. Email from Robert Hales to Gregory JPS 63282
Sokolov, et al. re: Physician Meeting, dated
March 4, 2012
197. Email from Paul Hendricks to Carla JPS 63408
Blackmon, et al. re: 2P Changes, dated
December 14, 2012
198. • Email from Jason Roof to Gregory JPS 63969-63972,
Sokolov re: 2P backlog, dated May 24, JPS 61744-617445
2013
• Email from Gregory Sokolov to Jason
Roof re: 2P backlog, dated May 23,
2013
• Email from Jason Roof to Gregory
Sokolov re: One Consult list addition,
dated July 5, 2013
199. Sacramento County Sheriff's Department JPS 50001
Correctional Health Services patient care
log re: James Mayfield, dated June 21,
2011-June 25, 2013
200. JPS Clinical-Initial Clinical Assessments of JPS 50707-50713,
James Mayfield JPS 50727-20729,
JPS 50737-50741,
JPS 50748-50753,
JPS 50756-50763,
JPS 50771-50773,
JPS 50623-50630,
JPS 50632-50639,
JPS 50641-50655
JPS 50678,
JPS 50515-50519,
JPS 50527-50530,
JPS 50535-50538,
JPS 50417-50421,
JPS 50437-50452,
JPS 50458-50461,
JPS 50476-50479,
JPS 50328-50330,
JPS 50332-50341,
JPS 50352-50355
(not in this order)
201. Dangerousness and Delirium, PowerPoint JPS 62038-JPS 62054
presentation of Jason Roof, M.D.
202. Sacramento County Sheriff's Department JPS 50032
Correctional Health Services patient care
log re: James Mayfield, dated January 27-28,
2013
203. Restraint Documentation Record & CO_000443
Denial and Reinstatement of Patient's CO_000144
Rights, dated June 13, 2013
204. JPSIP ADL Flow Sheet, 2011-2013 CO_000442,
CO_000278,
CO_000177,
CO_000178,
CO_000128-CO_000129
205. Sacramento County Sheriff's Department JPS 50060,
Correctional Health Services patient care JPS 50054,
log re: James Mayfield, dated May 21-25, JPS 50019,
2012 JPS 50016
206. Email from Andrea Javist to Gregory JPS 60588
Sokolov, et al. re: T-Sep Inmates, dated
January 4, 2012.
207. UCDHS Department of Psychiatry JPS Self JPS 58887
Inflicted Injury Report — Third Quarter
2013
208. UC Davis Health System Department of JPS 58899-58903
Psychiatry — Quality Improvement
Committee Meeting Minutes, December 8,
2011
209. JPS Mission Statement and Program JPS 57343-57348
Overview, undated
210. A • Email from Gregory Sokolov to JPS-ALL, JPS 60598,
re: Dr. Sokolov away 1/21-11/25, JPS 60601
dated November 18, 2011
• Email from Gregory Sokolov to JPS-ALL
re: MD On-Call coverage for
week of 10/24-10/28, dated October 24,
2011
210. B Email from Jason Roof to Gregory Sokolov JPS 61648
re: Addition to consult list/safety suit
program, dated June 14, 2012
(Confidential)
211. Email from Gregory Sokolov to Robert JPS 63562-63563,
Hales, et al. re: 2P wait list issues/concerns, JPS 63572
dated December 6, 2012.
212. Email from Robert Hales to Mary Ann JPS 63824-63829,
Carrasco, et al. re: Letter regarding JPS 63628-63638
Sacramento Jail w/attachment, dated
August 8, 2016
213. Email from Andrea Javist to Paul JPS 61823
Hendricks, et al. re: Safety Suits, dated
February 11, 2013
214. Email from Steve Cortez to Gregory JPS 60536
Sokolov, dated October 16, 2014
215. Email from Gregory Sokolov to Steve JPS 60542
Cortez, dated August 28, 2014
216. Email from Steve Cortez to Gregory JPS 61078
Sokolov, dated June 6, 2013
217. Email from Michael Singer to Gregory JPS 61227
Sokolov, dated June 19, 2012
218. Email from Gregory Sokolov to Michael JPS 61233
Singer, et al., dated April 2, 2012
219. Criminalization of the Mentally Ill: The Use JPS 58432-58468
of Jails as Psychiatric Hospitals,
PowerPoint presentation by Gregory
Sokolov, M.D.
220. Suicide Prevention Training, PowerPoint JPS 58267-58297
presentation by Gregory Sokolov, M.D.
221. Suicide Prevention Briefing, August/2006 JPS 58578-58582
222. Main Jail Self-Injury Report, 2007-2011 JPS 58874
223. Email from Lynn Delgado to Gregory JPS 62879
Sokolov re: Consult List, dated August 2,
2012
224. Email from Gregory Sokolov to Steve JPS 60587
Cortez re: 2P Waiting List — Inmate, dated
January 12, 2012
225. Email from Andrea Javist to Gregory JPS 61657
Sokolov re: 2P Wait List, dated November
20, 2012
226. Email from Lynn Delgado to Gregory JPS 61137
Sokolov, dated December 13, 2012
227. Plaintiff James Joshua Mayfield's Amended n/a
Notice of Deposition of Defendant UC
Davis Health System (FRCiv.P Rule
30(b)(6))-Topics 3, 8, and 13, dated March
3, 2016
228. Email from Andrea Javist to Narriman JPS 63406
Shahrokh, et al re: Division of Paul's
Duties, dated June 17, 2013
229. UC Davis Health System Position JPS 59280-59290
Description forms
230. Email from Andrea Javist to Gregory JPS 62090
Sokolov re: 2P Wait list, dated November
20, 2012
231. JPS UC Davis Health System, Power Point JPS 58246-58257
presentation by Andrea Javist, LCSW
Program Director
232. Email from Andrea Javist to Paul JPS 63045
Hendricks, et al re: Safety Suits, dated
February 11, 2013
233. UC Davis JPS Incident Reports, dated JPS 59354-59377
between November 22, 2013 and May 15,
2015
234. Self-Inflicted Injury Log, June 11, 2013-August JPS 60162-60176
5, 2015
235. JPS Clinical Assessment and JPS JPS 50476-50480
Telephone Referral & Contact, dated
December 28 & 30, 2012
236. Email from Andrea Javist to Narriman JPS 63374
Shahrokh re: Firearms Prohibition
Notification Forms, dated December 4,
2013
237. Second Amended Notice of Taking n/a
Deposition of Lorilene Emmanuel Pursuant
to Subpoena Duces Tecum, dated May 3,
2016
238. Certificate of Live Birth for James Joshua n/a
Mayfield, December 18, 1992
239. Sacramento County Jail Inmate Telephone CO_001572-CO_001576
Log of James Mayfield from September 21,
2011-August 14, 2013
240. Handwritten letter from James Joshua n/a
Mayfield to Linda Evans, dated October 31,
2011
241. Sacramento County Sheriff's Department JPS 50001-50100
Correctional Health Services patient care
log re: James Joshua Mayfield, dated
September 21, 2011-August 14, 2013
242. Health Services Kite of James J. Mayfield, CO_004281
dated January 29, 2012
243. Thumb drive of documents produced by CO_000001-CO_000465;
County of Sacramento at deposition CO_001755-CO_002397
244. INTENTIONALLY LEFT BLANK ---
245. INTENTIONALLY LEFT BLANK ---
246. INTENTIONALLY LEFT BLANK ---
247. Sacramento County Jail Assessment-Executive CO_004431-CO_004570
Summary
248. Memorandum from George Anderson & CO_004571-CO_004596
Judy McGarry to: Board of Supervisors re:
Response to Phase Two of the Sheriff's
Department Programmatic Audit
Recommendations, for the agenda of
October 31, 2006
249. Self-Inflicted Injury Log, June 11, 2013-August JPS 60162-60176
5, 2015
250. Authorization to Execute Two Agreements n/a
for Consulting Services Related to Mental
Health Care and Housing in Jail Facilities
Totaling $75,000 for the Period of January
21, 2016 through January 20, 2017
251. Agreement with Puget Sound Mental n/a
Health, PS Incorporated, for Consultant
Services, dated January 21, 2016
252. Agreement with Eldon Vail, an individual, n/a
for Consultant Services, dated January 21,
2016
253. Evaluation of Mental Health Services, CO_010626-CO_010816
Sacramento County Jails, prepared by
Bruce C. Gage, M.D., dated June 8, 2016
254. Memo to the Board of Supervisors from n/a
Sheriff's Department re: Authorization to
Execute Two Agreements for Consulting
Services Related to Mental Health Care and
Housing in Jail Facilities totaling $75,000
for the Period of January 21, 2016 through
January 20, 2017, dated December 16, 2015
255. Sheriff's Department, Sacramento County CO_002646-CO_002647
Training Bulletin-Dual Control Holds,
dated January 21, 2015
256. Defendant Regents of the University of
California, DBA UCDHS, Dr. Gregory
Sokolov, and Dr. Robert Hales' Second
Amended Notice of Taking Deposition of
Plaintiff James Mayfeild, Sr. with Request
for Production of Documents, dated July
11, 2016
257. Email from Steve Cortez to Gregory JPS 61163
Sokolov, dated October 18, 2012
258. Email from Michael Singer to Gregory JPS 61096
Sokolov re: developmentally disabled,
dated March 23, 2013
259. Email from Sandra Venus to Gregory JPS 61628
Sokolov re: Robert Bonnard, dated
November 24, 2012 (Confidential)
260. Email from Edgar Catingub to Gregory JPS 63117
Sokolov, dated May 20, 2013
261. Sacramento County Sheriff's Department CO_000032,
Correctional Health Services patient care CO_000067-CO_000068
log re: James Joshua Mayfield, dated April
21, 2012-January 28, 2013
262. Call Schedule from January 2012-June JPS 60591-60596
2012 identifying attending psychiatrist
263. Order Confirmation Report of James J. JM 0667-0668
Mayfield, dated February 2, 2013
264. State Of California-Health and Welfare CO_000351-CO_000352
Agency Application for 72-hour Detention
for Evaluation and Treatment of James
Mayfield, dated March 27, 2012
265. JPS Acute Inpatient Unit Discharge JPS 63312-63318
Summary, dated April 25, 2012 and January
4, 2013
266. Email from Narriman Shahrokh to Gregory JPS 62854-62855
Sokolov re: Meeting, dated November 27,
2012
267. JPS All Staff Meeting Minutes, dated JPS 66806-66807
January 30, 2008
268. 2P Issues Meeting Minutes, dated April, 22, JPS 66705
2009
269. JPS Staff Meeting minutes and PowerPoint JPS 66879-66854
presentation, dated May 3, 2012
270. CD of Documents produced by Bruce Gage n/a
at deposition, August 29, 2016
271. CD of Documents produced by Bruce Gage n/a
at deposition, August 29, 2016
272. Handwritten notes produced by Bruce Gage n/a
at deposition, August 29, 2016
273. JPS medical records of James Joshua JPS 50352-50355,
Mayfield's clinical assessment and care JPS 50340-50341,
from June 11-25, 2013 JPS 50338-50339,
JPS 50336-50337,
JPS 50334-50335,
JPS 50332-50333,
JPS 50328-50330,
CO_000130
274. Appointments Report of James Joshua CO_011128-CO_011132
Mayfield, clinical section of patient e-chart,
May 29 to July 22, 2013
275. Email from Amy Burton to Gregory JPS 61386
Sokolov, dated June 11, 2013
276. Incident Report Detail (PF10) re: James CO_000843-CO_000845
Joshua Mayfield, dated June 11, 2013
277. 2 P Census Board-Pre Admit Patient List, JPS 62815-62817
April 14, 2012 (Confidential)
278. Photographs of surveillance monitors JM 2349-2350
279. Photographs of jail cell JM 2330 & 2336
280. Sacramento County Sheriff's Department, JPS 50228-50231,
Medication Administration Reports, dated JPS 50275,
January 22 to February 2, 2013 and June 12 JPS 50277,
to June 25, 2013 JPS 50278,
JPS 50323,
JPS 50345,
JPS 50350
281. Email from Paul Hendricks to Narriman JPS 63413-63416
Shahrokn re: Patient Issues,
September 25, 2012
282. Evaluation of Mental Health Services at CO_010642
Sacramento Jails (page 17), dated June 8,
2016 (Confidential)
283. Amended Notice of Deposition of Dr. n/a
Jinmei Woan Pursuant to Subpoena Duces
Tecum, dated August 29, 2016
284. Curriculum Vitae of Jinmei Woan, dated n/a
September 7, 2016
285. Subpoenaed medical records of James n/a
Mayfield from Jinmei Woan, M.D.
286. Plaintiff James Joshua Mayfield's Notice of n/a
the Deposition of Defendant County of
Sacramento (FRCivP Rule 30(b)(6)), dated
December 16, 2015
287. Photographs of Prison Rape Elimination JM 2347,
Act ("PREA") postings JM 2409,
JM 2447
288. Sacramento County Sheriff's Department CO_004988-CO_004989
2014 Year-End PREA Report
289. Sacramento County Sheriff's Department CO_004990-CO_004992
2015 Year-End PREA Report
290. Sheriff's Department County of Sacramento CO_004936-CO_004941
Operations Order, Rape, dated 07/04 (rev
01/04)
291. Correctional Health Services, Sexual CO_004785-CO_004786
Assault, Admin. Policy # 1424, updated
September 30, 2015
292. PREA Incident Routing Sheet, revised CO_004933-CO_004935
February 2016 (blank)
293. Sacramento County Sheriff's Department, CO_010940-CO_010942
Inmate/Detainee PREA Attestation Form
and Classification Worksheet (blank),
revised April 2016
294. Suicide Prevention Training, PowerPoint CO_005370-CO_005378
presentation by Gregory Sokolov, MD
295. Suicide Prevention Training, PowerPoint CO_005414-CO_005430
presentation by Deputy Chad Outman,
dated September 2014
296. Sacramento County Sheriff, Annual Officer CO_005382-CO_005413
Training, Suicide Prevention for
Corrections, PowerPoint Presentation by
Deputy Mark Campbell #1121
297. 24 Hour Format for Crisis Intervention CO_005068-CO_005075
Training Outline
298. 8 Hour Format Crisis Intervention Training CO_005062-CO_005067
Expanded Course Outline
299. Sheriff's Department County of Sacramento CO_001088-CO_001095
Operations Order, Social, Social Service
Consultation, and Media Visits, dated 6/17
(rev 8/13)
300. Correctional Health Services, Suicide CO_001314-CO_001316
Prevention 2M-Joint Policy, Admin. Policy
# 1412, revised May 2005
301. Correctional Health Services, Suicide CO_004771-CO_004773
Prevention 2M-Joint Policy, Admin. Policy
# 1412, updated September 30, 2015
302. Correctional Health Services, Mental CO_004768-CO_004770
Health Services, Admin. Policy # 1411,
dated September 30, 2015
303. Correctional Health Services, Medication CO_001338-CO_001344
Administration, Admin. Policy # 1601,
revised December 2007
304. Correctional Health Services, Medication CO_001331-CO_001337
Administration, Admin. Policy # 1601,
revised January 2013
305. Correctional Health Services, Patients in CO_001321-CO_001322
Safety Cells, Admin. Policy # 1415, revised
May 2005
306. Correctional Health Services, Patients in CO_001323-CO_001324
Safety Cells, Admin. Policy # 1415, revised
November 2011
307. Medication administration records of James CO_001951-CO_001954;
Mayfield, dated September 21, 2011 to CO_001968-CO_001969;
August 14, 2013 CO_001973-CO_001975;
CO_001986-CO_001988;
CO_001997-CO_001998;
CO_002006-CO_002007;
CO_002015-CO_002017;
CO_002022-CO_002023;
CO_002036-CO_002040;
CO_002045-CO_002046;
CO_002056-CO_002057;
CO_002066-CO_002067;
CO_002337-CO_002346;
CO_002348-CO_002354;
CO_002356-CO_002362;
CO_002365-CO_002374;
CO_002376-CO_002392;
308. Vital Signs and Nursing Orders Reports, CO_010878-CO_010898
August 14, 2011-July 17, 2013
309. Appointments Report of James Joshua CO_011006
Mayfield, clinical section of patient e-chart,
August 21-22, 2011
310. Appointments Report of James Joshua CO_010995
Mayfield, clinical section of patient e-chart, CO_011136
dated June 6, 2011-August 21, 2013
311. INTENTIONALLY LEFT BLANK ---
312. INTENTIONALLY LEFT BLANK ---
313. INTENTIONALLY LEFT BLANK ---
314. INTENTIONALLY LEFT BLANK ---
315. INTENTIONALLY LEFT BLANK ---
316. INTENTIONALLY LEFT BLANK ---
317. INTENTIONALLY LEFT BLANK ---
318. INTENTIONALLY LEFT BLANK ---
319. INTENTIONALLY LEFT BLANK ---
320. Still-frame photo from DVD — Disc M1, n/a
produced by Defendant Orozco on
09/14/2015,
"08128W200BelowTV_2012-11-22_21h50min00s000ms"
(Ex. 86) at 9:51:50 PM, dated November 22, 2012
321. County of Sacramento, Inter-Department ORZ 000224-ORZ 000229
Correspondence from Sergeant Robin Kolb
to Lieutenant Russ Munn re: Interview with
Inmate Newsome, 2012IA-058, dated
January 31, 2013
322. Audio recordings of IA interviews of CO_011299
Quentin Carthen, Nicholas Newsome, and
Nathaniel Carter
323. Still-frame photo from DVD — Disc M1, n/a
produced by Defendant Orozco on
09/14/2015,
"08128W200BelowTV_2012-11-22_21h50min00s000ms"
(Ex. 86) at 9:51:57 PM, dated November 22, 2012
324. DVD — Disc M1, produced by Defendant n/a
Orozco on 09/04/2015,
08108WIndoorRecby100_2012-11-22_21h50min00s000ms
325. Still-frame photo from DVD — Disc M1, n/a
produced by Defendant Orozco on
09/14/2015,
"08128W200BelowTV_2012-11-22_21h50min00s000ms"
(Ex. 86) at
9:51:53 PM, dated November 22, 2012
326. County of Sacramento, Inter-Department ORZ 000209-ORZ 000219
Correspondence from Sergeant Robin Kolb
to Lieutenant Russ Munn re: Interview
With Inmate Carter, 2012IA-058, dated
January 31, 2013
327. Still-frame photo from DVD — Disc M1, n/a
produced by Defendant Orozco on
09/14/2015,
"08128W200BelowTV_2012-11-22_21h50min00s000ms"
(Ex. 86) at 9:52:06 PM, dated November 22, 2012
328. INTENTIONALLY LEFT BLANK ---
329. INTENTIONALLY LEFT BLANK ---
330. INTENTIONALLY LEFT BLANK ---
331. INTENTIONALLY LEFT BLANK ---
332. INTENTIONALLY LEFT BLANK ---
333. INTENTIONALLY LEFT BLANK ---
334. INTENTIONALLY LEFT BLANK ---
335. Expert Report of Jeffrey Schwartz, dated n/a
September 22, 2016
336. CD of documents sent to Jeffery Schwartz n/a
by Plaintiff's, dated September 27, 2016
337. CD of correspondence sent to Jeffrey n/a
Schwartz by Plaintiff's, dated September 27,
2016
338. Sheriff's Department County of Sacramento CO_003604-CO_003607
General Order, Use of Force, 2/11 (rev
3/98)
339. Sheriff's Department County of Sacramento CO_001189-CO_001193
General Order, Use of Force Policy, 2/11
(rev 12/12)
340. Sheriff's Department County of Sacramento CO_001127-CO_001133
Operations Order, Use of Force, 2/01 (rev
7/07)
341. A Sheriff's Department County of Sacramento CO_001082-CO_001084
Operations Order, Housing Unit Checks,
6/05 (rev 9/10)
341. B Expert Report of Stacey Helvin, dated n/a
September 22, 2016
342. Supplemental Expert Report of Stacey n/a
Helvin, dated October 3, 2016
343. Life Care Plan and Cost Analysis of James n/a
Joshua Mayfield by Drs. Walter Harrell and
Juan Latorre, Dated September 9, 2015
344. Curriculum Vitae of Thomas Lyle n/a
Hedge, Jr., M.D.
345. Plaintiff's Notice of Deposition of n/a
Defendants' Expert Stacey R.
Helvin, RN and Demand for Production of
Documents, dated August 4, 2016
346. Curriculum Vitae of Stacey R. n/a
Helvin, RN, BSN, PHN, CRRN, CLCP
347. Case intake file and correspondence n/a
between Wilke Fleury and Stacey Helvin
348. Invoices of billing by Stacey Helvin, QLCP n/a
to Defendants in Mayfield v. Orozco,
various dates
349. Trials and Depositions list for Stacey n/a
Helvin
350. Handwritten notes of Stacey Helvin from n/a
the medical examination of James Joshua
Mayfield by Thomas Hedge, dated August
25, 2016
351. Medical records of James Mayfield from n/a
various facilities, produced by Stacey
Helvin at her deposition, October 5, 2016
352. INTENTIONALLY LEFT BLANK ---
353. Amended Subpoena to Testify at a n/a
Deposition in a Civil Action to Dr. Thomas
Owley, dated September 26, 2016
354. Medical records of James Joshua Mayfield JM 1735-1933
from Napa State Hospital, Dated September
29-December 8, 2011
355. Curriculum Vitae of Thomas B. Owley, n/a
MD
356. INTENTIONALLY LEFT BLANK ---
357. INTENTIONALLY LEFT BLANK ---
358. INTENTIONALLY LEFT BLANK ---
359. INTENTIONALLY LEFT BLANK ---
360. Still-frame photo of video footage from n/a
November 22, 2012 at 9:51:50 p.m.
361. County of Sacramento Inter-Department ORZ 000190-ORZ 000200
Correspondence from Sergeant Robin Kolb
to Lieutenant Russ Munn re: Interview with
Inmate Carthen, 2012IA-058, dated January
31, 2013
362. Audio recording of the interview of Inmate n/a
Quentin Carthen, dated December 27, 2012
363. County of Sacramento Inter-Department ORZ 00038-ORZ 00050
Correspondence from Robin Kolb to
Lieutenant Russ Munn re: Case Summary;
Internal Affairs Investigation 2012IA-058,
dated January 8, 2013 (Confidential)
365. Communications file of Jeffrey Hislop re: n/a
Mayfield v. Orozco, produced at his
deposition, October 10, 2016
366. Research file of Jeffrey Hislop re: Mayfield n/a
v. Orozco, produced at his deposition,
October 10, 2016
367. Notes file of Jeffrey Hislop re: Mayfield v. n/a
Orozco, produced at his deposition, October
10, 2016
368. Time sheet file of Jeffrey Hislop re: n/a
Mayfield v. Orozco, produced at his
deposition, October 10, 2016
369. Case file of Jeffrey Hislop re: Mayfield v. n/a
Orozco, produced at his deposition, October
10, 2016
370. Expert Opinion report Pursuant to Federal n/a
Rules of Civil Procedure, Rule 26
371. Defendant Ivan Orozco's n/a
Supplemental/Rebuttal Designation of
Expert Witnesses Pursuant to Federal Rule
of Civil Procedure 26(a)(2), dated October
7, 2016
372. Defendants' Notice of Deposition of Expert n/a
With Production of Documents, dated
September 27, 2016
373. Fee Agreement of Raymond F. Patterson, n/a
M.D.
374. Expert Report of Raymond F. Patterson, n/a
M.D., dated September 22, 2016
375. Complete File of Raymond F. Patterson, n/a
M.D.
376. Thumb Drive of documents produced by n/a
Raymond F. Patterson at his deposition,
October 11, 2016
377. Joint Meeting Minutes of Sheriff's JPS 63156 &
Department JPS Correctional Health JPS 63157
Services, dated June 12, 2008
378. • Email from Jaime Lewis to Erik CO_003486-CO_003489 &
Maness with attachment re: Crisis CO_003495-CO_003496
Intervention Training & Mental Health
Update Jan 2016, dated January 13,
2016
• Email from Scott Jones to Erik Maness
with attachment re: Crisis Intervention
Training & Mental Health Update Jan
2016, dated January 15, 2016
379. INTENTIONALLY LEFT BLANK ---
380. Article entitled "Guide to Developing and n/a
Revising Suicide Prevention Protocols
within Jails and Prisons," written by
Lindsay M. Hayes, revised March 2011
381. Publication entitled "Jail Suicide/Mental n/a
Health Update," Volume 17, Number 1,
containing article(s) by Lindsay Hayes,
Summer 2008
382. Declaration of Lindsay M. Hayes in Support n/a
of Plaintiffs' Objection to Defendants' Plan
to Address Suicide Trends in Administrative
Segregation Units, dated October 26, 2016
383. Publication entitled "Jail Suicide/Mental n/a
Health Update," Volume 16, Number 1,
containing article(s) by Lindsay Hayes,
Summer 2007
384. Article entitled "Avoiding Obstacles to n/a
Prevention," by Lindsay Hayes, 2011
385. Preliminary Assessment (Report) of n/a
Mayfield v. Orozco, et al. matter by Lindsay
M. Hayes, dated September 21, 2016
386. Publication entitled "Jail Suicide/Mental n/a
Health Update," Volume 10, Number 1,
containing article(s) by Lindsay Hayes, Fall
2000
387. An Audit of Suicide Prevention Practices in n/a
the Prisons of the California Department of
Corrections and Rehabilitation, by Lindsay
M. Hayes, dated January 14, 2014
388. U.S. Department of Justice, National n/a
Institute of Correction, National Study of
Jail Suicide 20 Years Later, by Lindsay M.
Hayes, April 2010
389. Thumb drive of documents, produced by n/a
Lindsay Hayes at his deposition, October
18, 2016
390. Thumb drive of documents provided to n/a
Lindsay Hayes by Defendant County of
Sacramento and produced at his deposition,
October 18, 2016
391. INTENTIONALLY LEFT BLANK ---
392. INTENTIONALLY LEFT BLANK ---
393. INTENTIONALLY LEFT BLANK ---
394. INTENTIONALLY LEFT BLANK ---
395. INTENTIONALLY LEFT BLANK ---
396. INTENTIONALLY LEFT BLANK ---
397. INTENTIONALLY LEFT BLANK ---
398. INTENTIONALLY LEFT BLANK ---
399. INTENTIONALLY LEFT BLANK ---
400. Plaintiffs' Notice of Deposition of n/a
Defendants' Expert Mark Cohen and
Demand for Production of Documents,
dated October 6, 2016
401. Curriculum Vitae and Expert Report of n/a
Mark Cohen, dated September 22, 2016
402. Net Discount Rates for Life Care Plan Costs n/a
and handwritten notes, prepared by Mark
Cohen, various dates
403. Supplemental Report of David Cohen, dated n/a
October 11, 2016
404. Addendum-B to the supplemental expert n/a
report of Stacey Helvin, M.D., dated
October 2016
405. Invoices and Communications between n/a
Mark Cohen and Wilke Fleury re: Mayfield
matter, various dates
406. Plaintiffs' lost earnings data, various dates 000037-000038 &
000027,
000003-00004,
000006, &
000008
407. INTENTIONALLY LEFT BLANK ---
408. INTENTIONALLY LEFT BLANK ---
409. INTENTIONALLY LEFT BLANK ---
410. Plaintiffs' Notice of Deposition of n/a
Defendants' Expert Scott Kush, M.D., and
Demand for Production of Documents,
dated October 6, 2016
411. Life Expectancy Report of James Mayfield, n/a
prepared by Scott Kush, M.D., dated
September 21, 2016
412. CD containing documents produced by n/a
Scott Kush at his deposition, October 25,
2016
413. American Spinal Injury Association, n/a
International Standards for Neurological
Classification of Spinal Cord Injury chart
(blank)
414. Deposition and Trial Testimony list of Scott n/a
Kush, M.D., July 30, 2007-March 15,
2016
415. List of Medical Record Received by Scott n/a
Kush, M.D. after Report Date of 9/21/16
416. Chart entitled "Table 14A. Life Expectancy n/a
for SCI persons surviving at least 24 hours
post-injury"
417. Group of correspondence between Dr. Kush n/a
and Attorneys, Dated September 20, 2016
418. Handwritten notation of Dr. Kush n/a
419. INTENTIONALLY LEFT BLANK ---
420. INTENTIONALLY LEFT BLANK ---
421. INTENTIONALLY LEFT BLANK ---
422. INTENTIONALLY LEFT BLANK ---
423. INTENTIONALLY LEFT BLANK ---
424. INTENTIONALLY LEFT BLANK ---
425. Plaintiffs' Notice of Continuance of the n/a
Deposition of Defendants' Expert Thomas
Lyle Hedge, Jr., M.D. and for Production of
Documents, Dated October 12, 2016
426. Letter from Robert Tyler to Dr. Thomas n/a
Hedge with Amended Stipulated Protective
Order, dated August 8, 2016
427. Letter from Robert Tyler to Dr. Thomas n/a
Hedge with additional medical records,
dated August 8, 2016
428. Letter from Robert Tyler to Dr. Thomas n/a
Hedge with Mayfield care log, dated July
28, 2016
429. Invoices of Dr. Thomas Hedge for services n/a
rendered in Mayfield v. Orozco matter,
various dates
430. List of cases from 2012-2016 where n/a
Thomas Lyle Hedge, Jr., M.D. has provided
deposition or court testimony
431. Curriculum Vitae of Thomas Lyle Hedge, n/a
Jr., M.D.
432. Expert Report of Thomas Lyle Hedge, Jr., n/a
M.D., dated August 25, 2016
433. Sutter Tracy Community Hospital records n/a
of James Mayfield, dated June 25-29, 2016
434. "Day in the Life" video of James Joshua JM 5545
Mayfield (DVD)
435. Updated Sutter Tracy Community Hospital n/a
Records of James Joshua Mayfield, Vols. 2
& 3 (CD)
436. X-rays of James Mayfield from UC Davis n/a
Medical Center (DVD)
437. Supplemental Expert Report of Stacey n/a
Helvin, R.N., dated October 3, 2016
438. Addendum-B to the supplemental Expert n/a
Report of Stacey Helvin, R.N. dated
October 2016
439. Rough deposition transcript of Dr. Juan M. n/a
Latorre, dated September 30, 2016
440. Condensed deposition transcript of T. n/a
Walter Harrell, Ph.D., dated September 29,
2016
441. Life Care Plan and Cost Analysis of James n/a
Joshua Mayfield by Drs. Walter Harrell and
Juan Latorre, Dated September 9, 2015
442. Deposition transcript of James Joshua n/a
Mayfield, dated July 26, 2016
443. Research articles, produced by Thomas Lyle n/a
Hedge, Jr. at his deposition, October 25,
2016
444. Case file of Lyle Hedge, Jr. M.D. re: n/a
Mayfield matter, produced at his deposition,
October 25, 2016
445. Plaintiffs' Notice of Deposition of n/a
Defendants' Expert Gary M. Vilke, M.D.,
and Demand for Production of Documents,
dated September 28, 2016
446. Expert Report of Gary M. Vilke, M.D., n/a
dated September 8, 2016
447. Chart of Main Jail Measurements, dated n/a
June 17, 2016 and emailed to Gary M.
Vilke, M.D. by Cheryl Gori via email, July
6, 2016
448. James Mayfield Review, prepared by Gary n/a
M. Vilke, M.D., undated
449. Letter from Van Longyear to Gary M. n/a
Vilke, M.D., dated September 13, 2016
450. Email from Cherly Gori to Gary Vilke, n/a
dated February 4, 2016
451. Handwritten notes taken by Gary Vilke, n/a
M.D. re: Mayfield matter, dated February 4,
2016
452. Photographs of various parts of a jail cell JM 2386,
JM 2392,
JM 2402,
JM 2405
453. UC Davis Health System records of James 000014-000027
Mayfield from July-September 2013
454. Handwritten medication administration log CO_001986-CO_001968
for James Mayfield, dated June 17-July 19,
2013
455. Sacramento County Sheriff's Department CO_000007-CO_000100
Correctional Health Services patient care
log re: James Mayfield, dated June 5, 2011-July
25, 2013
456. UC Davis JPS Review of Patient Self-Injury, n/a
Suicide Attempt or Completed
Suicide for James Joshua Mayfield, dated
August 12, 2013
457. Excerpts from Self-Inflicted Injury Log for JPS 60162,
June 11-August 5, 2013 (Confidential) JPS 60167,
JPS 60172,
JPS 60176
458. Sacramento County Sheriff's Department, JPS 79017-79024;
JPS, Clinical Assessment of Justin Brinsky, JPS 79049-79052
dated July 17, 2013 (Confidential)
459. JPS Acute Inpatient Unit Discharge JPS 79107-79110
Summary of Justin Brinsky, Admit/Release
Dates: July 18-August 8, 2013
(Confidential)
460. 2P Census Board/Pre Admit List, dated JPS 78642,
September 20, 2013 (Confidential) JPS 78646,
JPS 78643,
JPS 78652,
JPS 78651,
JPS 78650,
JPS 78648
461. INTENTIONALLY LEFT BLANK ---
462. INTENTIONALLY LEFT BLANK ---
463. INTENTIONALLY LEFT BLANK ---
464. INTENTIONALLY LEFT BLANK ---
465. INTENTIONALLY LEFT BLANK ---
466. INTENTIONALLY LEFT BLANK ---
467. INTENTIONALLY LEFT BLANK ---
468. INTENTIONALLY LEFT BLANK ---
469. INTENTIONALLY LEFT BLANK ---
470. Expert Report of Joseph V. Penn, M.D., n/a
dated September 22, 2016, Curriculum
Vitae, dated March 1, 2016
471. Position Statement on Segregation of n/a
Prisoners With Mental Illness, American
Psychiatric Association Official Actions,
approved December 2012
472. Position Statement on Restricted Housing of n/a
Mentally Ill Inmates, American College of
Correctional Physicians, 2016
473. Case file of Joseph V. Penn, M.D. re: n/a
Mayfield matter, produced at his deposition,
November 4, 2016
474. RMS Incident Report, dated December 3, ORZ 001710-ORZ 001712;
2011 (Confidential) ORZ 001719;
ORZ 001717-ORZ 001718;
ORZ 001716;
ORZ 001713-ORZ 001715
475. SSD Personal Details page, listing trainings ORZ 002304-ORZ 002306
received by Deputy Ivan Orozco, August 8,
2006-March 16, 2016
476. County of Sacramento, Inter-Department ORZ 001800-ORZ 001822
Correspondence from Sergeant Robin Kolb
to Lieutenant Matt Morgan re: Interview
With Ivan Orozco, 2011IA-062, dated
February 7, 2012 (Confidential)
477. Sacramento County Sheriff's Department ORZ 02368-ORZ 02388
Casualty Report of Orin Colburn, Report
#11-0139095SD, dated July 1, 2011
478. County of Sacramento, Inter-Department ORZ 001770-ORZ 001799
Correspondence from Sergeant Robin Kolb
to Lieutenant Matt Morgan re: Interview
with Deputy Francis, 2011IA-062, dated
February 8, 2012 (Confidential)
479. Defendants' Notice of Deposition of Expert n/a
with Production of Documents, August 2,
2016
480. Life Care Plan and Cost Analysis of James n/a
Joshua Mayfield by Drs. Walter Harrell and
Juan Latorre, Dated September 9, 2015
481. Copy of MediSys file n/a
482. Documents produced by Dr. Harrell at n/a
deposition
483. Defendants' Notice of Deposition of Expert n/a
with Production of Documents
484. Life Care Plan and Cost Analysis of James n/a
Joshua Mayfield by Drs. Walter Harrell and
Juan Latorre, Dated September 9, 2015
485. Documents produced by Juan Latorre at n/a
deposition, September 30, 2016
486. Defendants' Notice of Deposition of Expert n/a
With Production of Documents, dated
September 27, 2016
487. Plaintiffs' Responses and Objections to n/a
Defendants' Amended Notice of Deposition
of Expert Margo Rich Ogus, Ph.D. with
Production of Documents, dated October 6,
2016
488. Expert Report of Margo Rich Ogus, Ph.D., n/a
dated September 19, 2016
489. Handwritten notes and email n/a
communications between Plaintiffs' counsel
and Margo Ogus, produced at her
deposition, October 19, 2016
490. Email from Walter Harrell to Margo Ogus n/a
re: Mayfield, dated September 14, 2016
491. Table of historical average net discount n/a
rates, prepared by Margo Ogus, undated
492. Handwritten notes of Margo Ogus, undated n/a
493. Spreadsheet of Medical costs for James n/a
Joshua Mayfield for 2016-2031, prepared by
Margo Ogus
494. Invoice of services rendered to Hadsell n/a
Stormer & Renick LLP by Margo Ogus,
dated September 30, 2016
495. INTENTIONALLY LEFT BLANK ---
496. INTENTIONALLY LEFT BLANK ---
497. INTENTIONALLY LEFT BLANK ---
498. INTENTIONALLY LEFT BLANK ---
499. INTENTIONALLY LEFT BLANK ---
500. Video entitled
"0814IndoorRecVisit_2011-12-03_00h39min11s000ms" ORZ 002289
of the December 3, 20111 incident between
Defendant Orozco and inmate Steven
Russell
501. Excerpts from Defendant County of n/a
Sacramento's Responses to Plaintiff James
Joshua Mayfield's Third Set of
Interrogatories to Defendant County of
Sacramento, dated July 8, 2016
502. County of Sacramento Inter-Department ORZ 000178-ORZ 000189
Correspondence from Sergeant Robin Kolb
to Lieutenant Russ Munn, subject: Interview
with Inmate Mayfield, 2012IA-058, dated
January 31, 2013
503. Letter from County of Sacramento to James n/a
Mayfield, c/o Justin Ward re: receipt of
Claim and/or Lawsuit against the County of
Sacramento, dated May 29, 2013
504. Letter from Mark Stone to Justin Ward re: n/a
Notice of Rejection of Claim, dated June 4,
2013
505. Excerpts from the 2008-2011 Annual CO_009542,
Reports from the County of Sacramento CO_009564,
Office of Inspector General CO_009699,
CO_009725,
CO_009828,
CO_009843,
CO_009946,
CO_009960
506. • Dr. Jennifer A. Chaffin's medical file JM 1999-2037
and report to the Honorable L. Brown re:
the evaluation of James Joshua
Mayfield, dated July 7, 2011
• Dr. Janice Y. Nakagawa's report to the
Honorable L. Brown re: the evaluation
of James Joshua Mayfield, dated August
6, 2011
507. INTENTIONALLY LEFT BLANK ---
508. Sacramento County Sheriff's Department CO_001970-CO_001972
Medication Administration Report for
James Mayfield, dated July 7-July 13, 2013
509. Sacramento County Sheriff's Department CO_001976-CO_001978
Medication Administration Report for
James Mayfield, dated June 30-July 6, 2013
510. Sacramento County Sheriff's Department CO_001982-CO_001984
Medication Administration Report for
James Mayfield, dated June 23-June 29,
2013
511. Sacramento County Sheriff's Department CO_001990-CO_001992
Medication Administration Report for
James Mayfield, dated June 16-June 22,
2013
512. Sacramento County Sheriff's Department CO_002220
Medication Administration Report for
James Mayfield, dated July 29-July 31,
2012
513. Handwritten medical notes re James Joshua CO_002104;
Mayfield CO_002113
514. INTENTIONALLY LEFT BLANK ---
515. INTENTIONALLY LEFT BLANK ---
516. Defendant County of Sacramento's Second n/a
Supplemental Response to Plaintiff James
Allison Mayfield, Jr.'s Second Set of
Interrogatories, dated September 30, 2016
517. INTENTIONALLY LEFT BLANK ---
518. • Incident Report Detail (PF10) re: James CO_000862-CO_000873
Joshua Mayfield, Report #0960304629,
dated November 26, 2012
• Incident Report Detail (PF10) re: James
Joshua Mayfield, Report #0960304628,
dated November 22-26, 2012
519. Defendant County of Sacramento's Second n/a
Supplemental Responses to Plaintiff James
Joshua Mayfield's Second Set of
Interrogatories, dated August 1, 2016
520. INTENTIONALLY LEFT BLANK ---
521. Transcript of the Audio Interview of Inmate JM 5588-5617
James Mayfield by the Sheriff's Department
Professional Standards Division, taken
December 27, 2012
522. Excerpts from Defendant County of n/a
Sacramento's Responses to Plaintiff James
Joshua Mayfield's Second Set of
Interrogatories to Defendant County of
Sacramento, dated March 19, 2016
523. Handwritten medical notes re James Joshua CO_002121,
Mayfield, dated November 2012-January CO_002130,
2013 CO_002139
524. Photographs of plaintiff's inspection of the JM 2327-2576
Sacramento County Jail, conducted May 31,
2016
525. James Joshua Mayfield's Claim Against the n/a
County of Sacramento, filed May 22, 2013
526. Handwritten medical notes re James CO_009331-CO_009408
Mayfield, dated June 28-July 16, 2013
527. INTENTIONALLY LEFT BLANK ---
528. Audio recording of IA's interview of CO_011299
Deputy Ivan Orozco, produced by
Defendant County of Sacramento
September 30, 2016
529. Audio recording of IA's interview of CO_004606
Deputy Michael Pietrek, produced by
Defendant County of Sacramento at Mr.
Pietrek's deposition June 1, 2016
530. Report of Anthony Cozzolino, M.D., dated JM 1730-1734
April 25, 2013
531. Report of Robert Perez, Ph.D., dated April JM 1943-1953
15, 2008
532. Audio recordings of calls between James CO_001754
Joshua Mayfield and his family while
incarcerated (CD)
533. Emails between James Joshua Mayfield and CO_001579-CO_001631;
his family while incarcerated. JM 1227-1291
534. Photographs of James Joshua Mayfield after JM 1934-1942,
beating by Officer Ivan Orozco; JM 2924-2929,
Photographs of floor produced by JM 2992-2999;
Defendant Orozco on Disc M1 on un Bates-stamped
September 4, 2015
535. Photographs of James Joshua Mayfield and JJM 2078-2085,
his family, pre-incarceration 2919-2923, 2930-2992
536. Audio recording of IA's interview of James CO_011299
Joshua Mayfield, produced by Defendant
County of Sacramento September 30, 2016
537. Records of medical expenses accrued by JM 2233-2301,
James Allison Mayfield & Terri Mayfield, 3298-3339
various dates
538. Medical records of James Joshua Mayfield JM 1354-1374,
from San Joaquin County Behavioral Health 1727-1729, 3192-3206
Services, March 14, 2014-April 29, 2016
539. Handwritten log book of James Allison JM 2763-2918
Mayfield, Jr. re: medical administration and
care of son, James Joshua Mayfield,
EXHIBIT "E"
LONGYEAR, O'DEA & LAVRA, LLP
VAN LONGYEAR, CSB NO. 84189
PETER C. ZILAFF, CSB NO. 272658
NICOLE M. CAHILL, CSB NO. 287165
3620 American River Drive, Suite 230
Sacramento, California 95864-5923
Tel: (916) 974-8500 Fax: (916) 974-8510
Attorneys for Defendants, County of Sacramento, Scott Jones,
James Lewis and Rick Pattison
UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF CALIFORNIA
Estate of JAMES JOSHUA MAYFIELD, by CASE NO. 2:13-CV-02499-JAM-AC
and through LISA BERG, as Conservator;
JAMES ALLISON MAYFIELD, JR.;
and TERRI MAYFIELD, DEFENDANTS' EXHIBIT LIST
Plaintiffs, EXHIBIT "E"
vs.
IVAN OROZCO, in his individual capacity;
SHERIFF SCOTT JONES, in his individual
and official capacity; JAMES LEWIS, in his
individual and official capacity; RICK
PATTISON, in his individual and official
capacity; COUNTY OF SACRAMENTO;
UNIVERSITY OF CALIFORNIA DAVIS
HEALTH SYSTEM; DR. GREGORY
SOKOLOV, in his individual capacity; DR.
ROBERT HALES, in his individual
capacity; and Does 1-5,
Defendants.
Ex. Description Bates No. Intro by Admitted
ID
1 James Joshua Mayfield's (JJM) CO 00001-000465; CO
medical & JPS records from 004056-004359; CO
Sacramento County Jail; 04960-04987;
CO 011201-011284
2 JJM diabetic flow and MAR from CO 001755-002397
Sacramento County Jail
3 JJM Appointment log from CO 010995-011136
Sacramento County Jail
4 JJM refusals of care from CO 003011-003318
Sacramento County Jail
5 JJM records from Napa State CO 001351-001528
Hospital
6 Sacramento County Main Jail CO 00466-00619
logbooks 2E & 2W July 1, 2013-July
18, 2013
7 JJM Jail Information CO 00738-00898;
Management System (JIMS) CO 00903-00917;
Jail screens from Sacramento County CO 03499-03504;
CO 03918-04032;
CO 04916-04932;
CO 05076-05273
8 JJM custody/arrest packet CO 00683-00737
9 Casualty report July 17, 2013 CO 001560-001571
10 Casualty report August 13, 2011 CO 01555-01559
11 JJM phone and visit records from CO 01572-01578;
Sacramento County Jail CO 01754
12 Transcript of phone calls from N/A
Sacramento County Jail
13 JJM commissary and balance CO 00899-00902;
records from Sacramento County CO 04360-04374
Jail
14 JJM email records from CO 001579-001631
Sacramento County Jail
15 Suicide prevention training CO 001284-001298;
documents for Sacramento CO 04380-04385;
Sheriff's Department
CO 05343-5379;
CO 5382-5459;
CO 010562-010625;
CO 10938-10939
16 Use of force training documents CO 002398-002425;
for Sacramento Sheriff's CO 002433-002446;
Department
CO 002454-002598;
CO 002601-002615
17 Crisis intervention training CO 005062-005075
documents for Sacramento
Sheriff's Department
18 Advance Officer Training (AOT) CO 012632-012708;
for Sacramento Sheriff's CO 012710-012714
Department
19 Suicide prevention task force CO 03395-03401;
documents for Sacramento CO 05380-05381
Sheriff's Department
20 Office of Inspector General (OIG) CO 09542-010106
reports for Sacramento County
(2008-2012)
21 Inmate handbook for Sacramento CO 00918-00997;
County Main Jail CO 004993-005061
22 Frame-by-frame photos from CO 001125
video of November 22, 2012 (video)
23 Report dated November 22, 2012 ORZ 0001-0021
24 Frame-by-frame photos from N/A
video of December 3, 2011
25 Training log for Deputy Ivan ORZ 01546-01548
Orozco
26 Training and personnel ORZ 1257-1545
documents for Deputy Ivan
Orozco
27 Contracts for services between CO 01632-01753;
Sacramento County and Regents CO 004391-004430
28 Photos of the Sacramento County JM 2434, 2499,
Main Jail 2510, 2520-2521
29 Jail Psychiatric Services(JPS) JPS 50777-50940
policy and procedure manual
20 Internal Affairs (IA) investigation ORZ 00022-000283
re November 22, 2012
31 IA investigation re December 3, ORZ 001687-001897
2011
32 Suicide statistics for Sacramento CO 03319-03394;
County Jails CO 0035505-003546;
CO 10910;
CO 010910-10937
33 Training log for Deputy Michael CO 004597-004599
Pietrek
34 Training documents for Deputy CO 002679-003010
Rachel Fitch
35 Sacramento County Jail intake CO 01547-01559;
forms CO 010903-010905;
CO 010941-010942
36 Sacramento County chart reviews CO 03608-03611;
and reports of JPS services CO 03634-03658;
CO 03889-03894
37 CHS policy 1107: decision CO 01000-01001;
making/special needs CO 04753-04754
38 CHS policy 1403: emergency CO 001002-001004;
services CO 04757-04759
39 CHS policy 1404: receiving CO 001005-001009;
screening CO 04760-04764
40 CHS policy 1411: mental health CO 001010-001012;
CO 04768-04770
41 CHS policy 1412 (joint): suicide CO 001013-001015
prevention
42 CHS policy 1415: patients in CO 01016-01017
safety cells
43 CHS: Patients in Segregation, CO 001018-CO 001019;
Administrative Policy Number CO 04779-04780
1416
44 CHS: Emergency Response, CO 001020-CO 001025;
Administrative Policy Number CO 04787-04792
1429
45 CHS: Limitations for Admission CO 001026-CO 001028;
to Jail Acute Psychiatric Inpatient CO 04793-04794
Unit, Administrative Policy
Number 1433
46 CHS: Inmate Health Care CO 001029-CO 001031;
Grievances, Admin. Policy No. CO 04795-04797
1435
47 CHS organizational chart CO 01299
48 CHS policy 1304: medication CO 01302-01305;
admin. Training CO 04755
49 CHS policy 1306.1: credentialing CO 01301; CO
04756
50 CHS policy 1404: receiving CO 01302-01310
screening
51 CHS policy 1410: outpatient CO 01311-01313;
housing CO 04765-04767
52 CHS policy 1412: suicide CO 01314-01317;
prevention CO 04771-04773
53 CHS policy 1413: use of CO 01318-01320;
restraints CO0 4774-04776
54 CHS policy 1415: patients in CO 01321-01324;
safety cells CO 04777-04778
55 CHS policy 1417: Adult Dev. CO 01325-01328;
Disability CO 04781-04784
56 CHS policy 1601: medication CO 01331-01344;
administration CO 04800-04806
57 CHS policy 1424: sexual assault CO 04785-04786
58 CHS policy 2300: food services CO 04811
59 CHS policy 1416: Patients in CO 011297-011298
segregation
60 SSD Operations Order No. 2-10, CO 001032-CO 001035
Use of Force
61 SSD Operations Order No. 3-10, CO 001036-CO 001048
Death or Serious Injury
62 SSD Operations Order No. 4-01, CO 001049-CO 001052
Intake Search, Reception and
Holding
63 SSD Operations Order No. 4-05, CO 001053-CO 001059
Use of Safety Cells/Segregation
Cells/Multipurpose Rooms/
North Holding #2
64 SSD Operations Order No. 4-08, CO 001060-CO 001062
Prisoner Orientation
65 SSD Operations Order No. 6-01, CO 001063-CO 001066
Logbooks
66 SSD Operations Order No. 6-02, CO 001067-CO 001068
Housing Plan
67 SD Operations Order No. 6-03, CO 001069-CO 001074
Classification Process
68 SSD Operations Order No. 6-04, CO 001075-CO 001081
Counts and Lockdowns
69 SSD Operations Order No. 6-05, CO 001082-CO 001084
Housing Unit Checks
70 SSD Operations Order No. 6-09, CO 001085-CO 001087
Prisoner Movement Within a
Facility
71 SSD Operations Order No. 6-17, CO 001088-CO 001095
Social, Social Service
Consultation, and Media Visits
72 SSD Operations Order No. 7-01, CO 001096
Inmate Message Requests
73 SSD Operations Order No. 7-02, CO 001097-CO 001100
Grievances
74 SSD Operations Order No. 10-01, CO 001101-CO 001104
Health Care Services
75 SSD Operations Order No. 10-02, CO 001105-CO 001106
Psychiatric Services
76 SSD Operations Order No. 10-03, CO 001107-CO 001110
Healthcare Treatment Access
77 SSD Operations Order No. 10-04, CO 001111-CO 001112
Medical Intake Screening
78 SSD Operations Order No. 10-5, CO 001113-CO 001118
Suicide Prevention Program
79 SSD Operations Order No. 10-08, CO 001119-CO 001121
Medication Distribution "Pill
Call"
80 SSD Operations Order No. 11-02, CO 001122-CO 001124
Meal Counts and Service
81 SSD Operations Order 2-01, Use CO 01127-001133
of Force
82 SSD Operations Order 2-02, Use CO 01134-001151
of restraint devices
83 SSD Operations Order 2-03, Use CO 001152-001158
of prostraint chair
84 SSD Operations Order 2-04, CO 01159-01171
Weapons tactical, etc.
85 SSD Operations Order 2-05, CO 001172-001188
CERT/cell extractions
86 SSD Operations Order 2-11, Use CO 01189-01193
of force
87 SSD Operations Order 3-09, CO 01199-01202
Fights, Riots, etc
88 SSD Operations Order 3-120, CO 01203-01204
Inmate Searches
89 SSD Operations Order 3-130, CO 01205-01207
Searches of Main Jail
90 SSD Operations Order 4-04, Use CO 01211-01215
of Sobering Cells
91 SSD Operations Order 4-05, Use CO 01216-01229
of Safety/Seg cells
92 SSD Operations Order 6-01, CO 01230-01231
Logbooks
93 SSD Operations Order 6-03, CO 01232-01237
Classification process
94 SSD Operations Order 6-30, CO 01238-01239
Housing plan
95 SSD Operations Order 7-07, CO 01258-01261
Health records
96 SSD Operations Order 11-01, CO 01262-01263
Food services
97 SSD Operations Order 11-110, CO 01280-01281
Medical emergencies
98 SSD Operations Order 11-140, CO 01282-01283
Receiving screening
99 SSD General Order re Electronic CO 02426-02432
Control Device
100 SSD General Order re Use of CO 02440-02442
Firearms
CO 02443-02446
101 SSD Use of force documentation
102 SSD report writing tool CO 02451
103 SSD General Order re Use of OC CO 02452-02453
spray
104 SSD Use of force Appendix CO 02599-2600
105 SSD General Order 3/01 CO 03402-03409;
Complaints/disciplinary CO 3612-03633
procedures
106 SSD General Order 3/02 Internal CO 03410-03426;
Affairs CO 03452-03459
107 SSD General Order 3-10 Death or CO 03439-03451
Serious Injury
108 SSD Internal Affairs flowchart CO 03460
109 SSD General Order 2/11 Use of CO 03604-03607
Force
110 SSD General Order 1/34 Reports CO 03845-03852
111 SSD Operations Order 8/05 CO 04386-04390
Commissary Operations
112 Other inmate write-ups CO 04600-04605
INTENTIONALLY SKIPPED
113 Operations Order 7/60: Inmate CO_004607-CO_004612
114 Deaths and Serious Injury, Rev.
10/20
115 SSD General Order 2/05: Use of CO_004613-CO_004615
Firearms (Rev. 9/91)
116 SSD General Order 2/08: Use of CO_004616-CO_004617
Oleoresin Capsicum (O.C.) (Rev.
8/05)
117 SSD General Order 2/14: Use of CO_004618-CO_004624
Taser (New 5/01)
118 SSD Operations Order 2/20: Cell CO_004625-CO_004626
Extraction Procedures (Rev. 8/02)
119 SSD Operations Order 2/30: CO_004627-CO_004628
Custody Emergency Response
Team (C.E.R.T.) (Rev. 8/02)
120 SSD Operations Order 2/80: CO_004629
Fights and Minor Disturbances
(Rev. 8/02)
121 SSD Operations Order 2/100: Use CO_004630-CO_004632
of Restraints (Rev. 4/03)
122 SSD Operations Order 3/101: Use CO_004633-CO_004636
of the Prostraint Chair (Rev. 4/03)
123 SSD Operations Order 3/110: Use CO_004637-CO_004640
of Force (Rev. 8/02)
124 SSD Operations Order 3/150: CO_004644-CO_004650
Tactical Weapons and Equipment
(Rev. 9/02)
125 SSD Operations Order 4/40: Use CO_004651-CO_004652
of Sobering Cell (Rev. 10/02)
126 SSD Operations Order 4/90: CO_004653
Inmate Orientation (Rev. 9/02)
127 SSD Operations Order 4/100: CO_004654-CO_004656
Intake Classification and Holding
(Rev. 9/02)
128 SSD Operations Order 4/110: CO 004657-CO_004660
Intake Search and Reception
Process (Rev. 9/02)
129 SSD Operations Order 4/230: CO_004661-CO_004667
Safety and Segregation Cell Use
(Rev. 4/03)
130 SSD Operations Order 4/260: CO_004668-CO_004676
Transfers (Rev. 9/02)
131 SSD Operations Order 6/10: CO_004677-CO_004681
Classification Process (Rev. 9/02)
132 SSD Operations Order 6/30: CO_004682-CO_004683
Housing Plan (Rev. 9/02)
133 SSD Operations Order 7/30: CO_004684-CO_004691
Crimes Occuring Within the Jail
(Rev. 9/02)
134 SSD Operations Order 7/110: CO_004692-CO_004694
Movement of Inmates Within the
Main Jail (Rev. 9/02)
135 SSD Operations Order 8/05: CO_004695-CO_004696
Housing Unit Checks (Rev. 9/02)
136 SSD Operations Order 8/80: CO_004697-CO_004699
Inmate Housing Procedures (Rev.
9/02)
137 SSD Operations Order 8/90: CO_004700
Inmate Message Requests (Rev.
9/02)
138 SSD Operations Order 8/110: CO_004701-CO_004706
Lockdowns and Counts (Rev.
9/02)
139 SSD Operations Order 8/180: CO_004707
Media Visits (Rev. 10/02)
140 SSD Operations Order 8/190: CO_004708-CO_004710
Social Visits (Rev. 10/02)
141 SSD Operations Order 9/10: CO_004711-CO_004717
Discipline Plan (Rev. 1/02)
142 SSD Operations Order 9/20: CO_004718-CO_004719
Grievances (Rev. 9/01)
143 SSD Operations Order 11/60: CO_004725-CO_004728
Health Care Services (Rev.
11/02)
144 SSD Operations Order 11/70: CO_004729-CO_004732
Health Care Treatment Access
(Rev. 11/02)
145 SSD Operations Order 11/90: CO_004733-CO_004734
Health Records (Rev. 11/02)
146 SSD Operations Order 11/110: CO_004735-CO_004736
Medical Emergencies (Rev.
11/02)
147 SSD Operations Order 11/120: CO_004737-CO_004738
Medication Distribution (Rev.
12/02)
148 SSD Operations Order 11/130: CO_004739-CO_004740
Psychiatric Services (Rev. 12/02)
149 SSD Operations Order 11/140: CO_004741-CO_004742
Receiving Screening (Rev. 12/02)
150 SSD Operations Order 11/150: CO_004743-CO_004748
Suicide Prevention Program (Rev.
10/02)
151 SSD Operations Order 12/30: CO_004749-CO_004750
Food Services (Rev. 1/03)
152 SSD Operations Order 12/40: CO_004751-CO_004752
Meal Count and Service (Rev.
1/03)
153 Internal Affairs investigations CO 011552-011843
2011
154 Internal Affairs investigations CO 011844-012028
2012
155 Internal Affairs investigations CO 012029-012159
2013
156 Sacramento County Main Jail CO 009304-009416
logbooks 6/13/13-7/17/13
157 SSD Main Jail Kitchen special CO 011300-011301
diet logs
158 SSD handheld video from 6/13/13 CO 03485
159 Operations Order 3/17: CO 003779-003784
Preventing, detecting, responding
to inmate or detainee sexual
assault
160 General Order: preventing, CO 003853-003888
detecting, responding to inmate or
detainee sexual assault
(PREA)(Draft)
161 Operations Order 3/17: CO 003913-003917
preventing, detecting, responding
to inmate or detainee sexual
assault
162 Operations order 3/17: CO 004375-004379
preventing, detecting, responding
to inmate or detainee sexual
assault
163 PREA routing sheet CO 004035-004036;
CO 004933-004935
164 Year end PREA reports 2014-2015 CO 004988-004992
165 PREA Video CO 004037
166 Deposition Exhibit 200-JPS Various
notes for JJM
(Marked during deposition of Dr.
Roof)
167 Deposition Exhibit 241 — CHS JPS 50001-50100
chart notes for JJM
(Marked during deposition of
Rosalinda Vizina)
Summaries and Charts
168 Summary/chart of all contacts by
CHS with JJM
169 Summary/chart of all contacts by
CHS with JJM while in classroom
170 Summary/chart of all refusals of
medication by JJM
171 Summary/chart of all CHS
contacts with JJM after discharge
from 2P on June 25, 2013
172 Summary/chart of all incidents of
violence by JJM
173 Summary/chart of all incidents of
2P hospitalizations for JJM
174 Summary/chart of all referrals to
JPS by CHS and/or custody
175 Summary/chart of all Riese
Orders
Dated: March 21, 2017 LONGYEAR, O'DEA & LAVRA, LLP
By: _____________________________
VAN LONGYEAR
PETER C. ZILAFF
NICOLE M. CAHILL
Attorneys for Defendants
County of Sacramento, Scott Jones,
James Lewis and Rick Pattison
EXHIBIT "F"
EXHIBIT F: DEFENDANT IVAN OROZCO'S EXHIBITS
A. Deputy Ivan Orozco's training records
B. County Policy on use of force
C. Incident reports
D. CSI photographs
E. Statement of Plaintiff by Deputy Pietrek
F. Transcript of James Joshua Mayfield interview with Lt. Robin Kolb (ORZ 000183)
G. Audio of James Joshua Mayfield interview with Lt. Robin Kolb
H. Reporter's Transcript of James Joshua Mayfield interview with Lt. Robin Kolb
I. Acute Inpatient Admission Summary (JPS 50340-50341)
J. Initial Psychiatric Assessment (JPS 50761-50763)
K. January 22, 2013, Clinical Assessment of James Mayfield (Exhibit 47 to Delgado Deposition.)
L. October 13, 2012 Clinical Assessment of James Mayfield (Exhibit 105 to Singer Deposition.)
M. Claimant James Joshua Mayfield tort claim
N. Plaintiff's responses to written discovery
O. Post Basic Academy arrest and control curriculum
P. Frame by frame photographs/stills from videos of November 22, 2012
Q. Newton interview transcript and/or audio to Kolb 12.27.12
EXHIBIT "G"
Mayfield v. Orozco, et al./ Case No.: 2:13-cv-02499-JAM-AC
PLAINTIFF'S DISCOVERY DOCUMENTS LIST
EXHIBIT "G"
No. Document Description of portion Offered Admitted
INTERROGATORIES
Defendant County of Sacramento
1 Defendant County of
Sacramento's Responses to
Plaintiff James Allison Mayfield,
Jr.'s Interrogatories (Set 1)
2 Defendant County of
Sacramento's Responses to
Plaintiff James Allison Mayfield,
Jr.'s Interrogatories (Set 2)
3 Defendant County of
Sacramento's First Supplemental
Responses to Plaintiff James
Allison Mayfield, Jr.'s
Interrogatories (Set 2)
4 Defendant County of
Sacramento's Second
Supplemental Responses to
Plaintiff James Allison Mayfield,
Jr.'s Interrogatories (Set 2)
5 Defendant County of
Sacramento's Responses to
Plaintiff James Joshua
Mayfield's Interrogatories (Set
1)
6 Defendant County of
Sacramento's First Supplemental
Responses to Plaintiff James
Joshua Mayfield's
Interrogatories (Set 1)
7 Defendant County of
Sacramento's Second
Supplemental Responses to
Plaintiff James Joshua
Mayfield's Interrogatories (Set
1)
8 Defendant County of
Sacramento's Responses to
Plaintiff James Joshua
Mayfield's Interrogatories (Set
2)
9 Defendant County of
Sacramento's First Supplemental
Responses to Plaintiff James
Joshua Mayfield's
Interrogatories (Set 2)
10 Defendant County of
Sacramento's Second
Supplemental Responses to
Plaintiff James Joshua
Mayfield's Interrogatories (Set
2)
11 Defendant County of
Sacramento's Responses to
Plaintiff James Joshua
Mayfield's Interrogatories (Set
3)
12 Defendant County of
Sacramento's First Supplemental
Responses to Plaintiff James
Joshua Mayfield's
Interrogatories (Set 3)
Defendant Robert Hales
13 Defendant Dr. Robert Hales'
Responses to Plaintiff James
Joshua Mayfield's
Interrogatories (Set 1)
14 Defendant Dr. Robert Hales'
First Supplemental Responses to
Plaintiff James Joshua
Mayfield's Interrogatories (Set
1)
Defendant Scott Jones
15 Defendant Scott Jones'
Responses to Plaintiff James
Joshua Mayfield's
Interrogatories (Set 1)
16 Defendant Scott Jones' First
Supplemental Responses to
Plaintiff James Joshua
Mayfield's Interrogatories (Set
1)
17 Defendant Scott Jones' Second
Supplemental Responses to
Plaintiff James Joshua
Mayfield's Interrogatories (Set
1)
Defendant James Lewis
18 Defendant James Lewis'
Responses to Plaintiff James
Joshua Mayfield's
Interrogatories (Set 1)
19 Defendant James Lewis' First
Supplemental Responses to
Plaintiff James Joshua
Mayfield's Interrogatories (Set
1)
20 Defendant James Lewis' Second
Supplemental Responses to
Plaintiff James Joshua
Mayfield's Interrogatories (Set
1)
Defendant Ivan Orozco
21 Defendant Ivan Orozco's
Responses to Plaintiff James
Joshua Mayfield's
Interrogatories (Set 1)
22 Defendant Ivan Orozco's
Amended Responses to Plaintiff
James Joshua Mayfield's
Interrogatories (Set 1) (dated
January 26, 2016)
23 Defendant Ivan Orozco's
Amended Responses to Plaintiff
James Joshua Mayfield's
Interrogatories (Set 1) (dated
March 18, 2016)
24 Defendant Ivan Orozco's
Responses to Plaintiff James
Joshua Mayfield's
Interrogatories (Set 2)
25 Defendant Ivan Orozco's Further
Responses to Plaintiff James
Joshua Mayfield's
Interrogatories (Set 2)
26 Defendant Ivan Orozco's
Responses to Plaintiff James
Joshua Mayfield's
Interrogatories (Set 3)
27 Defendant Ivan Orozco's
Supplemental Responses to
Plaintiff James Joshua
Mayfield's Interrogatories, Nos.
10-12 (Set 3)
28 Defendant Ivan Orozco's
Responses to Plaintiff James
Joshua Mayfield's
Interrogatories (Set 4)
Defendant Rick Pattison
29 Defendant Rick Pattison's
Responses to Plaintiff James
Joshua Mayfield's
Interrogatories (Set 1)
30 Defendant Rick Pattison's First
Supplemental Responses to
Plaintiff James Joshua
Mayfield's Interrogatories (Set
1)
31 Defendant Rick Pattison's
Second Supplemental Responses
to Plaintiff James Joshua
Mayfield's Interrogatories (Set
1)
Defendant Regents of the University of California
32 Defendant Regents of the
University of California's
Responses to Plaintiff James
Joshua Mayfield's
Interrogatories (Set 1)
Defendant Charles Scott
33 Defendant Dr. Charles Scott's
Responses to Plaintiff James
Joshua Mayfield's
Interrogatories (Set 1)
Defendant Gregory Sokolov
34 Defendant Dr. Gregory
Sokolov's Responses to Plaintiff
James Joshua Mayfield's
Interrogatories (Set 1)
35 Defendant Dr. Gregory
Sokolov's First Supplemental
Responses to Plaintiff James
Joshua Mayfield's
Interrogatories (Set 1)
36 Defendant Dr. Gregory
Sokolov's Responses to Plaintiff
James Joshua Mayfield's
Interrogatories (Set 2)
37 Defendant Dr. Gregory
Sokolov's Supplemental
Responses to Plaintiff James
Joshua Mayfield's
Interrogatories (Set 2) (dated
July 18, 2016)
38 Defendant Dr. Gregory
Sokolov's Supplemental
Responses to Plaintiff James
Joshua Mayfield's
Interrogatories (Set 2) (dated
August 25, 2016)
39 Defendant Dr. Gregory
Sokolov's Responses to Plaintiff
James Joshua Mayfield's
Interrogatories (Set 3)
40 Defendant Dr. Gregory
Sokolov's Supplemental
Responses to Plaintiff James
Joshua Mayfield's
Interrogatories (Set 3) (dated
May 24, 2016)
41 Defendant Dr. Gregory
Sokolov's Supplemental
Responses to Plaintiff James
Joshua Mayfield's
Interrogatories (Set 3) (dated
October 4, 2016)
Defendant UC Davis Health System
42 Defendant UC Davis Health
System's Responses to Plaintiff
James Joshua Mayfield's
Interrogatories (Set 1)
43 Defendant UC Davis Health
System's First Supplemental
Responses to Plaintiff James
Joshua Mayfield's
Interrogatories (Set 1)
44 Defendant UC Davis Health
System's Responses to Plaintiff
James Joshua Mayfield's
Interrogatories (Set 2)
45 Defendant UC Davis Health
System's First Supplemental
Responses to Plaintiff James
Joshua Mayfield's
Interrogatories (Set 2)
46 Defendant UC Davis Health
System's Responses to Plaintiff
James Joshua Mayfield's
Interrogatories (Set 3)
47 Defendant UC Davis Health
System's Supplemental
Responses to Plaintiff James
Joshua Mayfield's
Interrogatories (Set 3) (dated
May 24, 2016)
48 Defendant UC Davis Health
System's Supplemental
Responses to Plaintiff James
Joshua Mayfield's
Interrogatories (Set 3) (dated
October 4, 2016)
49 Defendant UC Davis Health
System's Responses to Plaintiff
James Joshua Mayfield's
Interrogatories (Set 4)
REQUESTS FOR ADMISSION
50 Defendant County of
Sacramento's Responses to
Plaintiff James Joshua
Mayfield's Requests for
Admission (Set 1)
51 Defendant Ivan Orozco's
Responses to Plaintiff James
Joshua Mayfield's Requests for
Admission (Set 1)
52 Defendant UC Davis Health
System's Responses to Plaintiff
James Joshua Mayfield's
Requests for Admission (Set 1)
DEPOSITIONS
53 Deposition transcript of Ricardo
Avila
(May 3, 2016)
54 Deposition transcript of Dylan
Black
(May 5, 2016)
55 Deposition transcript of Aron
Brewer
(February 10, 2016)
56 Deposition transcript of Amy
Burton
(September 2, 2016)
57 Deposition transcript of
Nathaniel Carter
(October 3, 2016)
58 Deposition transcript of Quentin
Carthen
(October 6, 2016)
59 Deposition transcript of Edgar
Catingub
(August 10, 2016)
60 Deposition transcript of Mark
Cohen
(October 21, 2016)
61 Deposition transcript of Steve
Cortez
(February 9, 2016)
62 Deposition transcript of Raylene
Cully
(September 8, 2016)
63 Deposition transcript of Deputy
Philip Daw
(June 2, 2016)
64 Deposition transcript of Lynn
Delgado
(February 12, 2016)
65 Deposition transcript of Lorilene
Emmanuel
(July 20, 2016)
66 Deposition transcript of Linda
Evans
(July 22, 2016)
67 Deposition transcript of Rachel
Fitch
(February 22, 2016)
68 Deposition transcript of
Marcella Fitzgerald
(September 2, 2016)
69 Deposition transcript of Bruce
Gage
(August 29, 2016)
70 Deposition transcript of
Benjamin Gonzales
(May 5, 2016)
71 Deposition transcript of Nate
Grgich
(September 8, 2016)
72 Deposition transcript of
Robert Hales
(February 25, 2016)
73 Deposition transcript of
Walter Harrell
(September 29, 2016)
74 Deposition transcript of
Walter Harrell
(September 29, 2016)
75 Deposition transcript of
Lindsay Hayes
(October 18, 2016)
76 Deposition transcript of
Thomas L. Hedge
(October 25, 2016)
77 Deposition transcript of
Stacey Helvin
(October 05, 2016)
78 Deposition transcript of
Jeffrey Hislop
(October 10, 2016)
79 Deposition transcript of
Andrea Javist
(November 01, 2016)
80 Deposition transcript of
Andrea Javist
(July 12, 2016)
81 Deposition transcript of
Scott Jones
(August 01, 2016)
82 Deposition transcript of
Robin Kolb
(May 06, 2016)
83 Deposition transcript of
Scott Kush
(October 25, 2016)
84 Deposition transcript of
Juan Latorre
(September 30, 2016)
85 Deposition transcript of
James Lewis
(October 12, 2016)
86 Deposition transcript of
Orlando Mayes
(February 10, 2016)
87 Deposition transcript of
James Joshua Mayfield
(July 26, 2016)
88 Deposition transcript of
James Jr. Mayfield
(August 3, 2016)
89 Deposition transcript of
Terri Mayfield
(July 25, 2016)
90 Deposition transcript of
Charles Munn
(February 27, 2016)
91 Deposition transcript of
Nicholas Newsome
(October 3, 2016)
92 Deposition transcript of
Margo Orgus
(October 19, 2016)
93 Deposition transcript of
Ivan Orozco
(November 30, 2016)
94 Deposition transcript of
Ivan Orozco
(March 1, 2016)
95 Deposition transcript of
Thomas Owley
(October 6, 2016)
96 Deposition transcript of
Raymond Patterson
(October 11, 2016)
97 Deposition transcript of
Captain Richard (Rick) Pattison
(May 26, 2016)
98 Deposition transcript of
Joseph Penn
(November 04, 2016)
99 Deposition transcript of
Michael Pietrek
(June 1, 2016)
100 Deposition transcript of
Anthony Reading
(October 7, 2016)
101 Deposition transcript of
Jason Roof
(June 24, 2016)
102 Deposition transcript of
Jeffrey Schwartz
(September 27, 2016)
103 Deposition transcript of
Charles Scott
(February 17, 2016)
104 Deposition transcript of
Narriman Shahrokh
(February 26, 2016)
105 Deposition transcript of
Mike Singer
(March 9, 2016)
106 Deposition transcript of
Gregory Sokolov
(November 01, 2016)
107 Deposition transcript of
Gregory Sokolov
(June 27, 2016)
108 Deposition transcript of
Gregory Sokolov
(June 22, 2016)
109 Deposition transcript of
Gary M. M.D. Vilke
(October 26, 2016)
110 Deposition transcript of
Rosalinda Vizina
(September 20, 2016)
111 Deposition transcript of
Rosalinda Vizina
(July 27, 2016)
112 Deposition transcript of
Jeffrey Wilson
(May 05, 2016)
113 Deposition transcript of
Jin-Mei Woan
(September 7, 2016)
114 Deposition transcript of
Andrea Yanez
(August 31, 2016)
115 Deposition transcript of
Ed Yee
(May 3, 2016)
EXHIBIT "H"
LONGYEAR, O'DEA & LAVRA, LLP
VAN LONGYEAR, CSB NO. 84189
PETER C. ZILAFF, CSB NO. 272658
NICOLE M. CAHILL, CSB NO. 287165
3620 American River Drive, Suite 230
Sacramento, California 95864-5923
Tel: (916) 974-8500 Fax: (916) 974-8510
Attorneys for Defendants, County of Sacramento, Scott Jones,
James Lewis and Rick Pattison
UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF CALIFORNIA
Estate of JAMES JOSHUA MAYFIELD, by CASE NO. 2:13-CV-02499-JAM-AC
and through LISA BERG, as Conservator;
JAMES ALLISON MAYFIELD, JR.;
and TERRI MAYFIELD, DEFENDANTS' DISCOVERY
DOCUMENTS LIST
Plaintiffs,
EXHIBIT "H"
vs.
IVAN OROZCO, in his individual capacity;
SHERIFF SCOTT JONES, in his individual
and official capacity; JAMES LEWIS, in his
individual and official capacity; RICK
PATTISON, in his individual and official
capacity; COUNTY OF SACRAMENTO;
UNIVERSITY OF CALIFORNIA DAVIS
HEALTH SYSTEM; DR. GREGORY
SOKOLOV, in his individual capacity; DR.
ROBERT HALES, in his individual
capacity; and Does 1-5,
Defendants.
Ex. Description Bates No. Intro by Admitted
ID
Depositions
1 Deposition transcript of
Avila, Ricardo
(May 3, 2016)
2 Deposition transcript of
Black, Dylan
(May 5, 2016)
3 Deposition transcript of
Brewer, Aron
(February 10, 2016)
4 Deposition transcript of
Burton, Amy
(September 2, 2016)
5 Deposition transcript of
Carter, Nathaniel
(October 3, 2016)
6 Deposition transcript of
Carthen, Quentin
(October 6, 2016)
7 Deposition transcript of
Catingub, Edgar Dr.
(August 10, 2016)
8 Deposition transcript of
Cohen, Mark/Expert
(October 21, 2016)
9 Deposition transcript of
Cortez, Steve
(February 9, 2016)
10 Deposition transcript of
Cully, Raylene
(September 8, 2016)
11 Deposition transcript of Daw,
Philip
(June 2, 2016)
12 Deposition transcript of
Delgado, Lynn
(February 12, 2016)
13 Deposition transcript of
Emmanuel, Lorilene
(July 20, 2016)
14 Deposition transcript of
Evans, Linda
(July 22, 2016)
15 Deposition transcript of Fitch,
Rachel
(February 22, 2016)
16 Deposition transcript of
Fitzgerald, Marcella
(September 2, 2016)
17 Deposition transcript of
Gonzales, Benjamin
(May 5, 2016)
18 Deposition transcript of
Grgich, Nathaniel
(September 8, 2016)
19 Deposition transcript of
Hales, Robert
(February 25, 2016)
20 Deposition transcript of
Harrell, Walter/Expert
(September 29, 2016)
21 Deposition transcript of
Hayes, Lindsay/Expert
(October 18, 2016)
22 Deposition transcript of
Hedge, Thomas/Expert
(October 25, 2016)
23 Deposition transcript of
Helvin, Stacey/Expert
(October 5, 2016)
24 Deposition transcript of
Hislop, Jeffrey/Expert
(October 10, 2016)
25 Deposition transcript of
Javist, Andrea
(July 2, 2016)
26 Deposition transcript of
Javist, Andrea
(November 1, 2016)
27 Deposition transcript of
Jones, Scott Sheriff
(August 1, 2016)
28 Deposition transcript of
Kolb, Robin
(May 6, 2016)
29 Deposition transcript of
Kush, Scott/Expert
(October 25, 2016)
30 Deposition transcript of
Latorre, Juan/Expert
(September 30, 2016)
31 Deposition transcript of
Lewis, Jamie
(October 12, 2016)
32 Deposition transcript of
Mayes, Orrlando
(February 10, 2016)
33 Deposition transcript of
Mayfield, James Alison
(August 3, 2016)
34 Deposition transcript of
Mayfield, James Joshua
(July 26, 2016)
35 Deposition transcript of
Mayfield, Terri
(July 25, 2016)
36 Deposition transcript of
Munn, Charles
(February 22, 2016)
37 Deposition transcript of
Newsome, Nicholas
(October 3, 2016)
38 Deposition transcript of
Ogus, Margo/Expert
(October 19, 2016)
39 Deposition transcript of
Orozco, Ivan
(March 1, 2016)
40 Deposition transcript of
Owley, Thomas
(October 6, 2016)
41 Deposition transcript of
Patterson, Raymond/Expert
(October 11, 2016)
42 Deposition transcript of
Pattison, Richard
(May 26, 2016)
43 Deposition transcript of
Penn, Joseph/Expert
(November 4, 2016)
44 Deposition transcript of
Pietrek, Michael
(June 1, 2016)
45 Deposition transcript of
Reading, Anthony/Expert
(October 7, 2016)
46 Deposition transcript of
Roof, Jason M.D.
(June 24, 2016)
47 Deposition transcript of
Schwartz, Jeffrey/Expert
(September 27, 2016)
48 Deposition transcript of
Scott, Charles M.D.
(February 17, 2016)
49 Deposition transcript of
Shahrokh, Narriman
(February 26, 2016)
50 Deposition transcript of
Singer, Mike
(March 8, 2016)
51 Deposition transcript of
Sokolov, Gregory M.D. [as
named party]
(June 27, 2016)
52 Deposition transcript of
Sokolov, Gregory M.D. [as
30(b)(6)]
(June 22, 2016)
53 Deposition transcript of
Sokolov, Gregory M.D.
[second]
(November 1, 2016)
54 Deposition transcript of
Vilke, Gary/Expert
(October 26, 2016)
55 Deposition transcript of
Vizina, Rosalinda
(July 27, 2016)
56 Deposition transcript of
Vizina, Rosalinda [second]
(September 20, 2016)
57 Deposition transcript of
Wilson, Jeffrey
(May 5, 2016)
58 Deposition transcript of
Woan, Jin-Mei
(September 7, 2016)
59 Deposition transcript of
Yanez, Andrea
(August 31, 2016)
60 Deposition transcript of
Yee, Ed
(May 3, 2016)
Interrogatories
61 James Alison Mayfield's
Responses to Defendant
County of Sacramento's
Interrogatories (Set one)
62 Plaintiff James Joshua
Mayfield's Responses to
Defendant Scott Jones
Interrogatories (Set one)
63 Plaintiff James Joshua
Mayfield's Responses to
Defendant County of
Sacramento's Interrogatories
(Set one)
64 Terri Mayfield's Responses
to Defendant County of
Sacramento's Interrogatories
(Set one)
Dated: March 21, 2017 LONGYEAR, O'DEA & LAVRA, LLP
By:______________________________________
VAN LONGYEAR
PETER C. ZILAFF
NICOLE M. CAHILL
Attorneys for Defendants
County of Sacramento, Scott Jones,
James Lewis and Rick Pattison
EXHIBIT "I"
DEFENDANT IVAN OROZCO'S DISCOVERY LIST
EXHIBIT "I"
No. Document
1. Plaintiff James Joshua Mayfield's Responses and Objections to Defendant Dr. Gregory
Sokolov's Request for Production of Documents, Set One
2. Responses and Objections of Plaintiff James Joshua Mayfield to Defendant Dr. Sokolov's
Special Interrogatories, Set One
3. Deposition transcript of Brewer, Aron (February 10, 2016)
4. Deposition transcript of Burton, Amy (September 2, 2016)
5. Deposition transcript of Catingub, Edgar Dr. (August 10, 2016)
6. Deposition transcript of Cohen, Mark/Expert (October 21, 2016)
7. Deposition transcript of Cortez, Steve (February 9, 2016)
8. Deposition transcript of Delgado, Lynn (February 12, 2016)
9. Deposition transcript of Emmanuel, Lorilene (July 20, 2016)
10. Deposition transcript of Evans, Linda (July 22, 2016)
11. Deposition transcript of Fitch, Rachel (February 22, 2016)
12. Deposition transcript of Fitzgerald, Marcella (September 2, 2016)
13. Deposition transcript of Grgich, Nate (September 8, 2016)
14. Deposition transcript of Hales, Robert (February 25, 2016)
15. Deposition transcript of Harrell, Walter/Expert (September 29, 2016)
16. Deposition transcript of Hayes, Lindsay/Expert (October 18, 2016)
17. Deposition transcript of Hedge, Thomas/Expert (October 25, 2016)
18. Deposition transcript of Helvin, Stacey/Expert (October 5, 2016)
19. Deposition transcript of Javist, Andrea, Vol. 1 (July 12, 2016)
20. Deposition transcript of Javist, Andrea, Vol. 2 (November 1, 2016)
21. Deposition transcript of Kush, Scott/Expert (October 25, 2016)
22. Deposition transcript of Latorre, Juan/Expert (September 30, 2016)
23. Deposition transcript of Mayfield, James Alison (August 3, 2016)
24. Deposition transcript of Mayfield, James Joshua (July 26, 2016)
25. Deposition transcript of Mayfield, Terri (July 25, 2016)
26. Deposition transcript of Munn, Charles (February 22, 2016)
27. Deposition transcript of Ogus, Margo/Expert (October 19, 2016)
28. Deposition transcript of Orozco, Ivan (March 1, 2016)
29. Deposition transcript of Owley, Thomas (October 6, 2016)
30. Deposition transcript of Patterson, Raymond/Expert (October 11, 2016)
31. Deposition transcript of Penn, Joseph/Expert (November 4, 2016)
32. Deposition transcript of Reading, Anthony/Expert (October 7, 2016)
33. Deposition transcript of Roof, Jason M.D. (June 24, 2016)
34. Deposition transcript of Schwartz, Jeffrey/Expert (September 27, 2016)
35. Deposition transcript of Shahrokh, Narriman (February 26, 2016)
36. Deposition transcript of Singer, Mike (March 8, 2016)
37. Deposition transcript of Sokolov, Gregory M.D., (PMK) (June 22, 2016)
38. Deposition transcript of Sokolov, Gregory M.D., Vol. 1 (June 27, 2016)
39. Deposition transcript of Sokolov, Gregory M.D., Vol. 2 (November 1, 2016)
40. Deposition transcript of Vizina, Rosalinda, Vol. 1 (July 27, 2016)
41. Deposition transcript of Vizina, Rosalinda, Vol. 2 (September 20, 2016)
42. Deposition transcript of Woan, Jin-Mei (September 7, 2016)
43. Deposition transcript of Yanez, Andrea (August 31, 2016)
44. Deposition transcript of Quentin Carthen (October 3, 2016)
45. Deposition transcript of Nathaniel Carter (October 3, 2016)
46. Deposition transcript of Nicholas Newsome (October 6, 2016)
