Vicki Chang v. Andrew Vanderwielen, Trooper, Washington State Patrol, et al.

Did the 9th Circuit three judge panel err in its calculation of the statute of limitations for the torts presented based on legal theories including date of discovery rules, estoppel and other forms detrimental reliance generated by WSP Trooper Ed Collins, supervisor of Brady listed for perjury WSP Trooper Andrew Vanderwielen, the actual statute of limitations for 42 U.S.C. § 1983 and state law tort claims, continued sanctions of State of WA under Trueblood v. State of WA DSHS, and claims tolling based on false imprisonment and grave disability?

Did the 9th Circuit 3 judge panel err in its con­ clusion this case was suitable for decision without oral argument?

Did the 9th Circuit three judge panel err in its conclusion that negligence claims including medical malpractice against Emergency Doctor of Osteopathy Emergency Riddhi Kothari DO cannot be brought under 42 U.S.C. § 1983 including gross negligence, intentional negligence, intentional and clearly incom­ petent negligence?

Did the 9th Circuit three judge panel err in its conclusion that reasonable force was used to avulsion fracture Vicki Chang’s right ankle and cause vascular and other soft tissue damage in 2019 according to Xrays from Kaiser Permanente and University of California-San Francisco and foot ankle MRIs from Cleveland Clinic in ejecting her from the UWHarborview without a required medical screening exam and cut through only one of two leather straps of a Longchamp bag by 5’4” aspiring runway model & actress Jane Gurevich, a UW-Harborview security guard, & 5’6” Brady-listed at the time perjurer Andrew Vanderwielen, a Washington State Patrol Trooper, based on security camera footage that obviously depicts excessive use of force except for people that are intentionally legally blind? https://youtu.be/FmD9a2i4m0, https://youtu.be/vY4KdkIc51c

Did the 9th Circuit 3 judge panel err in claiming there was no bias in assigning the Honourable John Coughenour, an adjunct State of WA Law School professor, on a case involving UW-Harborview with a past history of successful appeals and some awful gross out IMO decisions like Silva v. Arabi, 14-cv-0049-JCC (WAWD 2014)?

Did the 9th Circuit 3 judge panel & the Honourable S. Kate Vaughan err in dismissing a motion to compel discovery for Defendant Gurevich and her claims of employment at Kaiser PermanenteBellevue as an Emergency Department Technician, which Kaiser Permanente told me has no ER department and does not employ EDTs several times, including via a recorded phone call? https://youtu.be/XnSvV9zkOBs

Did the 9th Circuit 3 judge panel err in denying relief under U.S.C. 1983 and the 1st, 4th, 8th, and 14th amendment for Chang’s claims’ including being ejected from the Emergency Room without a required medical screening exam, avulsion fracturing Chang’s ankle, and having 5’4” aspiring runway model & actress Jane Gurevich freak her out with an obvious weave and conical head in Chang’s opinion as a former hair model for Bumble& Bumble, a subsidiary of Estee Lauder, claiming Chang didn’t deserve the medical screening exam since she was “fat”, and having Emer­ gency Doctor of Osteopathy Riddhi Kothari DO deny Chang had a disability at the time and in discovery against opinions of Kaiser Permanente-Bellevue, Cleveland Clinic, U.S. Social Security, University of California-San Francisco, and many expert witnesses?

Did the 9th Circuit 3 judge panel err, pursuant to Ninth Circuit Rule 32-2, by granting Appellees’ untimely motion to file a fat brief? New issues were raised for the first time in a reply brief from Appellees, including offers to take up the burden of replying to their fat brief by allowing a fatter appellant reply brief with an additional 2,850 words, claiming lack of pre­ judice towards Chang for their fat brief. Federal rules of appellate procedure remaining unchanged for years mandate parties file motions to file a fat brief on or before the due date. Appellees were already allowed a longer brief due to joint brief filing, but decided to file a fat brief with a false Form 8 certificate of compliance with standard joint brief length for their deficient brief. This blatant noncompliance demonstrated bad faith & lack of diligence or extraordinary & compelling need. Appellees contradictorily argued issues were uncomplicated & there were no extraordinary circum­ stances in opposing my motion to file an overlength opening brief. Courts have denied motions to file overlength briefs and imposed sanctions on represen­ ted parties when they decide to skirt the length rules this way. Fleming v. County of Kane, 855 F.2d 496 (7th Cir., 1988).

Did the 9th Circuit 3 judge panel err by concluding Chang cannot allege a 14th Amendment claim because state law provides an adequate post­ deprivation remedy for property loss caused by the state?

Did the 9th Circuit three judge panel err by concluding Chang did not prove constitutional law vio- lations, including but not limited to the 1st, 4th, 8th, and 14th amendments, by former Seattle Police Depart­ ment Officer Brian Hunt and establish Monell Liability for City of Seattle by pointing out its settlement agree­ ment with the U.S. government and other entities on escalating minor incidents, acts of violence, and other misconduct for people of color and with disabilities especially mental illness, failure to render emergency aid for Chang’s avulsion fractured ankle and other injuries, and Hunt’s prior complaint history, including a $185,000 settlement for beating an African-Ameri­ can man for allegedly littering or smoking with some ash. City of Revere v. Massachussetts General Hospital, 463 U.S. 239 (1983). Penilla v. City of Huntington Park, 115 F.3d 707 (9th Cir. 1997). https://www. prisonlegalnews.org/news/2009/feb/15/185000- settlement-for-man-needlessly-beaten-by-seattlepolice/

Did the 9th Circuit three judge panel err by concluding Chang did not prove 5’4” aspiring runway model & actress Jane Gurevich, 5’6” Brady listed for perjury WSP Trooper Andrew Vanderwielen, former SPD Officer Brian Hunt, City of Seattle, a muni corp, were deliberately indifferent to Chang’s avulsion fractured ankle, vascular injuries, and mental and physical health emergency issues? Farmer v. Brennan, 511 U.S. 825 (1994), Penilla, United States, v. City of Seattle, Black Lives Matter v. City of Seattle, No. 2:20- cv-00887-RAJ., 516 F.Supp.3d 1202 (WAWD 2021).