Thursday, December 25, 2008

23rd Request to State for Discovery (March 28, 2008)

RE: Photos For My Son‏
From: cam huegenot (cameocares@live.com)
Sent: Fri 3/28/08 5:15 PM
To: Caballero, Tomas (ATG) (tomasc@atg.wa.gov)
Bcc: dicksiedael@aol.com


Mr. Caballero,

Pro se litigants are NOT held to the same standards; in fact, they are to be regarded with leniency in their pleadings and requests, and even "motions" may be written as letters. Historically, letters by pro se persons, making observable requests (motions) for things, are taken as formal motions and pleadings. To ignore this standard sets the framework for appeal.

You have been aware of what my past discovery requests were, and you responded. Sometimes, you ignored my requests, and put me off, but you acknowledged they were discovery requests. If you now choose to ignore my discovery requests and deny me this information, it will be further proof of bad faith.

You know I had the right to be notified and consulted as to appointments for my son and you ignored this. You and CPS have multiple conflicts of interest. Your office was obtaining information from me months prior to involving CPS, and even told me, after speaking to me for hours, it was a conflict of interest for them to talk to me. I have also found out CASA is headed up by wives of medical professionals in town, all of which have covered up for the damages done to both me and my son. Your "speech therapists" didn't even contact me to obtain a history of my son's development, which, I'm being told, is unprofessional. I have talked to many people, including people with early intervention and PAVE and ADA, and your handling of this case and CPS's handling of this case, amounts to bad faith, discrimination, and an attempt to do what is in the best interest of DSHS, not my son.

Please let me know about discovery.

I have cc'd you in my emails just as Marie has cc'd you and YOU have also cc'd Marie AND CASA. I am unable to afford postage for U.S. mail and email is the only way I am able to make my requests in writing. It would be discriminatory for you to refuse my communications on the basis of poverty. I have the right to be pro se, and there is no law preventing me from advocating for myself and my son, without court appointed "assistance".

Should you choose to ignore my attempts to confer and gain discovery, this will be used in a court of appeals. I remind you, you cannot force me to take representation. The only way I will take representation, is if it is out of the area, with this case being removed to Whatcom or King county.

Thanks

Cameo



----------------------------------------
> Subject: RE: Photos For My Son
> Date: Fri, 28 Mar 2008 10:06:08 -0700
> From: TomasC@ATG.WA.GOV
> To: cameocares@live.com; SCNL300@dshs.wa.gov
>
> Ms. Garrett, I would appreciate if from now on you would not cc me in
> your emails. If you want to communicate with me about your case, you
> can do so via U.S. Mail. I will respond to this last email. If you are
> dissatisfied with Marie's handling of discovery in this case, please
> formulate appropriate discovery pleadings and send to my office. I will
> review them with Marie and answer them pursuant to the court rules. You
> can propound interrogatories, requests for admissions, and request for
> productions. The court rules provide for specific timelines to respond
> to discovery requests. An attorney can certainly assist you in pursuing
> your discovery requests. In the meantime, Ms. Scanlon will continue to
> provide you with discovery pursuant to her office's policies and
> procedures. As you may know, even though you are proceeding "pro se" at
> this time, you are held to the same standards as an attorney.
>
> Regards, Tomas Caballero
>
>
> "Print Only If Necessary"
>
> TOMAS CABALLERO
> Assistant Attorney General
> Regional Services Division
> Wenatchee
> 509-664-6385 / fax 509-664-6391
> E-mail: tomasc@atg.wa.gov
>
>
>
> -----Original Message-----
> From: cam huegenot [mailto:cameocares@live.com]
> Sent: Friday, March 28, 2008 9:58 AM
> To: Scanlon, Marie (DSHS/CA); Caballero, Tomas (ATG)
> Cc: dicksiedael@aol.com; hollybeanpole@aol.com
> Subject: Photos For My Son
>
>
>
> Marie,
>
> I have specifically requested my son have a few photos of me and him,
> and other people he cares about or knew. I asked my mother to send
> Holly some photos and out of all of them, she only printed out ONE for
> my son. The rest he does not have access to. I also asked Holly to
> print out photos of himself and of the two of us together which are easy
> to find on my blog, which Holly reads practically every day, and she has
> not done this.
>
> I also overheard Holly's husband Pablo, say in Spanish (probably
> thinking I wouldn't understand) to company that was there, that Oliver
> didn't like talking on the phone, or to me. I was on the phone with
> Oliver when I overheard this comment.
>
> I am troubled by the fact that not only CPS, but my aunt has not kept me
> informed as to my son's development, progress, and medical appointments,
> and has even refused to give him photos of his mother and himself, from
> the very beginning, which I know are a comfort to my son. It seems the
> plan here, is to try to force me out of my son's life and completely
> BREAK the bond. No effort whatever is being made to keep up the contact
> and communication between us, except as is the MINIMUM mandate by state
> law, which is such a low minimum, it's purpose is to accomodate parents
> who really do mentally abuse their kids, or physically abuse them, who
> may even be a disturbing presence to their kids.
>
> This is not the case with me or my son. My son needs more time with me
> and enjoys our time together. Last visit, he didn't cry when my aunt
> left, at all, and he didn't want to leave me at the end of the visit
> either, and that's with only 4 hours a week contact, after almost an
> initial first month of total separation.
>
> My aunt has already told me Pablo likes to have Oliver around and I
> believe their interest is in trying to adopt him. My own grandparents
> told me this was the case, and that they support this because I'm, of
> course, not capable of meeting his "spiritual needs" is what they would
> say. They want my son to be a holy-roller, no buts about it. They want
> my son to receive "laying on of hands" and probably hope he's even
> "speaking in tongues" by the time he's 4. Maybe they even think that's
> what he does NOW when he babbles. My son is not speaking more with my
> aunt either. His verbal progress is the same as it was with me==nothing
> at all except one or two words and then extremely slow additions which
> are mispronounced.
>
> I gave my son's medical records to the last lawyer I was talking to and
> have to get them back. I therefore cannot have them faxed today, but
> hope to get them to you by Monday.
>
> Please obtain my son's pediatric dental appointment records from the
> Wenatchee clinic and U of W clinic, to see the diagnosis for his enamel
> dysplasia, which they said was caused by his birth trauma and is rare.
> He didn't have "teeth trauma" as Pamela weirdly put it (did she even go
> to college? if someone needs Mensa testing, she does), and my son's
> birth injuries are real
>
> I am concerned that my aunt, even in her own house, is not doing things
> to foster and keep up contact and my memory with my son. He loves to
> look at photos, and she won't give them to my son.
>
> She also refused to tell me about the speech therapist, which is odd.
> She told me about him seeing a PCP, but not the speech therapist. I
> believe either she was advised by YOU not to discuss the speech therapy
> with me, or ?
>
> I know my mother and my aunt Holly are extremely close. If I am in an
> argument with my mother, Holly always defends my mom, no matter how
> wrong she is. Holly would attempt to keep Oliver from me, to punish me,
> on behalf of my mother. As I have included some things about my mother
> in my blog, my mother refuses to answer my email or respond, and Holly
> began taking it out on me. She will work against me, the entire Baird
> family will, to conceal their own problems, which are multiple.
>
> I want my son to get the photos Holly has already, all she has to do is
> PRINT THEM OUT and give them to my son. I've already asked, more than
> once. I also want you to obtain my son's dental records, because I
> don't have those and I'll get the other ones to you on Monday.
>
> Finally, I want ANY and ALL medical records for my son, sent to me.
> This is discovery and my right as a parent to have. I need the names of
> the clinics and people he's seen already.
>
> You have not responded to my requests for these records. Please do so
> today.
>
> Thanks.
>
> Cameo

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