Denise Chavez; Miguel R Luna Sr.
11755 Star Street
Adelanto California 92301
(760)980-5715
Chavezdenise609@gmail.com
Lunamiguel813@gmail.com
Miguel Luna 2 nd ; Heriberta Luna
Miracle Luna; Miguel Luna Jr;
Alyssa Luna;
24747 6 th Street
San Bernardino California 92410
UNITED STATES DISTRICT COURT
CENTRAL DISTRICT OF CALIFORNIA
DENISE CHAVEZ; MIGUEL R LUNA; MIGUEL
LUNA 2ND; HERIBERTA LUNA; MIRACLE
LUNA; MIGUEL LUNA JR; ALYSSA LUNA,
Plaintiffs,
vs.
LOMA LINDA UNIVERSITY MEDICAL
CENTER, AMINI SENAI REBECCA
GONZALEZ CINDY SIHOTANG; SAN
BERNARDINO JUVENILE DEPENDENCY
COURT; JUDGE ERIN K ALEXANDER;
Case No.: Number
CIVIL ACTION
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CIVIL ACTION – 2
COUNTY COUNSEL SARAH OLIVER;
CHILDRENS ADVOCACY COREY
TOLMASOFF; DEPARTMENT OF CHILDREN
AND FAMILY SERVICES; CHILD
PROTECTIVE SERVICES; EDWARD YORK JR
SSP; NICHOLE ROACH SSP; ALICE
MARTINEZ SSP; DAISY CASTENADA SSP;,
JANICE TSAI; ASHKAT JAINE; SOFIA
YASMIN; LATIKA PURI; TSUNGJU OLEE;
ALICE HYOJUNG RHEE; JADE-MING JENG;
SARAH JANE CRISTIAN KOPP; HEATHER
MARU; STACEY EARNEST; CINDY
SIHOTANG; MAKENA WILSON P LAO;
WILLIAM ALEXANDER KENNEDY; LOUISE;
MARJORIE JENNIFER; KIM MENDEZ
DANILO; LIANA; JTSAI; H. PEREZ; PHALLIN
CELINE; LOMA LINDA UNIVERSITY
CHILDRENS HOSPITAL; DOES 1-50; ADRIAN
JESUS LUNA; CRUZ R LUNA; ISREAL LUNA
ASSANTE FAMILY AGENCY
s
COMES NOW, Plaintiffs DENISE CHAVEZ; MIGUEL R LUNA; MIGUEL LUNA
2ND; HERIBERTA LUNA; MIRACLE LUNA; MIGUEL LUNA JR; and ALYSSA LUNA, and
file this Complaint against Defendants LOMA LINDA UNIVERSITY MEDICAL CENTER;
AMINI SENAI REBECCA GONZALEZ CINDY SIHOTANG; SAN BERNARDINO
JUVENILE DEPENDENCY COURT; JUDGE ERIN K ALEXANDER; COUNTY COUNSEL
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CIVIL ACTION – 3
SARAH OLIVER; CHILDRENS ADVOCACY COREY TOLMASOFF; DEPARTMENT OF
CHILDREN AND FAMILY SERVICES; CHILD PROTECTIVE SERVICES; EDWARD
YORK JR SSP; NICHOLE ROACH SSP; ALICE MARTINEZ SSP; DAISY CASTENADA
SSP;, JANICE TSAI; ASHKAT JAINE; SOFIA YASMIN; LATIKA PURI; TSUNGJU OLEE;
ALICE HYOJUNG RHEE; JADE-MING JENG; SARAH JANE CRISTIAN KOPP; HEATHER
MARU; STACEY EARNEST; CINDY SIHOTANG; MAKENA WILSON P LAO; WILLIAM
ALEXANDER KENNEDY; LOUISE; MARJORIE JENNIFER; KIM MENDEZ DANILO;
LIANA; JTSAI; H. PEREZ; PHALLIN CELINE; LOMA LINDA UNIVERSITY CHILDRENS
HOSPITAL; DOES 1-50; ADRIAN JESUS LUNA; CRUZ R LUNA; and ISREAL LUNA
ASSANTE FAMILY AGENCY. In support of this Complaint, the Plaintiffs state as follows:
NATURE OF ACTION
1. This case involves a violation of Plaintiff Denise Chavez and Miguel Luna Sr
rights to familial association with their minor children Miguel Luna 2nd; Heriberta Luna;
Miracle Luna; Miguel Luna Jr; and Alyssa Luna, under both the Federal and California
Constitutions and the California Family Code.
2. Plaintiffs aver that the Defendants’ actions and rulings in a state court action
brought by Department of children and family services Defendant’s Children Protective services
alleging inter alia, that 1) mother and baby’s urinalysis were positive for methamphetamine; 2)
Mother has unresolved substance history; 3) mother does not have a clear reason as to why
Miguel Luis Test came back Positive; 4) mother or father fails to acknowledge reason for cfs
intervention; and 5) not signing a cfs 32 form is prima facie evidence for the removal of children
from parents physical custody.
3. It is Plaintiffs’ averment that the Juvenile/State court did not have subject matter
jurisdiction. Plaintiffs further assert that the Department of Children and Family Services failed
to establish any relationship in which relief or equitable maximum cure maintenance, remedy
could be granted. The Plaintiffs further aver that the state/court and its CO-
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CONSPIRATORS/agents and contractors’ adverse actions as described herein and as on its face
as the record reflects, are moot, unlawful, procedurally inappropriate and raise the claimant
parent’s causation/cause of action.
4. Accordingly, the Plaintiffs sue the Defendants for unlawful seizure, deprivation
of rights, negligence, conversion, official misconduct-Title 42 usc 14141, kleptocracy, extortion,
fraud, coercion, abuse of process, gross negligence, legal malpractice, treason, parental
alienation, kidnapping, criminal conspiracy under the unilateral approach, 18 U.S. Code § 1038
False information and hoaxe, child endangerment Penal Code 273a Medical Battery Penal Code
206 PC – The Crime of “Torture” in California on a child under two.
PARTIES
5. Plaintiff DENISE CHAVEZ is an individual residing in California. Denise is the
mother of the third to the fifth Plaintiffs.
6. Plaintiff MIGUEL R LUNA is an individual residing in California. Miguel is the
father of the third to the fifth Plaintiffs.
7. Plaintiffs MIGUEL LUNA 2ND; HERIBERTA LUNA; MIRACLE LUNA;
MIGUEL LUNA JR; and ALYSSA LUNA, are the children of Denise and Miguel.
8. Defendant LOMA LINDA UNIVERSITY MEDICAL CENTER is a medical
center headquartered and located at 11234 Anderson, St Loma Linda, CA 92354.
9. Defendant AMINI SENAI is an individual residing in California.
10. Defendant REBECCA GONZALEZ is an individual residing in California.
11. Defendant CINDY SIHOTANG is an individual residing in California.
12. Defendant SAN BERNARDINO JUVENILE DEPENDENCY COURT is a
Juvenile Dependency court located at 860 East Gilbert Street San Bernardino, CA 92415-0955.
13. Defendant JUDGE ERIN K ALEXANDER is a judge for the Superior Court of
San Bernardino County in California.
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14. Defendant COUNTY COUNSEL SARAH OLIVER is the County Counsel for
San Bernardino County Los Angeles.
15. Defendant COREY TOLMASOFF is an individual residing in California.
16. Defendant DEPARTMENT OF CHILDREN AND FAMILY SERVICES is an
agency of the government of San Bernardino.
17. Defendant CHILD PROTECTIVE SERVICES is a department of the government
of San Bernardino.
18. Defendant EDWARD YORK JR SSP is an individual residing in California.
19. Defendant NICHOLE ROACH SSP is an individual residing in California.
20. Defendant ALICE MARTINEZ SSP is an individual residing in California.
21. Defendant DAISY CASTENADA SSP is an individual residing in California.
22. Defendant JANICE TSAI is an individual residing in California.
23. Defendant ASHKAT JAINE is an individual residing in California.
24. Defendant SOFIA YASMIN is an individual residing in California.
25. Defendant LATIKA PURI is an individual residing in California.
26. Defendant TSUNGJU OLEE is an individual residing in California.
27. Defendant ALICE HYOJUNG RHEE is an individual residing in California.
28. Defendant JADE-MING JENG is an individual residing in California.
29. Defendant SARAH JANE CRISTIAN KOPP is an individual residing in
California.
30. Defendant HEATHER MARU is an individual residing in California.
31. Defendant STACEY EARNEST is an individual residing in California.
32. Defendant CINDY SIHOTANG is an individual residing in California.
33. Defendant MAKENA WILSON P LAO is an individual residing in California.
34. Defendant WILLIAM ALEXANDER KENNEDY is an individual residing in
California.
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CIVIL ACTION – 6
35. Defendant LOUISE is an individual residing in California.
36. Defendant MARJORIE JENNIFER is an individual residing in California.
37. Defendant KIM MENDEZ DANILO is an individual residing in California.
38. Defendant LIANA is an individual residing in California.
39. Defendant JTSAI is an individual residing in California.
40. Defendant H. PEREZ is an individual residing in California.
41. Defendant PHALLIN CELINE is an individual residing in California.
42. Defendant ADRIAN JESUS LUNA is an individual residing in California.
43. Defendant CRUZ R LUNA is an individual residing in California.
44. Defendant ISREAL LUNA is an individual residing in California.
45. Defendant ASSANTE FAMILY AGENCY is a behavioral health community-
based resource center that serves the residents in the San Bernardino City metropolis.
46. Defendant LOMA LINDA UNIVERSITY CHILDRENS HOSPITAL is a
children’s hospital located at 11234 Anderson St Loma Linda, CA 92354.
47. Plaintiffs do not know the true names and capacities, whether individual,
corporate, associate, or otherwise, of Defendants DOES 1 through 50. Plaintiffs are aware that
DOES 1 through 50 are Loma Linda on site social workers and include all other physicians in the
pediatric department and other physicians from other branches. Therefore, Plaintiffs sues those
defendants by such fictional names. Plaintiffs further allege that each fictitious defendant is in
some manner responsible for the acts and occurrences herein. Plaintiffs will seek leave of this
court to amend this Complaint to state the real names and capacities of said fictitious name
defendants when the same have been ascertained. Plaintiffs are informed and believe, and based
thereon alleges that the fictitiously named defendants caused them damages.
48. Plaintiffs are informed and believe, and based thereon allege that the Defendants
named herein, acted as the agent, employee, representative, partner, joint ventures, or co-
conspirators of each of the other defendants named herein in the commission of the acts and
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CIVIL ACTION – 7
omissions to the acts alleged herein, and acted within the course and scope of his, her, or its duty
as such agent, employee, representation, partner, joint venture, or co-conspirator. The acts of
each such defendant were authorized and/or ratified by each other defendant, and together
configure a single and continuing course of conduct.
JURISDICTION AND VENUE
49. This Court has federal question subject matter jurisdiction over the 18
U.S.C.§1038 and 42 USC 14141 causes of action, which clearly arise under federal law, pursuant
to 28 U.S.C. § 1331.
50. Venue is proper in this judicial district pursuant to 28 U.S.C. 1391(b)(1) and
(b)(2), because Plaintiffs and most, if not all, of the Defendants reside and conduct business in
this judicial district, and a substantial part of the events giving rise to the claim occurred in and
originated from this judicial district.
FACTUAL ALLEGATIONS
The Defendants’ blameworthy actions against the Plaintiffs’ children
51. The Defendant hospital committed acts that ended up hurting the Plaintiffs’ son.
In one incidence, the son went to the hospital for a unknown insect bite on his right cheek.
However, the hospital ended up removing his organ without parental consent and absent court
order.
52. Further, the hospital claims that he has cancer and was giving him chemotherapy
while he was in the hospital to date. The hospital also tried to give him blood transfusions
although the doctor stated that there was no evidence that he needed Chemo. Besides, during the
son’s stay in the hospital, they gave him medicine that was harmful to children his age.
53. The Defendant hospital’s blameworthy conduct was also seen when Plaintiff went
to the dentist for emergency tooth extraction of an infected tooth. The dentist ended up doing 6
root canals and was trying to give Plaintiff permanent dentures to cover up their conduct. The
nurse showed Plaintiff what they had done to her upper front teeth. Plaintiff experienced a lot of
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CIVIL ACTION – 8
pain. When she tried to get up the dentist pushed her down to the chair. Plaintiff only came out
of the sedation on time to get up and left before they could cover it up. All of these was being
recorded and watched by a crowd in the adjacent room. Afterwards, Plaintiff realized that the
infected tooth that took Plaintiff to the dentist was untouched when Plaintiff left.
Interference with the parents’ liberty to raise their children
54. Defendants Social workers, State Court, and Loma Linda University Medical
Center used Fabricated Drug test Results for Plaintiff Miguel Luis Luna 2 nd to unlawfully
interfere with Parents’ fundamental liberty to raise their sons and daughters as parents deem fit.
Please see exhibit#1.
55. Defendants Social workers, State Court, and Loma Linda University Medical
Center alleged that Denise tested positive at the birth of Miguel 2 nd . Until this day the said
Defendants never provided State court and the Appeal Court an actual drug screen for Denise.
Further, all Defendants such as Loma Linda university medical center, amini Sanai Rebecca
Gonzalez cindy sihotang; San Bernardino Juvenile Dependency Court; Judge Erin K Alexander;
County Counsel Sarah Oliver; Children’s Advocacy Corey Tolmasoff; Department of Children
and Family Services; Child Protective Services; Edward York Jr SSP; Nichole Roach SSP; Alice
Martinez SSP; Daisy Castaneda SSP; Marlena Mccormick SSP; Marlene Hagen (court clerk);
Mark Roa; Art J Lacilento; Kathy Garcia; Janice Tsai; Ashkat Jaine; Sofia Yasmin; Latika Puri;
Tsung Ju Olee; Alice Hyojung Rhee; Jade-Ming Jeng; Sarah Jane Cristian Kopp; Heather Maru;
Stacey Earnest; Cindy Sihotang; Makena Wilson P Lao; William Alexander Kennedy; Louise;
Marjorie Jennifer; Kim Mendez Danilo; Liana; Jtsai; H. Perez; Phallin Celine; Loma Linda
University Children’s Hospital; DOES 1-50; Adrian Jesus Luna; Cruz R Luna; Israel Luna; AND
Assante family agency conspired to deprive parents of any or all rights.
The Judge’s blameworthy conduct
56. Judge Erin K. Alexander had been sitting on the case that was filed by the
Defendant San Bernardino County Department of Children And Family Services. During the
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prosecution of the case, the Judge made various decisions that were problematic. For instance,
the Court turned down the father’s concerns that no tests had turned positive, and that the Social
Worker was aware of this. Besides, no issue was raised when the Social Worker visited the
children at the grandmother’s house. Ultimately, the Court ordered the detaining of the children
amidst the concerns raised by the Parents.
57. The Judge also admitted evidence that contained hearsay information. The
parents’ attorneys objected to the inclusion of the said evidence but the Court still proceeded to
admit the said evidence.
58. The Judge also failed to consider recommendations from the Social Worker, who
stated that she recommended family reunification and that the children should be returned to the
Parents.
CAUSES OF ACTION
FIRST CAUSE OF ACTION
Deprivation of Rights under the Color of law
18 U.S.C. 242
59. The Plaintiffs incorporate by reference each preceding and succeeding paragraph
as though fully set forth at length herein.
60. Section 242 of Title 18 makes it a crime for a person acting under color of any
law to willfully deprive a person of a right or privilege protected by the Constitution or laws of
the United States.
61. For the purpose of Section 242, acts under "color of law" include acts not only
done by federal, state, or local officials within their lawful authority, but also acts done beyond
the bounds of that official’s lawful authority, if the acts are done while the official is purporting
to or pretending to act in the performance of his/her official duties. Persons acting under color of
law within the meaning of this statute include police officers, prisons guards and other law
enforcement officials, as well as judges, care providers in public health facilities, and others who
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are acting as public officials. It is not necessary that the crime be motivated by animus toward
the race, color, religion, sex, handicap, familial status or national origin of the victim.
62. In the instant action, Defendants, acting under the color of law, deprived
Plaintiffs’ rights. Notably, Defendants Social workers, State Court, and Loma Linda University
Medical Center used Fabricated Drug test Results for Plaintiff Miguel Luis Luna 2 nd to
unlawfully interfere with Parents’ fundamental liberty to raise their sons and daughters as parents
deem fit. Please see exhibit#1.
63. Defendants Social workers, State Court, and Loma Linda University Medical
Center alleged that Denise tested positive at the birth of Miguel 2 nd . Until this day the said
Defendants never provided State court and the Appeal Court an actual drug screen for Denise.
Further, all Defendants such as Loma Linda university medical center, amini Sanai Rebecca
Gonzalez cindy sihotang; San Bernardino Juvenile Dependency Court; Judge Erin K Alexander;
County Counsel Sarah Oliver; Children’s Advocacy Corey Tolmasoff; Department of Children
and Family Services; Child Protective Services; Edward York Jr SSP; Nichole Roach SSP; Alice
Martinez SSP; Daisy Castaneda SSP; Marlena Mccormick SSP; Marlene Hagen (court clerk);
Mark Roa; Art J Lacilento; Kathy Garcia; Janice Tsai; Ashkat Jaine; Sofia Yasmin; Latika Puri;
Tsung Ju Olee; Alice Hyojung Rhee; Jade-Ming Jeng; Sarah Jane Cristian Kopp; Heather Maru;
Stacey Earnest; Cindy Sihotang; Makena Wilson P Lao; William Alexander Kennedy; Louise;
Marjorie Jennifer; Kim Mendez Danilo; Liana; Jtsai; H. Perez; Phallin Celine; Loma Linda
University Children’s Hospital; DOES 1-50; Adrian Jesus Luna; Cruz R Luna; Israel Luna; AND
Assante family agency conspired to deprive parents of any or all rights.
64. Judge Erin K. Alexander had been sitting on the case that was filed by the
Defendant San Bernardino County Department of Children And Family Services. During the
prosecution of the case, the Judge made various decisions that were problematic. For instance,
the Court turned down the father’s concerns that no tests had turned positive, and that the Social
Worker was aware of this. Besides, no issue was raised when the Social Worker visited the
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children at the grandmother’s house. Ultimately, the Court ordered the detaining of the children
amidst the concerns raised by the Parents.
65. The Judge also admitted evidence that contained hearsay information. The
parents’ attorneys objected to the inclusion of the said evidence but the Court still proceeded to
admit the said evidence.
66. The Judge also failed to consider recommendations from the Social Worker, who
stated that she recommended family reunification and that the children should be returned to the
Parents.
67. As a direct and proximate result of Defendants’ willful action and inaction,
Plaintiff has suffered actual damages.
SECOND CAUSE OF ACTION
Law enforcement misconduct
42 U.S.C 14141
68. The Plaintiffs incorporate by reference each preceding and succeeding paragraph
as though fully set forth at length herein.
69. It is unlawful for any governmental authority, or any agent thereof, or any person
acting on behalf of a governmental authority, to engage in a pattern or practice of conduct by law
enforcement officers or by officials or employees of any governmental agency with
responsibility for the administration of juvenile justice or the incarceration of juveniles that
deprives persons of rights, privileges, or immunities secured or protected by the Constitution or
laws of the United States.
70. Judge Erin K. Alexander had been sitting on the case that was filed by the
Defendant San Bernardino County Department of Children And Family Services. During the
prosecution of the case, the Judge made various decisions that were problematic. For instance,
the Court turned down the father’s concerns that no tests had turned positive, and that the Social
Worker was aware of this. Besides, no issue was raised when the Social Worker visited the
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children at the grandmother’s house. Ultimately, the Court ordered the detaining of the children
amidst the concerns raised by the Parents.
71. The Judge also admitted evidence that contained hearsay information. The
parents’ attorneys objected to the inclusion of the said evidence but the Court still proceeded to
admit the said evidence.
72. The Judge also failed to consider recommendations from the Social Worker, who
stated that she recommended family reunification and that the children should be returned to the
Parents.
73. Defendants Social workers, State Court, and Loma Linda University Medical
Center used Fabricated Drug test Results for Plaintiff Miguel Luis Luna 2 nd to unlawfully
interfere with Parents’ fundamental liberty to raise their sons and daughters as parents deem fit.
74. Defendants Social workers, State Court, and Loma Linda University Medical
Center alleged that Denise tested positive at the birth of Miguel 2 nd . Until this day the said
Defendants never provided State court and the Appeal Court an actual drug screen for Denise.
Further, all Defendants such as Loma Linda university medical center, Amini Sanai Rebecca
Gonzalez Cindy Sihotang; San Bernardino Juvenile Dependency Court; Judge Erin K Alexander;
County Counsel Sarah Oliver; Children’s Advocacy Corey Tolmasoff; Department of Children
and Family Services; Child Protective Services; Edward York Jr SSP; Nichole Roach SSP; Alice
Martinez SSP; Daisy Castaneda SSP; Marlena Mccormick SSP; Marlene Hagen (court clerk);
Mark Roa; Art J Lacilento; Kathy Garcia; Janice Tsai; Ashkat Jaine; Sofia Yasmin; Latika Puri;
Tsung Ju Olee; Alice Hyojung Rhee; Jade-Ming Jeng; Sarah Jane Cristian Kopp; Heather Maru;
Stacey Earnest; Cindy Sihotang; Makena Wilson P Lao; William Alexander Kennedy; Louise;
Marjorie Jennifer; Kim Mendez Danilo; Liana; Jtsai; H. Perez; Phallin Celine; Loma Linda
University Children’s Hospital; DOES 1-50; Adrian Jesus Luna; Cruz R Luna; Israel Luna; AND
Assante family agency conspired to deprive parents of any or all rights.
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75. As a direct and proximate result of Defendants’ willful action and inaction,
Plaintiff has suffered actual damages.
THIRD CAUSE OF ACTION
Declaratory Relief
76. Plaintiff hereby incorporates by reference all the allegations contained in all the
preceding paragraphs of this complaint as though fully stated herein.
77. There now exists, between the parties hereto, a dispute and controversy to which
the Plaintiffs and the Defendants are entitled to have a declaration of their rights and further
relief relating to the facts and circumstances as set forth in this action.
78. Plaintiffs respectfully request this Honorable Court issue a declaratory judgment
declaring that the actions and/or inactions of the Defendants violate the rights of Plaintiffs.
PRAYER FOR RELIEF
WHEREFORE, the Plaintiffs are entitled to damages from the Defendants, and they
hereby pray that judgment be entered in their favor and against the Defendants and the following
relief be issued:
i. Declaratory relief;
ii. An award for actual damages for violation of Plaintiff’s rights as alleged herein;
iii. Interest as provided by law;
iv. An award of fees and costs;
v. Such other relief as the Court deems just and proper.
Respectfully submitted:
Dated: ________________
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