A SUPERIOR COURT OF CALIFORNIA COUNTY OF SAN FRANCISCO Document Scanning Lead Sheet Oct-03-2017 10:26 am Case Number: CGC-16-555910 Filing Date: Oct-03-2017 10:20 Filed by: RONNIE OTERO Image: 06049157 GENERIC CIVIL FILING (NO FEE) CHARLES PITTS VS. CITY AND COUNTY OF SAN FRANCISCO, HUMAN SERVICES ET AL 001006049157 Instructions: Please place this sheet on top of the document to be scanned.20 a 22 23 24 CHARLES PITTS ‘San Francisdo Codhty Superior Court PO BOX 641452 SAN FRANCISCO CA. 94164 1415 368 2354 PAKASAW@YAHOO.COM ot In Pro Per t coe SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SAN FRANCISCO CHARLES PITTS Case No. CGC-16-555910 Plaintiff, PLAINTIFFS OPPOSITION TO 2 DEFENDANT CITY AND COUNTY OF Me SAN FRANCISCO’S , HUMAN CITY AND COUNTY OF SAN SERVICES AGENCY, FRANCISCO EPISCOPAL COMMUNITY SERVICES OF SAN FRANCISCO DEMURRER HUMAN SERVICES AGENCY, EPISCOPAL COMMUNITY SERVICES OF SAN FRANCISCO and DOES | to 20 Defendant(s) INTRODUCTION Plaintiff moved into a the navigation center on or near 1-20-2017 The staff violated many parts of the standards of care. San Francisco administrative code 20.400 Just some of the main points . 1) The defendants protected several clients that were abusive and violent towards the plaintiff . Plaintiff was called racial slurs and sexual preference slurs. the defendants EPISCOPAL COMMUNITY SERVICES OF SAN FRANCISCO protected the people physically and emotionally harassing and abusing plaintiff . The defendants staff did nothing and protected several clients that were violent and harassing towards the plaintiff . Defendants EPISCOPAL COMMUNITY SERVICES OF SAN FRANCISCO protected the people including blocking sheriff service of a 1 102/2017 PLAINTIFFS OPPOSITION DEMURRER23 24 25 26 20 28 restraining order. 2.) The defendants did Not having a viable grievance policy . They have a system where the defendants are the judge , jury and executioner , regarding incidents that happen on the Premises in contradiction to the standards of care and the contract with the city and county of San Francisco . The contractor blindly followed what their staff said even thou staff violated their training and a average persons better judgement , even when shown evidence. All defendants didn’t act appropriately. regarding investigating and enforcing the contracts and laws regarding the contract and standards of care , San Francisco administrative code 20.400. 3) EPISCOPAL COMMUNITY SERVICES OF SAN FRANCISCO didn’t having proper controls regarding people entering the Premises and people entering different dorms after stripping the violent client bed they allowed the violent client in without knowing if it was right to do so . 4) The city poorly monitored the standards of care part of its contracts , If at all . One person who monitors the city contract told me they don’t monitor the standard of care part of the contract . 5 )The defendant has continually demanded I drop the complaint and that defendants have immunity to treat clients who use the shelter services with immunity .The shelter system has a history of exploiting its clients for sex and have been open drug dens. These are the things the defendants are fighting to keep in place by demanding the shelters have no liability towards its clients and the citizens of San Francisco and that the CITY AND COUNTY OF SAN FRANCISCO have no obligation to monitor contracts it pays people to preform . PLAINTIFFS OPPOSITION TO DEFENDANTS DEMURRER 1) The defendants council meet and confer letter was vague and ambiguous regarding what should be fixed. The defendants mention page three the defendants didn’t note what idem would need to be amended . Defendants have made it clear they want the case dropped refusing to address the injuries to the plaintiff enacted by the defendants. the defendants are acting in bad faith with this demurrer process . 1302/2017 PLAINTIFFS OPPOSITION DEMURRER