Case 2:19-cv-03056-PA-JC Document 1 Filed 04/19/19 Page 1 of 26 Page ID #:1

~FtL~

i Black Patients Matter ~F„~l rrar„e~

1Q1q ~4PR !9 ~M t I ~ ~~
2 3010 Wilshire Blvd, Suite 496 (Address Line 1)

3 Los Angeles, Cf~ (Address Line 2)

ri ~, c '
4 91 ~ 7~7 366 (Phone Number) ~,.~~,

5 Plaintiff in Pro Per

6
7
~~
8 UNITED STATES DISTRICT COURT
N~
9 CENTRAL DISTRICT OF CALIFORNIA
10
11 BLACK PATIENTS MATTER Case No.: CV 19- 03056 ODW(DFM)
(To be supplied by the Clerk)
12 Plaintiff,
13 vs. Civil Rights Complaint Pursuant to
DEAN R. GRAFlLO, CALIFORNIA DEPARTMENT OF
42 U.S.C.§ 1983(non-prisoners)
14
CONSUMER AFFAIRS,ICEIZ[2[E WEBB,
15 Jury Trial Demanded: Yes D N
16 MARYKAI'HIZYN CRULJONES,

17 KIMBERLY K1xcHIvlti~.YEx

18 Defendant(s).
19
2~ (Allparagraphs and pages must be numbered.)

21 I.JURISDICTION
22 1. This court has jurisdiction under 28 U.S.C. § 1331 and 28 U.S.C. § 1343.
23 Federal question jurisdiction arises pursuant to 42 U.S.C. § 1983.
24
25 II. VENUE
26 2. Venue is proper pursuant to 28 U.S.C. § 1391 because there is no district in
27 ,. ,, ,..,

28 giving rise to the claim occurred. on computer terminals in Los Angeles County and Defendants'
actions resu to m racia iscrimmation t roug out t e state o a i ornia.

Pro Se Clinic Form Page Number

 Case 2:19-cv-03056-PA-JC Document 1 Filed 04/19/19 Page 2 of 26 Page ID #:2

1 III. PARTIES
2 Black Patients Matter
3. Plaintiff resides at:
3 (yourfull name)
3010 Wilshire Blvd, Suite 496
4 Los Angeles, CA 9001.0-1103
5 (your address)

6 (You should specifically ident~ each Defendant you intend to sue in a separate, numbered paragraph.)

8 4./ 5. Defendant Dean R. Grafilo and the CA Dept of Consumer Affairs works at
Gull name ofDefendant) (CA DCA)
9
California Department of Consumer Affairs
10 (Defendant's place ofwork)

11 Defendant's title or position is Dean R. Grafilo is the Director ofthe CA DCA

(Defendant's title or position atplace ofwork)
12
13 This Defendant is sued in his/her (check one or both):
14 L7 individual capacity L9 official capacity
15 This Defendant was acting under color of law because: as Director ofthe CA DCA,
16
instead of prioritizin,~patient safety as measured by number of complaints to the DCA,
17 Defendant Grafilo used his position to not only discriminate against minority physicians but morE
18 importantly marginalize black patients.

19 5. Defendant Kerrie Webb works at

(full name ofDefendant)
2~
Medical Board of California
21 (Defendant's place ofwork)

22
Defendant's title or position is a California Deputy Attorney
23 (Defendant's title or position atplace ofwork)

24 This Defendant is sued in his/her (check one or both):

25 O'individual capacity ❑official capacity
26
This Defendant was acting under color of law because: as the staff counsel for the
27
Medical Board of California(MBOC),she misused_ her position to discriminate and intimidate
28 a disabled African-American quadriplegic individual attempting to attend a public
MBOC meeting to express his opinion and experience regarding Black patient care in California

Pro Se Clinic Form Page Number

 Case 2:19-cv-03056-PA-JC Document 1 Filed 04/19/19 Page 3 of 26 Page ID #:3

1 Defendant MaryKathryn CruzJones works at

Insert ¶ # (full name ofDefendant)
2
Medical Board of California
3 (Defendant's place ofwork)

4
Defendant's title or position 1S Associate Governmental Program Analyst
5 (Defendant's title or position at place ofwork)

6
This Defendant is sued in his/her (check one or both):
7
individual capacity official capacity
8
9
This Defendant was acting under color of law because she misused her position to
10
mislead and intimidate a disabled African-American quadriplegic individual attempting to
11 attend a public MBOC meeting to express his opinion and. experience regarding Black
12 patient care in Ca i orn~a.

13
14
15
16 Kimberly Kirchmeyer
Defendant works at
17 Insert ¶ # (full name ofDefendant)

18 Medical Board of California

(Defendant's place ofwork)
19
20 Defendant's title or position is Executive Director
(Defendant's title or position at place ofwork)
21
22 This Defendant is sued in his/her (check one or both):
23 individual capacity ~ official capacity
24
25 This Defendant was acting under color of law because Sadly, NIs. Kirchmeyer misused
26 her position as Executive Director of MBOC to marginalize and discriminate against
.. .. . ..
27 K~IIITiiLIIiL~YIs[~Ii~ ~'_lyiZ~ldil~i~iY_iii[~il~:Li~I~Z~R~i[~iil~L~i[~9K~i~~Y.i~~f[~~~~~ii1~71~•/

2g
and correspondences.
.~
Pro Se Clinic Form Page Number
 Case 2:19-cv-03056-PA-JC Document 1 Filed 04/19/19 Page 4 of 26 Page ID #:4

1 IV.STATEMENT OF FACTS
2 Explain what happened in your own words. You do not have to cite legal authority in this section. Be specific
names, dates, and places. Explain what each Defendant did. Remember to number every paragraph.)
3
Defendants Webb and. CruzJones were acting under color of state law when violating
4 Insert ¶ #

5 Plaintiff BPM's(Black Patients Matter) right to equal treatment under the law: Exhibit L (arrov~

6 states: "The[MBOC]meeting is accessible to the physically disabled. A person who needs a

7 disability-related accommodation or modification in order to participate in the meeting may ma:

8 a'reauest' by contacti CruzJones.. providing your request at least 5 business da

9 before the meeting.." On December 4, 201.8 PlaintiffBPM emailed Defendant CruzJones for
10 ~ecial accommodations for a dysarthric wheelchair-bound African-American elderly
Approximately two weeks later, Plaintiff called Defendant CruzJones to discuss special
11
accom modations and instead of being directed to MBOC's designated ADA coordinator
12 Inse''t ¶ #
Alexandria Schembra (Exhibit M), Plaintiff BPM was redirected to MBOC attorney
13 Defendant Webb. After hearing the disabled black patient speak a few words, Defendant Webb
14 concluded "based on how I'm hearing the way he moves his tongue, I'll let him speak for 5 minus
15 instead of the 3 minute rule." Defendants violated Plaintiff BPM's right to fair treatment by not
16 allowing a clinician to diagnose the patient with dysarthria and also for not allowing him to
17 with the 1VIBOC-designated ADA coordinator but instead being directed to speak with an attorne
18 regarding special accommodations for his disability.
19
20 v~~ v~ auvu~,raiivaiy ✓~ ~,vi~ a~ i ~uuiuii vviuii~~~.~ iii~.~uv~i ii.i~, vvu~ }~i~~a~~u~ ii~.~ Ul+ll'1

I"Serr ¶ #
21 against the MBOC Accusation(OAH No. 2018030315) in addiction to her defense agaii
a ~PraratP lawcnit and m>>lti~le failed attempts at restraining orders hroug~~ affiliates ~f
22
Orchard Hospital (Superior Court ofCA r of Butte No. 17CV03671), as well as
23
testimony by teleconference to the US Health &Human Services OIG in Washington DC as
24
witnessed by one of her attorneys, H.R. unfortunately discovered the extent of racial bias and. re]
25
intolerance ignorance brought against her by Defendants also involved the CA Department of C~
26
Affairs(DCA)(Exhibits N1-N4). Plaintiff was disappointed to discover the DCA maintained a
27
wont of"fake diversity" in that it provided the appearance of racial diversity but in fact maintain
28
a practice not limited to "less blacks, no hijabs, nor Sikhs" as illustrated in Exhibit P. Although
Exhibits Q&R are the opening pages ofthe DCA's website which does illustrate racial diversity,

Pro Se Clinic Form Page Number

 Case 2:19-cv-03056-PA-JC Document 1 Filed 04/19/19 Page 5 of 26 Page ID #:5

sadly none of the individuals featured on Exhibits Q, Rl are employed nor affiliated with the D(
Insert ¶ #
2 in any way, and all are in fact merely paid. actors. Exhibits N]-N4 illustrates the biased appointn
3 lacking racial diversity caused by the previous CA Governor's habit of"fewer black appointmem
4 using the excuse of"I couldn't fiind any qualified black people to appoint."
5
6 The CA Business and Practices Code states "The boards, bureaus, and commissions in the depar
7 are established for the purpose of ensuring that those private businesses and professions deemed
8 engage in activities which have potential impact upon the public health, safety, and welfare are
9 adequately regulated in order to protect the people of CA"(BPC Section. 101.6), the Defendant
10 has wiled to protect the people ofCA as the number ofcomplaints to MBOC has significantly
znserr ¶ #
11 increased since his appointment; he has instead used his position to discriminate against religious
12 faith-based racial minorities acting lawfully as in the case ofBPM volunteer H.R. by failing to
13 adequately train workers at DCA regarding religious tolerance diversity, as well as failing to hire
14 underrepresented minority state workers, and systematically contracting with medical experts wr
15 instead choose to practice medicine on a racially non-diversified patient population so as to
16 "avoid black patients." In addition to "hiring less black workers" within the Division of Investig
17
his Department has not surprisingly utilized his investigative resources to target underrepresentec
18 minority physicians (Exhibit R). But of utmost concern are the numerous studies which have red
19 minority patient populations' preference for clinicians within their own race; Defendant Grafilo
Insert ¶ #
2~ has resultantly misused his position as Director ofCA DCA to not only unfairly target said
21 minority physicians, but sadly to discriminate against black patients (Exhibit S).
22
23 As a result of such biases, not surprisingly the CA DCA's Chief of Division Investigation(DOI)
24 "law enforcement" agency states its values are based on "doing what's right for the public"(mak
25 no statement regarding enforcing the law as a priority) by not hiring a racially diversified investi ve
26
agency nor ever having any training whatsoever in religious diversity so as to continue to target
27 racial minorities mocking them as "odd.... strange... outside of societal norms" when in fact they
28 were merely acting as one does within their race and religious beliefs as was the case with BPM
volunteer H.R. In all other types of law enforcement investigations, there is always a photo ofth
accused enclosed with the case file. However, in the case ofthe CA DCA and MBOC,a photo
is not forwarded to MBOC so as to create a~~cial and religious bias for "odd behavior."
Pro Se Clinic Form Page Number
 Case 2:19-cv-03056-PA-JC Document 1 Filed 04/19/19 Page 6 of 26 Page ID #:6

1
2 When the CA DCA isnon-diversified, it becomes evident why racial. and religious minorities
Insert ¶ #
3 are unfairly targeted in the investigative process (Exhibit R2). Sadly, the CA DCA DOI which.

4 which investigated MBOC complaints never acknowledges the few African-American employee

5 diligently working long hours despite hardships as all. their DOI "'STARs"(Staff Appreciation
6 and Recognition) are not racially diverse "we couldn't find any black workers who deserved
7 our appreciation and recognition."(Exhibit T4-TS) While forcing CA DCA DOI employees to s

8 a table in the breakroom or to drink from the same water fountain or to sit at a desk near more
9 African.-American. coworkers may be too disruptive to their work flow, it is this work culture
which allows the CA DCA DOI to successfully investigate and create biased Accusations
10
against racial and religious minorities.
11
Insert.¶ #
12 On February 3, 201.9 Plaintiff was deeply saddened and hurt to learn they were marginalized /
13 ignored and not included in Defendant Kirchmever's emails to "patient advocacy" ~Lroups despite
14 Paintiff Black Patients Matter being present and speaking publicly at numerous MBOC

15 meetings and emailing /speaking with MBOC affiliates such as Defendant MaryKathryn

16 CruzJones and Defendant Webb.(Exhibit V)

17
18
19
20
21
22
23
24
25
26
27

Pro Se Clinic Form Page Number

 Case 2:19-cv-03056-PA-JC Document 1 Filed 04/19/19 Page 7 of 26 Page ID #:7

1 V. CLAIMS
2 Claim #1
3 L.
Insert ¶ #
Plaintiff realleges and incorporates by reference all ofthe paragraphs above.
4
Plaintiff has a claim under 42 U.S.C. §1983 for violation ofthe following
5
~nserr ¶ # federal constitutional or statutory civil right:
6 Equal protection under the law, right to assemble, and right to freedom ofspeech
7
8
9
10
i. The above civil right was violated by the following Defendants:
~
11 Insert ¶ #
Dean R. Grafilo, CA DCA,Kerrie Webb, MaryKathryn CruzJones, Kimberly Kirchmeyer
12
13
14
15 (You may listfacts supporting your claim. Be specific about how each Defendant violated this particular civil right.)

16
17
18
19
20
21
22
23 i
'

24
~. As a result ofthe Defendant's violation ofthe above civil right, Plaintiff
25 Insert ¶ # was harmed in the following way:
Because Defendants Webb and CruzJones did not follow the ADA protocol published on their w~
26
the dysarthric, quadriplegic African-American member ofBPM was intimidated into not speakin
27 ~,uv.~v.) u.~ ....., ...~.......,.....~. ,.b. ...........,.~.... ..,......,.,. .,. .> ................,. .....,.........~.,.....~............).., ., .......,.,

28 inc~irPc~tl~hrni~ah SeCnncl hand infnrm~tipn, Plaintiff wac not Elie tcialert itc mem~erc
so as to assemble their volunteers to speak at the patient advocate meeting.

Pro Se Clinic Form Page Number

 Case 2:19-cv-03056-PA-JC Document 1 Filed 04/19/19 Page 8 of 26 Page ID #:8

1 VI. REQUEST FOR RELIEF

2
3 WI-~REFORE,the Plaintiff requests:
ACLU
4 (1) $1 (one dollar)to be donated to California's
Insert ¶ #
5 (2) MBOC to include Plaintiff in all correspondences, meetings list of patient
6 advocacy groups.
7 (3) Public verbal apology to Plaintiff Black Patients Matter at the next MBOC meeting
8 for which a member of BPM will be present
9
(4) Racially and religiously diversified CA DCA DOI work force reflective ofthe
10 Insert ¶ #

11 population in which the MBOC investigates, charges, and settle cases.

12
13
14
15
16
17
18
19
20
21
22
23
24
25
26 Dated: ~ ~ ~' ~~~
27 Sign: ~/I.Gi ~ ~G~~~ /'i~
28 Pt~int Name: Black Patients Matter

Pro Se Clinic Form Page Number

 Case 2:19-cv-03056-PA-JC Document 1 Filed 04/19/19 Page 9 of 26 Page ID #:9

1 DEMAND FOR JURY TRIAL

2
3 Plaintiff hereby requests a jury trial on all issues raised in this complaint.
4
5 Dated: y l ~ ~5
6 Sign: ,~~~~ ~~~ ~~%~~~
7 Print Name: Black Patients Matter

8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28

✓~
Pro Se Clinic Form Page Number
 Case 2:19-cv-03056-PA-JC Document 1 Filed 04/19/19 Page 10 of 26 Page ID #:10

Meetitlt~ information ~ (~x~(~l / !.~-

This meeting will be available via t~elecvnference. Ir~div~duals listening
to the m~etinc~ will have an
opportunity to provide public.comment as outlined below.

Fc~r Thursday, January 31, 2419

Call in number: 888-455-972
Passcode: 8280~i64 (callers will be asked to verba(!y provide
this cods to the c~peratar to enter the meeting)
Please wait until the operator has introduced you before you make your
carnments.
Ta request to'make a comment during the public c~mm~nt period, press '~1; you will
hear a tone
indicating you are in the queuefir cvmrnent. if you change your mind and da not
want to make a
comment, press *2. Assistance is available throughout the teleec~nference meeting.. To
request a
specialist, press *0.

During Agenda item 2 — Pubfic Comments on Items not ort the Agenda, the Board his limited the
#otal
public ~ornment period via t~leeonference to 2Q minutes. Therefore, after 20 minutes, no further
comments vuill be accepted. Each person will be limited to three m r~ut~s per agenda item.

During public comment an any other agenda item, a fatal of 10 minutes will be a{lowed ft~r comments
via the teEeconference (ire. After 1fJ minutes, nv further ~amm~nts will be accepted. Each person wilt
be iimit~d to three minutes per agenda item.

Comments for those in attendance at the meeting will have the same time limitations as those
identified above for individuals on the teleconference line..

Ptease Na#e: Because khere is an audio delay, if you are participating by phone and simultaneously
watching the Webcast, the Board requests you turn ofF the.sound to the Webcast for improved clarity.

The rnlsslon of the Med3caf Board of California is to profect health care cnnsum~rs through the proper !cans ng and regula on o
physicians and surgeons ~Itd'certairr allied health care professionals and through fhe vigorous, objective enforcement o/fhe lNedlcal
Pract7ce Act and to romote access tv uall med/ca!care throe h tha Board's /Icensln and re ulato functions.
Meetings of fire Medlcaf Board of California are open Ro the public except when specifically noticed otherwise!n accordance with the Open
Meeting Act. The audience w81 be gJven appropriate opportunities to comment on any issue presented Jn ope» sessfon before the
Gomrrilffee, but the Ghalr may apportion available time amount those who wish to sAeak.
For addltlanaf Information, call 9?5 2b3-- 23E9.
he meeting fs accessible to the physically disable arson who nee sa ty-re a e mrraodallvn ormodlflcatlo
order to partlaipate In Ehe meeting may mak request aontaatin Mary Kathryn Cruz Jones a (946J X63-2388 or
thrvn.cruzlonesCa71n6c.ca~r oaf esr send a wrfft o Mary Kathry ur req~ast at least rive(5)
 Case 2:19-cv-03056-PA-JC Document 1 Filed 04/19/19 Page 11 of 26 Page ID #:11

~ rvc:secure vnvw.~~ cz~.gc~v ..:; _ ~,

.;ac~~: r :irk; ,, ~cgle Gc~rt~l~ ,.,!; ,. .~ EY ~~ ~~,, , ¢~' _ .,Ee <:a:.~;~~ar ,.~ ~ ~r~ir IE ~ ~cagl~ Nea~.~ Gcagf~ `~1a~~ IE
__ _. r—

C7if~i ~.tlty ~cces~ir~t~ N1~t~ri~l ,~,'C' ll l~ /

difficulty accessirs~ arty mafi~r~a~ on This site because Qf a dfisabi[ity, please eontaei us in t~+ritin~ or via telephone anc~ tea wit(
ork v~rith yo~c o make the information available. You can direct your request to:
w
r~1e~:andri~ ~ch~n~bra. ADA Coordinator
20i15E~ergr~er~Str~?t, Suite 7200
Sacramento. GA 95815
916-2~3-2466
 Case 2:19-cv-03056-PA-JC Document 1 Filed 04/19/19 Page 12 of 26 Page ID #:12
i2f1

Select Language

M TA t'G O IR CALIF Qsi M~ n

`
.

DEAN R. GRAFILO, l7ireetar

~ ~ ~~p Dean R. Grafilo was appointed director ~t the department of Consumer
Affairs in February 2~~.7. With C~~,~'s ~xecutivc team, he ~eacl~ the
:K~""~ regulatory entities end other divisions within DCA. Prior to his
' ~ appointment,GraFila was chief of staff in the office of state Assembly
~ s~ ~_~ Member Rob Bonta since 2012, He was a~saciate director of
t,,
,~ ,~ ' government relations at the Ca{ifornia MedicaC Association from 2009
to 2012,chief of staff in the office cif Assembly Member Warren T. Furutani from 2008 to
2QU~,and a senior legislative assistant in the office of Assembly Member Alberto Torrico
from 2004 to 2008. Grafilo was an organizer representative ~t Service Emplt~yees
international Union Local J~5 from 20Q3 to 2g04, and a political intern at the M.L. King
Co~~nty Labor CaunciC in S~att(e in 2002.5tarting in 1996 through 2001, he was a field
representative and organizer at ln~~rnational Longshore and Wareht~use Union Local 1A~2
in Hawaii. Grafilo earned a master of public administration degree from fihe University of
Wa~hingtan.

`,:~~ ~HR1~Tt}PMEFt 5HULTZ, ChiefDeputy Director

Christopher Shultz was appointed in October2q].7. Shwttz was deputy
` ~ R; commissioner of community programs and policy initiatives at the
`'~~~• ;; California D~p~rtment of insurance from 2017. to 2017. He was
`'~ fegislat'rve director in the Office of California State Assembly Member
~~
`~i:.. Davy Janes from 200 to 2010, where he served as chief of staff from
' - 2004 to 20'6. Shultz was public affairs director at the Ulum Group from
2D06 tQ 2009,director of Califr~rna State Senator Dede Alpert's Capitol Qffice from 2002 to
2004,and legislative aide in the Office of California State Assembly Member Ted Lempert
from 19 6 to 1 99. He was ~ technQla~y policy coordinator in the' office of the Secretary for
Education from 2001 to 2002 and manager of state government affairs at the American
Electronics Asso .iation frorr~ 1999 to 200 .Shultz completed the Leadership for
Government Executive Certificate Program at California State University, Sacramento, in
2013,and earned his bachelor of arts degree from the University of the Pacific in 1995.

MI[ps://www.dca.ca.govlabout_dcalleadership.shtml 1/5
 Case 2:19-cv-03056-PA-JC Document 1 Filed 04/19/19 Page 13 of 26 Page ID #:13
fi~11012~`!

r,r =. RYAN MARCRQFT, aeperty Directc~~, Legal Affairs Division

Ryan Marcroft was appointed in Ju[y 2017 as deputy director of the
'~ ~ c Legal Affairs Division. He previously served as DCA's assistant chief
counsel since 2016. Priorto his appointment, Marcroft was a deputy
,
. attorney general at the California department of Justice} Office of the
~.. -~= y ~ Attorney General,si~ee 2010. He was a deputy legal afFairs secretary in
~~ .
' the ~a~ernor's Qf~ ce from 2006 to 20iQ,and a staff attorney at the
Institute far Administrative Justice, Cpl forni~ Parole Aduocacy Program,from 2004 to
206. Ne earned a Juris Doctor degree from the University of the Pacific, McGeorge 5choa!
of Law.

+~~tACE ARUP+~ ~tC~~RIGtlEZ, Assistant ChiefCauns~l, Legal Affairs

Division
Grace Arup~ Rodriguez was appo~r~ted ire .luly 2Q1'~. Prior t~ ~t~r
appointment at DCA, Arupo Rodriguez served a~ deputy directe~r of
legal affairs in ttie Governor's Office of Business and. Economic
Dev~lopmentfrom 2013 to 2t}17, and as senior deputy city attorney in
the Sacramento City Attorney's Office from 201.2 to 2Q13. She was
corporate counsel at the California Independent System Operator Corporation from 2007
to 2012,a business associate at Downey Brand LLP from X002 to 2006, and a summer
associate at Wilke Fleury Hoffelt Gou[d and Birney LLP in 2000. Arupo Rodriguez was
president of the Asian Pacific Bar Association of Sacramento from 2Q11 to 2012. Sloe
+earned a Juris Doctor degree Froi~n fihe University of California, Davis, School of Law.

CHRISTt1R3~~R ~ASTRIi.LO, Deputy Director,. Office ofBaard end

Bureau Services
.: Chris~tr~pher CastriElo was ~p~ointe~ in ~c~aber 2t~17. Castrillo was a
~` ~' =` Cegisl~tiv~ acivoca~~ at Shav+tJYoderjAritwih Inc.from 2014 to 2p17,
°>,~: where he was a legislative aide.from 2013 to 201 .Fie was a field
director far Dr. Richard Pan for Senate in 2ti~.4, a I~ad organizer at
Graundw~rks C~rr~P~i~rrs in 212,and a le~islative assistant at
Lehman,Levi, P~p~as end Sadler in 20 .0. Cas~ri~lo ~~rnec{ bachelor ofi arks degrees ire
planning, public policy and management as well as political science,from the.University of
Oregon in 2009.

DENNI~~t1EVAS-RQM~RU, aeputyt~irector, DivisionofLegislative~l~f~ir~

C7ennis Cuevas-Romero was appointed in February 2018. Priarto his appointment,Cueuas-
Ramero was the government relations dir~ctar at the ~american Heart
AssociationfAmeric~n Stroke Assaciatior~ in Sacramento since 2016. He was a legislative
associate atthe Hernandez Strategy Group from 2013 to 2016 and a postgraduate !aw clerk
at the Sacramento Regional Fair Housing Commission En 2Q12. Cuevas-Romero was a legal
https:!/www.dca.ca,gov/about dcalleadership.sh#ml 215
 Case 2:19-cv-03056-PA-JC Document 1 Filed 04/19/19 Page 14 of 26 Page ID #:14
~--

12/10/20 ~ 1 ",~

intern at Refugees International Japan in 2012, and at Opening Doors ~"

;~, Inc., California Rural Legal Assistance, and the University of the Pacific,
'~''~ ~ McGeorge Schaal of Law Immigration Law Clinic, in 2011. Cuevas-
+
~ ;.~>-' .
n~ ,''r Romero earned a Juris Doctor degree from the University ofthe Pacific,
r' McGeorge School of Law.

VERQ~NIGA HARMS IJepu~~Director, Communications

Veronica Norms was appointed in February 2016. As deputy director of
camrnunications, Harms oversees the offiices of Public Affairs,
publications, Design and editing, and Digita(Print Services. Prior to her
appointment,she worked at the State Senate Democratic Caucus,
where she served as a consultant and media specialist since 2012.
Harms held multiple positions at Ogilvy Public f~elations from 2Q47 to
2012, including senior account executive and account supervisor. Sf7e held m~►itiple
positions at KCRA-TV from 2Q04 to2007, including national sales assistant, lacat sales
assistant and account executive, and was a loyal sales assistant at KOVR-TV in 240 . Harms
earned a bachelor of arts degree in communications from the University of California,
Davis, and master of business administration degree from California State University,
Sacramento.

~ IF
, NA7AL1~ DANIEL, t~epuiyDir'ector, Administrative S~ruices
~~, '~ Natalie Daniel was appQin~~d in October2017. Daniel was fiscal
~{`'"" ""-~'~Y superv`rsar at the J_ ~~dicisl Council of ~alifomia from 2Q15 to 2017.. She
F`. n~~ ~ ;.~ served in several positions at the California [7epartment of Finance
from 20 9 to 2015, including staff finance budget analyst far state
f ,''F L }~ ~ operations and the Capital Outlay Unit. Daniel held several positions at
,r
the California State Water Resources Contra{ Board from 2Qp~ to 2009,
including staff services manager and associate budget analyst. She was an associate
governmental program ~nal~st atthe California Pubic Er~7ployees' ~etirem~nt System
from 2005 to 2.007 and served in seven(positions at the California Department of Justice
from 2000 to 2005, including staff seruices analyst, ~ssaciate budget analyst, and ~ssotiate
governmental program analyst. Daniel ~~rneci a master of public administrakion degree
from the University of Southern California.

JAS~tV PIGCIONE, Deputy Director, Office nf(nfarmation Services

Jason Piccione was appointed in Nouember 2415. As chief information officer, he oversees
DCA's Office of Information Services as well as sets direction for information technology
ana coordinates infrastructure and service delivery across DCA. Prior to his appointment,
Picciane served as DCA's chief technnlagy officer. He has held various positions at the

hltps://www.dca.~a.gov/about dcalleadershp.shtml 3/5

 Case 2:19-cv-03056-PA-JC Document 1 Filed 04/19/19 Page 15 of 26 Page IDv#:15
v-- - - •-

12/10/20 ~ / ,~

Bureau for Private Postsecondary Education and the Contractors State

~~`~ License Board. Pictione has~wc~rked mire than 15 years in public
service. He obtained a bachelor of arts degree from the University of
.~~~` California, Davis.
.
,
~ ,-

. .. ~,` TRACY'MONTEZ, Chief, Division ofPrograms and Policy Review

~~~-- ~`'~ Tracy Montez was appointed in February 2016. As chief of division of
'~ 'a pragram~ and policy review, Montez oversees a number of units within
; ~ ~ DCA,including the Office of Professional.Examination Services(OFFS)
~~~ andthe Consumerinformatian Cenker. Priorto herappointment,
,
, ;i4 Montez served as the branch administratorforthe District, School, and
' ~~_~, ;~~~{',` fnnova#iron Branch in the Deputy Superintendent's Office within the
California Department of Education. She his more than 2Q years of experience providing
assessment end regulatory expertise to city, state, and national organ zatians. Previously,
she held the position of chief at OPES and served as an independent consultant,
contracting witf~ several b~aards under DCA. Mantez holds a doctorate of philosophy in
industrial and organizational psychology from Kansas State University.

DAVId M.CHR155, Chief, Division oflnvestrgation

~_ David M. Chriss vuas appointed in January 2016. From 2012 to 2016, he
; ;, ~. had s~rv~d as deputy chief for the Division of ~nv~stigation. Wier more
~" ♦ than 27 years of investigative and managerial law enforcement
~~ ~ ~ experience, Chris has held various law enforcement positions
\
~ % '' thiroughout his career,.including deputy inspector general, senior fior
the Office ofthe Fnspector General,supervising investigator,senior
special inuestigatar, and investigator. He also served as a police officer, police corporal, and
police sergeant for the Lincoln Police Department. Chris obtained a bachelor of arts:
degree in government and international relationsfrom California State University,
Sacramento,and an associafie of arts degree from Sierra College in administration ofi
justice.

pCA Board Member foster

t~~e3~ ~i C~ 9~~f7

l.Qri$~ut l3S

https:l/www.dca.ca.gov/about dcalleadership.shtml 415

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VITELC~JNIE FRt~IV~ ~HTEF ~AV~DM.~HRIS~

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'~ ''" ~ -~--~ ~ Wel~at~~ ~a the QUA Division of I~~~s~iga~iQn {DQ~} blag- ~~rr
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'~~`.~ . - committees, and comrnissi~n. Pho

C~urprofessi~nai investigative~'taff provide the ~tghestquali~yinve5tigative

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Are you looking for a chal~engin~ end exciting .career in Iaw er~~orc~r~ent~ ~lrck on the "~~BS AT ~DOI~'
tab abo~re to learn how y~~~ can join aui~ tearr~! tv~ar
Tr~r

Oar Cannabis Enforcement ~uni~ is actively recruiting—the pa~~age of Senate BiiE ~~. in July 2~~~ rr~erged
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ft~SOrURCES CONTACT US

II~TSIL~E I~~}~

I ts March ~4~8, ~~e Division Qf fnves~igatior~ (D~l~ he~~i i~~ St~~~ Ap~reciatior~ and R~cogr~itiar~r (STfi~f~~
awards ~eren~ony~, which reca~nizes ernp~oyees for s~~i~~r service. E~nplt~y~e~ v~rer~ n~r~ina~ed for STAR
av~ards ~flr ~xee~ational performance, cr~ativ~ty, organiz~tiQnaf ~bilities~ w~r4~ ~u~cess and teamwork,
DOi, and Depa~tmer~~C of Consumer Af#airs C~irecto~ Dean Grafilfl was proud t~ present ~~~~~i~n~s with
certificates ar~d medals at a c~remany held before ~cov~rork~rs, fi~mi~y ar~d ft~i~nds. Dpi was ~onar~d~ to
acknowledge ~n~~lc~yees for their Bard ti~rork and fc~r m~~~~~g DC~i sf7it~~.

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Case 2:19-cv-03056-PA-JC Document 1 Filed 04/19/19 Page 24 of 26 Page ID #:24

Ill~~esti~att~r ~~ev~ i~icllols.

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F~ren i~~o~eaa'Gai~ay, t~ffiee Tecllnieial~~l~erry Le~~Fis,S~l~ei-~~isi`i~gIllvestigator Eiliil}~ Kefldric~:, Su~e~~v~sin~ It1~~~stiQ~tor i~~~~,k
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Case 2:19-cv-03056-PA-JC Document 1 Filed 04/19/19 Page 25 of 26 Page ID #:25

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Case 2:19-cv-03056-PA-JC Document 1 Filed 04/19/19 Page 26 of 26 Page ID #:26

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