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Timeline of State Kidnapping

2001
November 14, 2001	Nancy Golin wanders from parents at their workplace as they were moving in at 8:30PM. Parents immediately call police for help and search all night.
November 15, 2001	Police treat parents as suspects in am, delay parents’ search. Parents go to PAPD station, offer $10,000 reward. Police call parents cell phone 6 AM, ask them to return to workplace. Police call out five building inspectors at 8am to shut down business for alleged code violations, impairing parent’s ability to sustain income; Gas meter pulled. Nancy returns 11 AM, while police are detaining parents, searching and photographing their car. Nancy is smiling, healthy, seems fine, and goes into mother’s shop. Police barge in without warrant, search, and seize Nancy’s prescription anti-seizure medication. Police put Nancy in Stanford Hospital, on 72-hr psych hold in locked ward, clear violation of her rights as a developmentally disabled person. Parents ordered to leave or be arrested.
November 16, 2001	TRO obtained against parents to prevent seeing Nancy or taking her out. The 72-hour psych hold is extended to thirteen days. Stanford psychiatrists take Nancy off the anti-seizure medication prescribed by her neurologists. They experiment on Nancy with different anti-seizure medications and dosages; Nancy goes into prolonged seizures at hospital that continue throughout period. Doctors turn away outside medical advice and information. They let Nancy get into beds with the mental patients and eat off their dishes. Doctors find no mental illness, yet start drugging her on Trazidone, Ativan.
November 18, 2001	Parents go to the Palo Alto Daily News with story, initially report favorably to parents, then receive false prejudicial information from police, and begin to libel parents. Parents shown copy of heavily falsified police report. DA gives statement to press that we will “undoubtedly” be found guilty and sentenced to prison for four years, that we supposedly have long criminal histories. Seek help from attorney Kazubowski. Dr. Kaplan calls to offer information to doctors about medical history and care, supporting parents.
November 21, 2001	Stanford psych doctor Luu calls APS telling them Nancy is not safe with men there, asking her to be moved, also inappropriate for her to be there since she is developmentally disabled not mentally ill. APS disagrees insisting Nancy stay there.
November 23-26, 2001	All records of Nancy at Stanford Hospital for this period are suppressed after apparent undisclosed serious incident. Risk management called.
November 27, 2001	Unreported incident regarding Nancy causes panic meeting to be held by all parties, APS, PAPD, SARC, Stanford, and risk management is called. Narrative to conversations is missing. Same gap in both Stanford and APS records.
November 28, 2001	TRO runs out, last legal authority to hold, SARC decides against hearing, parents go to pick Nancy up at hospital, Stanford refuses to release Nancy. Nancy is instead removed to Embee Manor, but her whereabouts are undisclosed, newspapers are unable to find her. SARC Places Nancy at Embee, forges her signature in five places on IPP to place her without authorization. Nancy does not write or speak.
November 30, 2001	Parents each arrested on false allegations of abuse, $50,000 felony warrants filed. Released on bail within 24 hours contrary to police expectations. After making bail, police send Elsie to Valley Medical Center for attempted 72 hour psych hold, grill her and keep her in shackles and chains demanding to know where she keeps her cash, then release after overnight stay. Palo Alto Police detective reports release with panic call to APS, concerned parents will go back to newspapers. DA libels parents to newspapers, which publish defamatory information. When Elsie returns she finds $2,000 in cash missing from her jacket pocket.
December, 2001	a) SARC rushes to get Temporary Conservatorship without court approval, DDS declines. No legal authority to hold admitted. Nancy’s whereabouts kept secret. APS admits Nancy could go with parents if she wanted, but admit they want at all costs to avoid court or any hearing. Not placed in any program. Denied visits by anyone that knew her previously.) Meanwhile, some undisclosed incident reported at Embee Manor while Nancy is there which is so serious it results in the firing of entire staff. New staff including current caretaker Lynn is newly employed, observe Nancy to be very ill, are misinformed reason is parent abuse.
2002
January 2, 2002	Parents first arraignment before Judge Manoukian, no contact order imposed at request of Department of Developmental Services, supervised visits ordered, but APS does not comply. Parents present rebuttal letter from Dr. Kaplan shortly after to DA. Mr. Golin represented by Kazubowski; Mrs. Golin represented by public defender.
February 2, 2002 (Sunday 2am)	Mountain View Police spot van in parking lot, question Jeff whether Elsie is inside. Force Elsie out, place under arrest again under same warrant that she was arrested on November 30, which she had discharged at that time, claiming that the warrant was still outstanding. Elsie shows them jail bracelet she is still wearing in protest from 11/30 arrest. Nonetheless, put her in handcuffs, hold her in the back of patrol car, detain and deny use of bathroom. Contents of pockets including notes and money placed on hood of patrol car to blow away. She is finally released after an hour. Tried to prevent her from driving away after release. Later investigation showed warrant was not still outstanding in computer at the time.
February 4, 2002	DA states that if Kaplan letter is verified true, parents will be dismissed; orders all medical records to investigate. Judge repeats orders for supervised visitation; but County still does not comply.
March 1, 2002	Judge Manoukian threatens County with contempt of Court if visits do not begin in 3 days. County does not comply. States he is “surprised nobody seems to be able to control these people”. Subpoenaed documents coming in large boxes for review, no decision on dismissal. Mother’s public defender attorney refuses to allow her to see the subpoenaed evidence, refuses to subpoena refuting information or interview any witnesses, and behind the scenes actively worked against mother’s defense. Kazubowski lets parents study documents at length. Find evidence of collusion, fraud and cover-up.
March 21, 2002	Parents see Nancy for 1 hr offsite for first time in 4-1/2 months under APS supervision, Nancy shows signs of molestation, she is all bent over and clutching her crotch with both hands. Nancy is heavily sedated. Parents are told visits will terminate if they ask questions about Nancy’s condition. Visits held for 1 hrs per week, under severely oppressive conditions. Parents plead with the Court, DA, Social Services director, and disability rights groups to help Nancy, all to no avail. The public defender refuses to allow mother to see the any of the records provided by the DA.
April 21, 2002	DDS secretly petitions for conservatorship, still no legal authority to hold Nancy, avoid serving notice on parents. Both the DDS and the County Public Defender falsely allege to the Court that the parents have been “done jail time” for abusing Nancy and their whereabouts are unknown. Two more monthly hearings on matter falsely claiming this, while meetings and visits go on constantly between parents and County. Kazubowski’s review of documents for defense reveals all proofs of innocence needed, but case continues with no sign of promised dismissal.
May 7, 2002	Careworkers secretly take Nancy to Dr. Cerezo to ask for her to be drugged further on Risperdal, falsely claiming psychiatric symptoms that she has become fearful since visits with parents began, claiming to Cerezo that she was there at Embee because parents had abused her and were in jail. Unreported to parents.
July 15, 2002	Mrs. Golin hires effective private counsel, Eric Conner. Second subpoena for documents by DA reveals even less evidence against them than first. Case drags on every month.
July 15, 2002	Parents move to Merced County to get away from SARC area and Santa Clara County jurisdiction.
July 31, 2002	SARC forced by Gallagher to give notice to parents of previously secret Conservatorship petition. Parents finally find confirmation of her whereabouts in filings.
August 1, 2002	Parents inspect Court file and find DDS’s petition and three prior undisclosed hearings; get transcripts made claiming parents whereabouts were unknown, and claiming that Nancy was evaluated with dementia by quack doctor.
August 10, 2002	Obtain Probate Investigator’s report showing Nancy’s room at Embee stinks and Embee claims Nancy was urinating on the floor; but Nancy does not have this behavior. That would happen only if she were having seizures, but Embee denies this. SARC gives report falsely claiming Nancy has dementia, and is too ill to come to the probate court; MD who has lost his license issues it.
August 14, 2002	Nancy appears at supervised visit showing signs of serious abuse: ripped off fingernail on middle finger of right hand, raw nail bed without bandage, claw marks on left hand, bloody mouth, bruised cheek. No explanation. Parents call police to report abuse but APS Buckmaster turns them away, telling them parents are criminals. Father searched by police. (Declaration regarding this misdated as July 14). Date might correlate with later discovered clavicle fracture. Parents report to court.
August 17, 2002	Parents react and file own Petition to counter DDS’ and objection to DDS. Parents file extensive declarations on all issues showing innocence and fitness.
August 20, 2002	Probate hearing before Judge Ward, first hearing at which parents are present. Hearing set for 2 months to allow time for investigation of conservators. Parents object to failure to notify.
August 28, 2002	Visit cancelled without notice or explanation.
August 29, 2002	Careworkers again take Nancy for x-rays at Meridian Medical Clinic. No injury reported by them; radiologist’s report is missing from the file, but the X-ray shows the recent collarbone break with no dislocated shoulder. Careworker suddenly begins to lift Nancy up from under arms rather than pulling on arms, instructing everyone else to do same. The break is not treated and heals into permanent deformity.
September 14, 2002	Nancy begun in day program for first time since abduction, after parents complained in objection that she had no activities, despite their similar complaints about the parents. Parents not allowed to view. Someone attempts to visit Nancy at Embee; Despite lack of no-contact order for her, she is turned away by careworker who calls APS/Buckmaster who screams demanding to know how she found secret address.
September 30, 2002(Nancy’s 32^nd birthday)	Embee issues Fourth Quarterly Report on Nancy showing 118 incidents of wandering or AWOL at Embee in the nine months since December, 2001 contrary to claims.
October 3, 2002	First Habeas Corpus Writ Filed by Parents.
October 7, 2002	Order granting Writ of Habeas Corpus, petitioned by parents, issued by Gallagher after reviewing entire file, Order to show cause issued.
October 15, 2002	Conservatorship Petition before Ward, Parents speak at length before the Court about their work with Nancy and refuting all known false allegations. DA Hey listens in gallery. Elsie talks of how the State and County, while often doing a fine job with the mildly developmentally disabled, tend to badly mistreat the more severely impaired ones like Nancy. Private non-professional Temporary Conservator (TC) appointed over objection of the Public defender DDS and APS. All pending Petitions are continued to February 4, 2003 Status review hearing. Date set to give parents sufficient time for clearing of criminal matters. Parents finally allowed seeing Nancy, notes Nancy’s signs of brain damage, distinct signs of tardive dyskinesia, videos taken. orders careful discontinuation of the psychotropic drugs. Later find transcripts of hearing contain many large deleted portions, parents object but transcript remains uncorrected.
October 27, 2002	DA continues case against parents and will not discuss with defense counsel, but reduces charges to misdemeanor, offers insignificant penalties, removes APS as visit supervisor. Moves for trial rather than preliminary hearing without discussing issues with defense attorneys.
November 7, 2002	a) SARC files return to OSC for Habeas Case denying they have any involvement with Nancy now, relying mainly on criminal case status, claiming TC and Embee are completely in charge.
	b) Parents and TC take Nancy to Alta Bates ER for pneumonia and withdrawal from drugs. Undisclosed and untreated broken collarbone is found in x-rays and documented to be recent, and is reported soon after to Gallagher who orders expert evaluation of evidence by parents. Expert estimates by Dr. Nguyen say it’s recent, in State care. TC refuses to cooperate to move Nancy from system, fearing SARC and DDS.
December 2, 2002	Parents contact State Licensing, reporting broken collarbone, drugging and other injuries. Embee seeks to punish parents for reporting the injuries, refusing to allow visits to Nancy there, in violation of the Lanterman Act. Also gives Nancy 30 days notice to move out. TC supports Embee, claiming parents are “tattling”. Parents refuse to accept this and are barred by TC from visiting Nancy and objecting parents do not see her again until Christmas.
December 9, 2002	Parents move to have Nancy moved to home for emergency medical treatment because of the collarbone and drugging, TC insists on parents taking over conservatorship for this, Gallagher balks due to TC’s precondition citing outstanding criminal case. Motion denied due to TC’s stance. Orders getting an outside PI lawyer to sue County on behalf of Nancy, suggests TC move her as soon as possible from county. Repeats request for parents to dispose of criminal charges so their Petition can be considered.
December 10-20, 2002	Parents hunt for proposed placement in Merced County, eventually find excellent placement, but TC balks and scuttles, complaining about distance, preferring to leave Nancy at Embee despite proven dangers.
December 17, 2002	Parents file denial of SARC OSC for Habeas. DA sets trial for end of January when Conservatorship petition to be reheard.
2003
January 5, 2003	During Sunday visit, Nancy has grand mal seizures. After battle with TC, Nancy is taken to Good Samaritan ER. During admission, discover unreported prior ER admission on Sunday 9/15/02 for unknown purposes, taken by careworkers. Careworkers listed as next of kin and person to contact. TC informed, then attempts to find out what this was fail, and records disappear from computer next day without a trace. Parents and admissions nurse all saw it on the computer, it was there.
January 10, 2003	Gallagher denies Habeas petition without prejudice saying TC has full powers to move Nancy, but TC ignores responsibility and SARC obstructs move, immediately refusing to allow her to move out of county.
January 24, 2003	Gallagher rotates off Probate bench.
January 28, 2003	Parents exonerated of criminal charges on eve of trial. DA admits he has no case against parents in pre-trial conference, plea settlement to avoid trial dismisses Mrs. Golin completely, Mr. Golin dismissed with very minor conditions not to interfere with Conservatorship hearing to be dismissed in 6 months, reduced plea to watered down charges of letting Nancy wander one time. Supervised visit orders dissolved. Parents prepare to get daughter back to safety.
February 4, 2003	Status review of TC before Probate’s new Judge Thomas Edwards, removes TC and grants to State despite allegations against Embee on petition from PDO Street. Reasons are stated that TC failed by taking Nancy off damaging drugs and did not share records, contrary to all logic. Parent’s petition and order of preference not considered seriously. PDO agrees to share all records with parents; then they do exactly the opposite. Grants all PDO, SARC, DDS and County unscheduled motions against parents. Parents’ attorney asks for jury trial, blocked by PDO. Nancy again not present, Morrissey objects to no effect. Orders “continuation” of supervised visits. Nancy not allowed to leave County even for medical examination or treatment. Injuries shown to have occurred scoffed as merely “allegations” and “outlandish”. Parents represented by new attorney Morrissey, whom they fire soon after when he refuses to fight orders. Trial set April 8. Nancy remains at Embee. No discussion of enumeration of full powers at hearing.
February 21, 2003	Parents retain Conner as co-counsel for Federal Court action.
February 22, 2003	Nancy misses visit, supervisor feigns illness to keep parents in dark while Nancy secretly goes into hospital in grave condition due to drugging and vomiting up esophageal lining. Parents not informed.
February 23, 2003	Parents re-file Habeas brief with new facts, prepare for Federal Court. Retain Conner for Federal Court Habeas Emergency Petition and prepare Peremptory Challenge.
February 25, 20033:56pm	Parents file Peremptory Challenge against Edwards for cause, prior knowledge and for prejudice. Parents file objection.
February 25, 20034:12pm	Edwards files Orders granting DDS TLC with six powers not heard on 2/4. Receive proposed orders by DDS requesting consent for six powers, not previously seen.
February 26, 2003	Parents file objection to granting of six powers.
March 1, 2003	Edwards files Answer to Peremptory Challenge, postmarks it March 3, consents to withdraw but denies allegations refusing to be disqualified. Matter sent to outside judge for decision.
March 1, 2003	Parents learn Nancy is gravely ill with uncontrolled seizures, vomiting blood from huge stomach ulcer; Supervisor concealed that Nancy was in hospital from about 2/17-2/20 without notifying parents previous weekend. Claims Nancy too ill to visit, denies parents entry to home to see, will not allow visit with her, refuses to give parents names of doctors to assist in helping her, doctors have been ordered by SARC not to speak to parents even if to help Nancy. Parents get civil standby to see her 5 minutes, see she is gravely ill and severely abused showing bruises around wrists from restraints and needs immediate help, police refuse to assist due to conservatorship situation and APS involvement. Not seen since then by parents for four months afterwards.
March 2, 2003	Parents visit doctors and hospital requesting information despite SARC orders not to talk. Learn about ulcer and cauterization operation. Learn that Nancy has not been in her day program for several weeks, perhaps since February 4, either very sick or taken out after keeping up appearances became unnecessary. MediCal billings show charge for ER visit for skull fracture and broken thigh.
March 3, 2003	Parents set to go into Federal Court but learn that Gallagher is substituting for Edwards this week so prepare for ex Parte hearing hoping she will grant.
March 7, 2003	a) Ex Parte motion before Judge Gallagher, asking for Nancy’s immediate release, citing her life-threatening medical problems, including a large bleeding ulcer, repeated uncontrolled seizures, and brain damaging drugging. Parents file extensive declarations and motions withheld while Morrissey was in charge. Gallagher refuses to reverse any Edwards orders while Challenge is being decided, informs parents that Edwards assumed recusal is not recusal but Answer and that trial judge will decide in time. Allows parents to obtain letter from doctor establishing Nancy’s serious condition, as condition to release her. b) Parents immediately visit neurologist in charge Gaskins to offer assistance and get letter, and she reports that just after hearing she received call from SARC saying she was ordered not to speak to us, undermining Gallagher’s orders. Parents persuade her to discuss briefly and give her names to call. c) Parents get similar letter instead from Dr. Nguyen, request P & A brief from Conner to support motion.
March 10, 2003	Parents turned away from Gaskins office without being allowed to give helpful information or discuss letter.
March 14, 2003	Received transcript of February 4 hearing, find it to be totally altered and deleted, removing oral arguments that were used in open court that we used or of others that we objected to in our peremptory challenge of Judge Edwards and the Public Defender. Prepare and file objection.
March 19, 2003	Received ruling of Judge Gallagher denying our Emergency Ex Parte petition to Terminate Conservatorship, ignoring all of our other motions, on grounds that we were unable to present her with the required affidavit by Dr. Gaskins, although we declared that our access to Dr. Gaskins was frustrated by SARC, and that Gallagher had been unmistakably heard to ask for a letter. Orders the Department of Social Services to investigate itself on the collarbone issue, to get a medical opinion that supports their contention that they are innocent of any liability, no other orders issued.
March 24, 2003`	Parents serve subpoenas on all involved agencies for medical and other records, which are all opposed and blocked by SARC in subsequent days. Parents file motion to reconsider Exparte motion of Judge Gallagher from March 7, 2003.
March 26, 2003	Parents obtain sworn affidavit from Dr. Duc Nguyen, showing that the dislocated shoulder and the fractured clavicle occurred in two separate incidents.
March 28, 2003	Judge O’Farrell, outside judge from Monterey County, rules on Peremptory Challenge of Judge Edwards, recusing Edwards without disqualification, without noting parents Denial of Edwards’ Answer or Objections to pending orders. Parents file Request for Reconsideration based on other filings not noted, asking Edwards be disqualified so that his untimely orders may be vacated.
April 8, 2003	Status Review Conference and Trial Setting Date for Conservatorship before Judge Gallagher. Judge despite doctor‘s reports denied motions for relief, not in any hurry, sets trial motion dates month away, delays requested reconsideration. We receive alarming medical records showing that Nancy did not have an ulcer, but a precancerous condition Barnett’s esophagus, vomiting up blood and chunks of esophageal lining. Clearly has a life-threatening condition caused by drugs as we had alleged, which was covered up.
April 18, 2003	Parents visit Nancy for three hours, after day program, she appears very weak and inactive, depressed, distant, much display of tardive dyskinesia, lip pursing, tongue thrusting, hands shaking, even on Zyprexa, finds it hard to walk. Go to Santa Theresa Park but Nancy too weak to walk far. First visit allowed in more than two months.
May 5, 2003	Parents file tort claims with State, County, SARC and Embee Manor in time for 6 month deadline following discovery of broken collarbone and dislocated shoulder injuries. Claims are eventually rejected as expected leaving another 6 months to file suits.
May 7, 2003	Pre-trial conference with Gallagher, Conner attending for parents. Golin prepares extensive reply brief answering Berliner Cohen’s motions. Gallagher moves against parents on each motion, denying jury trial on request of Street, denying modification of supervised visitation orders, denying termination of conservatorship motion, denying removal of PD Street representing Nancy, denying removing Nancy from placement where injuries occurred, denying Nancy’s right to sue, expressing doubt about parents criminal case settlement status, denying motions concerning discovery, allowing APS records to be used in trial, Street files joinder motions with SARC. Rules parents may have independent medical examination but must not be present and must occur only during daytime hours. Chapnik attempts to substitute for Street and is rejected.
May 9, 2003	Second Habeas Petition is Rejected without prejudice, alleging by inference Gallagher has no ability to modify visitation orders so Nancy cannot come home.
May 15, 2003	Russ George, alternate petitioner for conservatorship, friend of parents, appears at his calendared appointment hearing set two months prior and nobody else shows up except parents, Gallagher refuses to come out of chambers to speak to him, refuses to rule on his petition, refuses to reject his petition. George gets completely ignored. Hearing is aborted with no reschedule date.
May 23, 2003	Judge Gallagher sponsors Settlement Conference one week before trial date, says “case should settle”. George out of town unable to attend. Lasts 5 hours. Opposing parties are PDO Street (court appointed to represent Nancy), Kennedy/County Counsel for APS, Johnson/Berliner Cohen for SARC, and DDS Stiles. Talks break down when opposing parties insist on getting permanent conservatorship. Buckmaster and Kratzer go for gutter, claimed parents do not really live in Merced County but are homeless, that mother is Munchhausen, that now Nancy was covered with lice when found, and increasingly wild allegations. Opposing parties admonished this is a fiasco. Parents motion for continuance of trial set for June 2 is moved to September 29, 2003 because obstruction of discovery makes it impossible to be prepared. State’s temporary conservatorship is extended to trial date with all six powers contrary to probate code.
June 11, 2003	Mrs. Golin files appeal of Judge Edwards’ decisions within timeline. Nancy undergoes second gastroesophageal endoscopic follow up examination, this time parents are allowed to come to hospital over objection of Street, by SARC. No medical report is provided to follow up and SARC only gives a summary report they prepared without any records.
June 20, 2003	Conner files Federal Habeas suit Golin v. Allenby in Federal 9^th District Court, on behalf of Elsie with Judge Alsup assigned. Case languishes for months until parents hire another attorney who briefly pursues the case, then drops the ball.
June 22, 2003	Nancy visited, looks sullen and unhappy, very much frozen up physically and weak, has black right eye and gash on right eyelid, nobody knows how this happened. Caregiver Lynn Gelle has been sent back to Canada, and is not being rehired. New staff at Embee Last visit two months ago.
August 9, 2003	All charges against Jeffrey Golin finally dismissed by DA on plea of not guilty, exonerated, expunged.
September 11, 2003	Hearing in Federal District Court Northern District California, Judge Alsup, on motion for medical exam prior to Petition for Habeas Corpus, taken under submission and briefs, exhaustion issue and jurisdiction.
September 23, 2003	Jeffrey Golin intervenes in Federal Habeas case on own behalf. Files extensive brief. Parents instructed that they must proceed in State Court with trial before Habeas despite history.
September 20, 2003	MediCal billing history subpoena finally complied with despite interference from Liske, showing extensive seizure activity and record of ER visit for skull fracture and broken thigh bone.
September 26, 2003	Parents call ex-parte motion in probate to delay trial to explore discovery further, denied. Says this is important case, should move forward. Judge William Martin assigned at last moment to trial.
September 29- October 18, 2003	State probate trial begins to decide if Nancy should be conserved, by parents or state. Judge Martin presiding. Parents unwillingly represent selves. Parents bring 13 witnesses, but most important ones kept out. Martin rules against parents for state, despite parental preferences.
October 23, 2003	Parents file own Section 1983(5) civil rights complaint in Federal District Court against state, county, city, SARC, APS, care home, and individuals, just within statutory time limits.
November 18, 2003	Parents file motions for rehearing in state court, file affidavits objecting to opinion and decisions, notice of appeal.
November 24, 2003	Habeas Corpus first petition in Federal Court dismissed for failure to exhaust state remedies, after briefing. Parents file their own supplemental brief.
November 25, 2003	State Supreme Court denies Habeas Petition, exhausting state remedies, one day after District Court dismisses for failure to exhaust.
December 29, 2003	Parents file Second petition for Habeas Corpus in Federal District Court, pursuant to exhausting state remedies. Case languishes, state fails to file response, parents move to declare default, clerk refuses to notice.
2004
January 14, 2004	Motion for rehearing in state court denied, exparte motion to give temporary conservatorship to state pending appeal, opposed and granted by Judge Martin.
January 18, 2004	Nancy moved from Embee Manor to Talla House, parents visit establish initial relationship with Tallas. Have not seen Nancy since trial three months before. Visits resume on irregular basis.
January 22, 2004	Case Management Conference in District Court, Section 1983 civil rights suit, briefing begins on 12(b)(6) motions and oppositions, Golin files own opposition brief to each motion to dismiss.
March 25, 2004	Section 1983 civil rights suit and second Habeas Corpus dismissed in District Court, Judge Alsup, on 12(b)(6) Motions. Alsup calls case “frivolous”, ridicules parents, praises state, relies on biased Martin opinion. Parents appeal to Ninth Circuit.
April 1, 2004	Judge Martin denies parents approved settled statement proceeding or transcripts on appeal to state court, opining parents can afford. Parents unable to attend for medical reasons, proceeds without them. Parents renew their challenge.
December 4, 2004	State Court of Appeals denies parents motion for extension of time to procure remainder of trial transcripts for appeal, dismisses state appeal.
December 6, 2004	Parents file Opening brief in Ninth Circuit Court of Appeals, Civil Rights case. Visits with Nancy cut off during holiday season.
December 13, 2004	Golin files Petition for Certiorari with US Supreme Court for denial of petition for Habeas Corpus in Ninth Circuit for failure to obtain Certificate of Appealability. Subsequently file Supplemental Brief.
December 14, 2004	Golin files Petition for Certiorari with US Supreme Court for denial of review in State Supreme Court. Subsequently file Supplemental Brief.
December 23, 2004	Parents file emergency injunctive motion with US Circuit Court fearing that Nancy is very ill and being subjected to mistreatment, requesting holiday visitation, motion denied.
2005
February 18, 2005	Conference in US Supreme Court on petitions for Certiorari, denied.
February 22, 2005	Parents file Reply brief in Ninth Circuit Court of Appeals, Civil Rights case.
April 19, 2005	Nancy rushed to El Camino Hospital for secret hospitalization with no one accompanying her, no one permitted to know reason, stays for week, hospital denies she is there but parents see her under guard. Parent renew motion for protective injunctive relief in US Circuit Court. Returns to same placement she was abused at. Nancy had been rushed there due to seven seizures, status epilepticus. Had been fully tapered off of Dilantin because of loosening of teeth for at least a month. SARC blamed this for these seizures and put her back on to Dilantin. Nancy was so near death due to bradycardia (sudden drop of blood pressure to near cardiac failure) they had to administer CPR and external pacemaker for heart failure. Cause of these seizures actually was a rip-roaring E-Coli urinary track infection, hundreds of thousands of colonies, caused by keeping Nancy in diapers while she was in restraints most of the time, concealed by Talla. Partially collapsed lung, heart failure. Placed main line in neck, she rips it out. Infections had always spurred seizures. Liske and Wendt sends letters to attending physician telling them that the parents require close supervision under guard for periods of only 5 minutes at a time due to past allegations of abuse (unfounded) and there is to be no release of information or visits by anyone including the parents. Doctors follow.
April 25, 2005	Watchdog Carole Herman calls Mimi Kinderlehrer and Tucker Liske and demands to know what is going on, receives few explanations, only saying hospitalization was “medication related”.
May 11, 2006	Two Judge panel in Ninth Circuit, Pregerson and Callum, denies motion for emergency injunctive relief to protect Nancy. Waiting for calendaring.
June 20, 2005	Parents visit Sen. Jeff Denham’s office in Sacramento to plead for help.
June 22, 2005	Ninth Circuit affirms dismissal of lower court, Judge Alsup, in three judge panel, Judges Kleinfeld, Tashima and Thomas. Decision so inept that it is hard to believe such judges could have written it, every citation of authorities is misstated and obviously incorrect, very cursory ruling, failed to apply recently decided Exxon-Mobil case, while at the same time applying it to another case with same issues. Primary ground is that parents are not represented by attorney and thus cannot represent Nancy as guardians ad litem. Denies all outstanding motions as moot.
July 6, 2005	File petition for rehearing en banc with Ninth Circuit Court of Appeals on civil rights lawsuit.
July 9, 2005	Jeff Golin sits down with Peggy Collins, chief consultant to Sen. Wayne Chesbro, Chm. Of Senate Committee on Developmental Disabilities and Mental Health. Collins promises help, then studiously avoids Golin.
July 13, 2005	Filed Amended Memorandum of Points and Authorities for Motion for rehearing en banc with Ninth Circuit.
August 16, 2005	Ninth Circuit denies Motion for Rehearing en banc. Only recourse is to U.S. Supreme Court. Have 90 days.
October 20, 2005	Gerard W. Wallace of New York agrees to help Jeff petition US Supreme Court pro bono for certiorari from the Ninth Circuit on civil rights case.
December 14, 2005	Filed petition for certiorari by Wallace with US Supreme Court, after two months of preparation and editing, printed ourselves to professional standards. (30 day delay had been granted by retiring Justice Sandra Day O’Connor).
2006
March 27, 2006	US Supreme Court denies bid for certiorari, without comment.
April 26, 2006	Parents, with Wallace continuing pro hac vice from New York, refile civil rights lawsuit for damages and injunctive relief against state, county, city and state actors, in Sacramento Superior Court, within 30 day time period allowed, perfect causes and defendants. Start looking for California trial lawyer to pursue locally.
May 30, 2006	SARC’s Kinderlehrer, apparently having been tipped off about lawsuit before service of summons, retaliated against parents by shutting down their visitation rights, clamping down on supervised visitation rules again, alleging that she allegedly received word that the parents had intended to leave with Nancy and not come back.
August 18, 2006	After two months of pursuit of Judge Loren McMaster in Sacramento who originally signed guardian ad litem order on June 19, then tried to hide it, Sacramento Judge Michael P. Kenny appoints Elsie as guardian ad litem to represent Nancy in lawsuit. For first time in five years someone other than the people who are abusing Nancy is appointed to represent her interests, due to the representation of Wallace. Without standing case could never go forward on Nancy’s claims.
August 24, 2006	All defendants are served with summons within extended deadline.
September 19, 2006	Parents fail to defeat County’s motion to remove lawsuit from Sacramento County to Santa Clara County, where are expected to remove Elsie as Guardian Ad Litem and thus gut their case as they have done previously.
October 2, 2006	Parents found new authorities and facts and filed motion to reconsider change of venue to Santa Clara County with new affidavits and motion for stay, where parents are convinced the County has influence and bias in Superior Court against their case favoring the defendants, and will quickly suppress the case, preventing it from ever going to discovery or going before a jury.