Preview
He 4S 909-4 2.1 FI
Justin & D enisha Walton
eI 7eP GG ale Superior Court of California
County of San Francisco
SE cA M22
400-MeAHister-Street—
San Francisco, CA94102_—
MAR 13 2024
SUPERIOR COURT OF THE STATE OF CALIFORNIA JAMES FORONDA
COUNTY OF SAN FRANCISCO
Justin & Denisha Walton Case No.
CPF -24-518492
Plaintiffs Judicial Review Petition
Vv California Administrative Procedures Act
Challenge to Agency action
San Francisco County California Code of Civil Procedure
Department of Children and Family (CCP) §1094.5,
Services Juvenile Case No.
JD22-3070-C/D/E/F/G/H.
Defendants
[EX PARTE]
APPLICATION FOR ALTERNATIVE
WRIT OF ADMINISTRATIVE
MANDAMUS,
[CCP §§1087, 1107]
COMES NOW, Plaintiffs Justin and Denisha Walton the Plaintiffs, aggrieved parties seeking an
Alternative Writ of Mandamus, to challenge the unjust administrative actions of San Francisco
County Department of Children and Family Services (DCFS), the Defendants.
NATURE OF THE CASE
The Plaintiffs contend that the respondents, DCFS, have acted in excess of their
jurisdiction and abused their discretion which violated the procedural and substantive rights
guaranteed under the California Code of Civil Procedure §1094.5(b) and (c).
Through a pattern and practice of denying the plaintiffs’ a right to a fair trial and
pre-deprivation hearings, the plaintiffs have been prevented fro, challenging the allegations and
presenting evidence. The plaintiffs will present legal and factual arguments that:
e The agency, through its social worker, Mamie Wong, makes unilateral decision
regarding the family without a pre-deprivation hearing or proper investigation
The court is biased and always sides with the agency which has already made
their decision before the parent even come to court
The lawyers appointed to represent the plaintiffs have breached their fiduciary
duties to the plaintiffs and instead act act on behalf of the agency by not
challenging them adequately or presenting the plaintiff’s evidence. They also
waive the parents rights in court when the parents have said they dont want their
rights waived.
WALTON’S EX PARTE WRIT OF ADMINSTRATIVE MANDAMUS
ADMINISTRATIVE DECISION(S) BEING CHALLENGED
i. Decision 1 - January 17, 2024 Decision to Terminate Parental Rights
ii. Decision 2 - March 5, 2024 Unilateral Modification of Visitation Right pre-hearing
HOW THE AGENCY VIOLATED CCP§1094.5(b) and (c)
The Plaintiffs contend that the Defendants have violated the procedural and substantive
rights guaranteed under the California Code of Civil Procedure §1094.5(b) and (c), through
actions and decisions that have not only lacked fairness and transparency but have also been
substantively unsupported by evidence and marred by abuses of discretion.
DECISION 1
The agency did not provide notice of the hearing of allow the parents an opportunity to
present evidence or challenge the petition. Additionally, the court appointed attorneys
lied to the plaintiffs on multiple occasions.
- Ryan and Peggy told plaintiff that they had not chance because they hadnt
visited the children in months. (Failing to considered the mom’s health and
the parent’s indigency). Moreover, the children can still have a bond with
their parents which remained to be seen
Ryan and Peggy both promised the parents they would file appeals but
failed to do so after parents signed and submitted notices of appeal
WALTON’S EX PARTE WRIT OF ADMINSTRATIVE MANDAMUS
- Peggy lied and said she would reschedule the hearing if mom had a valid
medical reason. After mom plaintiff sent proof, she still did not schedule
the hearing.
Ryan refused to answer the question of it what Mamie Wong was doing
deprived the plaintiffs of their rights. Instead Peggy covered for him and
told the plaintiffs they had no chance.
DECISION 2
Without a preceding court order and contrary to California Family Code Sections
3022 and 3100, which mandate court oversight for any modifications to visitation arrangements.
Defendant Mamie Wong, acting on behalf of the respondent agency, unilaterally
suspended all visitation rights for the Waltons, citing “incidents” from the February 28, 2024,
visitation but not giving details as to what these incidents were or what these incidents entailed.
This action was taken without affording the Waltons any form of hearing or the ability to
contest the suspension. This action also prejudiced the plaintiffs by providing Ms. Wong with
time to think of a reason to put in the petition as to why their visitation rights should be ended.
Mamie Wong ended the parents’ visits strategically for ulterior motives. She knows that
the parents can prove that they have a beneficial relationship with their children; and that
evidence of this would prevent the agency from terminating the rights to their other children at
their next court hearing.
By preventing the parents from visitng, she can then argue that they parents don't visit
and don't have a bond, which means the agency can move forward with permanency planning.
WALTON’S EX PARTE WRIT OF ADMINSTRATIVE MANDAMUS
EXHIBITS B
Subject: RE: Walton In-Person Visit - Wednesday, 2/28/24
Good afternoon —
Ireceived both parents’ confirmation for the visit tomorrow, 2/28/24, from 3pm to 4:30pm located at the Concord library.
I learned that during the last virtual visit, the parents asked the children to “pray that they will be returning home” to
them. This caused unnecessary confusion and disruption in their placement. The virtual visit should have ended
immediately after such comments were made.
The parameters for virtual and in-person visits have not changed. Blatant disregard for the requirements will end the in-.
person visit immediately and will impact future visits held virtually or in-person.
The visit will be 100% supervised by the Agency. The parameters previously outlined remains:
1 not allowed to speak to the kids about their disclosures, discuss the case, tell the kids they will return home or ask
them to recant their disclosures;
2. not allowed to bring any electronics of any kind’into the visit, i.e. phone, laptop, Ipad, Kindle, camera, gaming
system, etc, Note: if any devices are pulled out for any reason or any recordings of any type, the visit will end
immediately;
3. not allowed to video or audio record or take pictures; Note: the visitation and Agency staff have not and do not
consent to be recorded or have their pictures taken;
4, not to ask questions about the placement/caregiver or caregiver’s family/childcare provider; children’s respective
schools or afterschool programs;
5. not allowed to walk children to county vehicle
Please arrive on time. Per usual, you will have a 15 minute grace period before the visit is cancelled. If you are not able to
make it to the visit, let us know so the children are not transported unnecessarily.
Best,
Mamie
Mamie Wong, MSW
Protective Services Supervisor, M140
0: 415-557-6213
WALTON’S EX PARTE WRIT OF ADMINSTRATIVE MANDAMUS
On Feb 26, 2024, at 5:24PM, Denisha Walton wrote:
Hi, What number do we call to confirm?
Sent from my iPhone
On Feb 24, 2024, at 1:15PM, Wong, Mamie (HSA)
wrote:
Good afternoon —
The once a month court ordered in-person visit will be on Wednesday,
2/28/24 from 3pm to 4:30pm located at:
Concord Library - 2900 Salvio St, Concord, CA 94519
Per usual, you must confirm the visit by noon, the day before (2/27/24)
otherwise the visit is cancelled.
Best,
Mamie Wong, MSW
Protective Services Supervisor, M140
Family and Children’s Services
Family Services Unit
O: 415-557-6213
C: 415-416-9155 (preferred)
Mailing address:
P.O. Box 7988
San Francisco, CA 94120
swww.SFHSA.org
WALTON’S EX PARTE WRIT OF ADMINSTRATIVE MANDAMUS
From: Wong, Mamie (HSA)
Sent: Tuesday, March 5, 2024 9:38:24 AM
Move ; Denisha Walton
Cc: pweety.baybe415@qmail.com ; waltonnevaeh91 @gmail.com
;
rsheets@hotmail.com ; peggy @pafmap.com ;
ayeelaw @outlook.com ; ONEILL, BRENDON (CAT)
Subject: RE: Walton In-Person Visit - Wednesday, 2/28/24
Good morning —
Ms. Walton, I received your email this morning.
The Agency has suspended all in-person and virtual visits due to events that
occurred at the in-person visit last Wednesday, 2/28/24. Please await the 388
hearing.
Best,
Mamie
_
Mamie Wong, MSW
Protective Services Supervisor, M140
O: 415-557-6213
C: 415-416-9155 (preferred)
URGENCY FOR THE ALTERNATIVE WRIT
The case at hand involves egregious violations of the plaintiffs’ fundamental rights,
including the right to a fair process and to be heard, as well as the Defendants’ first amendment
right to free speech, right to religion and familial association, and the right to be free from torture
and government coercion.
Recent alarming evidence presented by a new witness shows the Walton children are
subjected to neglect and bullying in their current placement, we urgently request the court's
immediate intervention. This situation is contrary to the children's best interests and, along with
their expressed desire to return home, necessitates a swift reevaluation of their custody and
WALTON’S EX PARTE WRIT OF ADMINSTRATIVE MANDAMUS
visitation rights. Immediate judicial review is imperative to prevent further harm to the Plaintiffs
and to rectify the injustices that the Defendants have perpetrated under the guise of
administrative discretion.
Such conduct has resulted in significant and irreversible harm to the Plaintiffs,
necessitating immediate and decisive intervention by this Honorable Court.
As a direct result of the Defendants' excessive use of force and unwarranted actions, the
Plaintiffs are being separated from their children and the imposition of unjust conditions upon
their reunification, the urgency for the Court to issue an Alternative Writ of Mandamus could not
be clearer or more compelling.
In light of the Defendants' actions, which have directly resulted in the unwarranted
separation of the plaintiffs from their children and the imposition of unjust conditions upon their
reunification, the urgency for the Court to issue an Alternative Writ of Mandamus could not be
clearer or more compelling.
Immediate judicial review is imperative to prevent further harm to the Plaintiffs and to
rectify the injustices that the Defendants have perpetrated under the guise of administrative
discretion.
EXHIBITS C
C-1 Proof children are being abused and neglected and its being
concealed from parents by not letting them ask questions
WALTON’S EX PARTE WRIT OF ADMINSTRATIVE MANDAMUS
From: "Wong, Mamie (HSA)"
Date: February 21, 2024 at 2:15:48PM PST
To: Denisha Walton , imoved04@qi
Cc: ONE, BRENDON (CAT"
Subject: Justin Walton
Good afternoon —
Yesterday, I was notified that Justin had an accident at his afterschool program and broke his arm. The agency is
awaiting the incident report from the school and medical records. My apologies for the delay in notifying everyone.
Mr. and Ms. Walton, in your virtual visit today and any court ordered visits, please do not ask Justin (or his
siblings) about where he attends school or the location of his afterschool program or where he received medical
care. This will end the visit. Other parameters that have been set by the agency, remains the same:
a) not allowed to speak to the kids about their disclosures, discuss the case, tell the kids they will retum home or
ask them to recant their disclosures;
Q) not allowed to bring any electronics ofany kind into the in-person visit, i.e. phone, laptop, Ipad, Kindle, camera,
gaming system, etc — they must leave phone in a designated table/space at the visit center. Note: if an any devices are
pulled out for any reason or any recordings of any type, the visit will end immediately;
@) not allowed to video or audio record or take pictures; Note: the visitation and Agency staff have not and do not
consent to be recorded or have their pictures taken;
(4) not to ask questions about the placement/caregiver or caregiver’s family/childcare provider;
() not allowed to walk children to county vehicle (during in-person visits)
Best,
Mamie Wong, MSW
Protective Services Supervisor, M140
Family and Children's Services
Family Services Unit
0: 415-557-6213
C: 415-416-9155 (preferred)
Motlina addroce:
C-2 Proof plaintiff mom as a medical condition that makes it difficult
for her to travel
WALTON’S EX PARTE WRIT OF ADMINSTRATIVE MANDAMUS
From: J Move
Date: February 8, 2024 at 3:06:55 PM PST
To: Denisha Walton
Cet "Wong, Mamie (HSA)" , pweely.baybed15@gmail.com, waltona@sfusd.edu, Nevaeh Walton
, Ryan Sheets , Andrew Yee , peggy@pofmap.com, "ONEILL,
BRENDON (CAT)"
Subject: Re: Walton visits for January 2024
Giving the current situation what do me and my wife need or have to do to get our kids back what steps do we need to take
Sent from my iPhone
On Jan 28, 2024, at 11:19PM, Denisha Walton wrote:
Hi Mamie as u know | been in and out the hospital is it a way we can still get both in person visits for tomorrow please it’s been a lot going on
and we don’t ask for much please
Sent from my iPhone
On Jan 24, 2024, at 4:43PM, Wong, Mamie (HSA) wrote:
Good afternoon —
The last visit with Jaylah is scheduled for Monday, 1/29/24, from 9am to 10:30am. This is the last visit that will be
provided per the court order and will be supervised at 170 Otis. San Francisco, 94103.
The visit with the children, Deja, Justin, Ikiyrah, Auni and Romelio is scheduled for Monday, 1/29/24, from 4pm to
5:30pm, located at the Concord library: 2900 Salvio St. Concord, CA 94519. Per the court order, this will be the last
visit with Romello.
Per usual, you must confirm the visit with me, via email, the day before (Friday, 1/26/24), by noon otherwise the visits
is cancelled.
Best,
‘Mamie Wong, MSW
Protective Services Supervisor, M140
r Children’s Services
Jo Voi
EXHIBITSD
D-1 - MOM’S ATTORNEY PEGGY PROMISSING THAT SHE WILL SCHEDULE FOR
A NEW HEARING IF MOM HAS MEDICAL CERTIFICATE
WALTON’S EX PARTE WRIT OF ADMINSTRATIVE MANDAMUS
10
On Fri, Jan 19, 2024 at 6:12PM Furst & Pendergast LLP wrote:
| Fam sorry to hear about your illness. Unfortunately, the matter went forward without you or your husband. If you have a
| medical certificate, | am willing to add the matter back to the calendar. However, since you have not had any in person visits
; With either Romello since August or with Jaylah since September, | could not establish a significant bond or relationship with
\ you which would overcome the termination of parental rights.
Peggy
i
1
\ PETER A. FURST
MARGARET A, PENDERGAST
| FURST & PENDERGAST,
| 646 24th AVENUE
SAN FRANCISCO, CA 94121
Phone and FAX 415 749-3200
fop@pafmap.com
On Mon, Jan 22, 2024 at 9:25AM Furst & Pendergast LLP wrote:
i Denisho
| The department will not agree to have the kids visit you at your home. At this point, Remello and Jaylah are going to be
| adopted. Your parental rights were terminated last week. As ! explained you would get one final but that visit will not be at
i your home, The screen shots you sent are not sufficient in my opinion to show that you were unable fo log on to court for the
| hearing. If the only reason you want to add this to calendar is to ask for visits at your home, that is not a valid reason.
i {can only add the matter to calendar if ! have some valid reason fo challenge the termination of parental rights. Since you have
jot seen the children in months,there is no valid reason. You have the right to appeal the termination of parental rights.
| Attached are the forms, please sign and return to me so | can file it. There are separate forms for each child as they have
| different case numbers
|
' Peggy
I
PETER A. FURST
MARGARET A. PENDERGAST
FURST & PENDERGAST, LLP
646 24th AVENUE
| SAN FRANCISCO, CA 94121
Phone and FAX 415 749-3200
| fap@pafmap.com
i
1
D-2 - MOM PROVIDES MEDICAL CERTIFICATE AND REQUESTS A REHEARING
WALTON’S EX PARTE WRIT OF ADMINSTRATIVE MANDAMUS
10
1
On Mon, Jan 22, 2024 at 7:59AM Denisha Walton wrote:
‘ Hiean you please appeal that and put it back on the calendar please and we've been asking the kids start coming to the house for a visits
| bocouse of my health issues ond yall never responded about that
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19 Kenneth Johnson
JAN Hospital Outpatient Visit 2024 UCSF Cardiovascular Care & Prevention Center
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——__--
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D-3 - ATTORNETS FAILING TO ADVOCATE AND OTHERISE REPORT
MISCONDUCT OF THR AGENCY PROVING THEIR BREACH OF FIDUCIARY
DUTIES IN THE PROCESS
WALTON’S EX PARTE WRIT OF ADMINSTRATIVE MANDAMUS
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From:
J Move
ate: January 9, 4 at jOAM PST
Fo: "Wong, Mam (HSA)
Ce: Danisha Walton , Andrew Yee
, Ryan Sheets heels @hotmail.com>, peggy. @patmap.com,
*ONEILL, BRENOGN (CATY
Subject: Re: Justin and Aunt Walton
I'm just trying to contiem our visit for tomorow
Sent trom my iPhone
On a POE SB one mara ong 1@she igo
Good evening ~
Justin and Auni will move into a foster-to-adoptive home
this Sunday, 1/7/24.
Best,
Mamie
Mamie Wong, MSW
Pratective Services Supervisor, M140
.
0: 57-6213
116-9155 (preferred)
Case 3:23-cv-04842-MMC Document 16 Filed 01/24/24 Page 81 of 109
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CAT!
Bubjeot RE: Justin and Auni Wallon
Good evening —
This evening Justin and Auni were moved into another
placement. There are no safety concerns and they are safe
and well cared for.
Best.
Mamie
~
Mamie Wong, MSW
Protective Services Supervisor, M140
oO: 5-557-6213
C4 16-9135 (preferred)
Case 3:23-cv-04842-MMC Document16 Filed 01/24/24 Page 82 of 109
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He 4S 909-4 2.1 FI Justin & D enisha Walton eI 7eP GG ale Superior Court of California County of San Francisco SE cA M22 400-MeAHister-Street— San Francisco, CA94102_— MAR 13 2024 SUPERIOR COURT OF THE STATE OF CALIFORNIA JAMES FORONDA COUNTY OF SAN FRANCISCO Justin & Denisha Walton Case No. CPF -24-518492 Plaintiffs Judicial Review Petition Vv California Administrative Procedures Act Challenge to Agency action San Francisco County California Code of Civil Procedure Department of Children and Family (CCP) §1094.5, Services Juvenile Case No. JD22-3070-C/D/E/F/G/H. Defendants [EX PARTE] APPLICATION FOR ALTERNATIVE WRIT OF ADMINISTRATIVE MANDAMUS, [CCP §§1087, 1107] COMES NOW, Plaintiffs Justin and Denisha Walton the Plaintiffs, aggrieved parties seeking an Alternative Writ of Mandamus, to challenge the unjust administrative actions of San Francisco County Department of Children and Family Services (DCFS), the Defendants. NATURE OF THE CASE The Plaintiffs contend that the respondents, DCFS, have acted in excess of their jurisdiction and abused their discretion which violated the procedural and substantive rights guaranteed under the California Code of Civil Procedure §1094.5(b) and (c). Through a pattern and practice of denying the plaintiffs’ a right to a fair trial and pre-deprivation hearings, the plaintiffs have been prevented fro, challenging the allegations and presenting evidence. The plaintiffs will present legal and factual arguments that: e The agency, through its social worker, Mamie Wong, makes unilateral decision regarding the family without a pre-deprivation hearing or proper investigation The court is biased and always sides with the agency which has already made their decision before the parent even come to court The lawyers appointed to represent the plaintiffs have breached their fiduciary duties to the plaintiffs and instead act act on behalf of the agency by not challenging them adequately or presenting the plaintiff’s evidence. They also waive the parents rights in court when the parents have said they dont want their rights waived. WALTON’S EX PARTE WRIT OF ADMINSTRATIVE MANDAMUS ADMINISTRATIVE DECISION(S) BEING CHALLENGED i. Decision 1 - January 17, 2024 Decision to Terminate Parental Rights ii. Decision 2 - March 5, 2024 Unilateral Modification of Visitation Right pre-hearing HOW THE AGENCY VIOLATED CCP§1094.5(b) and (c) The Plaintiffs contend that the Defendants have violated the procedural and substantive rights guaranteed under the California Code of Civil Procedure §1094.5(b) and (c), through actions and decisions that have not only lacked fairness and transparency but have also been substantively unsupported by evidence and marred by abuses of discretion. DECISION 1 The agency did not provide notice of the hearing of allow the parents an opportunity to present evidence or challenge the petition. Additionally, the court appointed attorneys lied to the plaintiffs on multiple occasions. - Ryan and Peggy told plaintiff that they had not chance because they hadnt visited the children in months. (Failing to considered the mom’s health and the parent’s indigency). Moreover, the children can still have a bond with their parents which remained to be seen Ryan and Peggy both promised the parents they would file appeals but failed to do so after parents signed and submitted notices of appeal WALTON’S EX PARTE WRIT OF ADMINSTRATIVE MANDAMUS - Peggy lied and said she would reschedule the hearing if mom had a valid medical reason. After mom plaintiff sent proof, she still did not schedule the hearing. Ryan refused to answer the question of it what Mamie Wong was doing deprived the plaintiffs of their rights. Instead Peggy covered for him and told the plaintiffs they had no chance. DECISION 2 Without a preceding court order and contrary to California Family Code Sections 3022 and 3100, which mandate court oversight for any modifications to visitation arrangements. Defendant Mamie Wong, acting on behalf of the respondent agency, unilaterally suspended all visitation rights for the Waltons, citing “incidents” from the February 28, 2024, visitation but not giving details as to what these incidents were or what these incidents entailed. This action was taken without affording the Waltons any form of hearing or the ability to contest the suspension. This action also prejudiced the plaintiffs by providing Ms. Wong with time to think of a reason to put in the petition as to why their visitation rights should be ended. Mamie Wong ended the parents’ visits strategically for ulterior motives. She knows that the parents can prove that they have a beneficial relationship with their children; and that evidence of this would prevent the agency from terminating the rights to their other children at their next court hearing. By preventing the parents from visitng, she can then argue that they parents don't visit and don't have a bond, which means the agency can move forward with permanency planning. WALTON’S EX PARTE WRIT OF ADMINSTRATIVE MANDAMUS EXHIBITS B Subject: RE: Walton In-Person Visit - Wednesday, 2/28/24 Good afternoon — Ireceived both parents’ confirmation for the visit tomorrow, 2/28/24, from 3pm to 4:30pm located at the Concord library. I learned that during the last virtual visit, the parents asked the children to “pray that they will be returning home” to them. This caused unnecessary confusion and disruption in their placement. The virtual visit should have ended immediately after such comments were made. The parameters for virtual and in-person visits have not changed. Blatant disregard for the requirements will end the in-. person visit immediately and will impact future visits held virtually or in-person. The visit will be 100% supervised by the Agency. The parameters previously outlined remains: 1 not allowed to speak to the kids about their disclosures, discuss the case, tell the kids they will return home or ask them to recant their disclosures; 2. not allowed to bring any electronics of any kind’into the visit, i.e. phone, laptop, Ipad, Kindle, camera, gaming system, etc, Note: if any devices are pulled out for any reason or any recordings of any type, the visit will end immediately; 3. not allowed to video or audio record or take pictures; Note: the visitation and Agency staff have not and do not consent to be recorded or have their pictures taken; 4, not to ask questions about the placement/caregiver or caregiver’s family/childcare provider; children’s respective schools or afterschool programs; 5. not allowed to walk children to county vehicle Please arrive on time. Per usual, you will have a 15 minute grace period before the visit is cancelled. If you are not able to make it to the visit, let us know so the children are not transported unnecessarily. Best, Mamie Mamie Wong, MSW Protective Services Supervisor, M140 0: 415-557-6213 WALTON’S EX PARTE WRIT OF ADMINSTRATIVE MANDAMUS On Feb 26, 2024, at 5:24PM, Denisha Walton wrote: Hi, What number do we call to confirm? Sent from my iPhone On Feb 24, 2024, at 1:15PM, Wong, Mamie (HSA) wrote: Good afternoon — The once a month court ordered in-person visit will be on Wednesday, 2/28/24 from 3pm to 4:30pm located at: Concord Library - 2900 Salvio St, Concord, CA 94519 Per usual, you must confirm the visit by noon, the day before (2/27/24) otherwise the visit is cancelled. Best, Mamie Wong, MSW Protective Services Supervisor, M140 Family and Children’s Services Family Services Unit O: 415-557-6213 C: 415-416-9155 (preferred) Mailing address: P.O. Box 7988 San Francisco, CA 94120 swww.SFHSA.org WALTON’S EX PARTE WRIT OF ADMINSTRATIVE MANDAMUS From: Wong, Mamie (HSA) Sent: Tuesday, March 5, 2024 9:38:24 AM Move ; Denisha Walton Cc: pweety.baybe415@qmail.com ; waltonnevaeh91 @gmail.com ; rsheets@hotmail.com ; peggy @pafmap.com ; ayeelaw @outlook.com ; ONEILL, BRENDON (CAT) Subject: RE: Walton In-Person Visit - Wednesday, 2/28/24 Good morning — Ms. Walton, I received your email this morning. The Agency has suspended all in-person and virtual visits due to events that occurred at the in-person visit last Wednesday, 2/28/24. Please await the 388 hearing. Best, Mamie _ Mamie Wong, MSW Protective Services Supervisor, M140 O: 415-557-6213 C: 415-416-9155 (preferred) URGENCY FOR THE ALTERNATIVE WRIT The case at hand involves egregious violations of the plaintiffs’ fundamental rights, including the right to a fair process and to be heard, as well as the Defendants’ first amendment right to free speech, right to religion and familial association, and the right to be free from torture and government coercion. Recent alarming evidence presented by a new witness shows the Walton children are subjected to neglect and bullying in their current placement, we urgently request the court's immediate intervention. This situation is contrary to the children's best interests and, along with their expressed desire to return home, necessitates a swift reevaluation of their custody and WALTON’S EX PARTE WRIT OF ADMINSTRATIVE MANDAMUS visitation rights. Immediate judicial review is imperative to prevent further harm to the Plaintiffs and to rectify the injustices that the Defendants have perpetrated under the guise of administrative discretion. Such conduct has resulted in significant and irreversible harm to the Plaintiffs, necessitating immediate and decisive intervention by this Honorable Court. As a direct result of the Defendants' excessive use of force and unwarranted actions, the Plaintiffs are being separated from their children and the imposition of unjust conditions upon their reunification, the urgency for the Court to issue an Alternative Writ of Mandamus could not be clearer or more compelling. In light of the Defendants' actions, which have directly resulted in the unwarranted separation of the plaintiffs from their children and the imposition of unjust conditions upon their reunification, the urgency for the Court to issue an Alternative Writ of Mandamus could not be clearer or more compelling. Immediate judicial review is imperative to prevent further harm to the Plaintiffs and to rectify the injustices that the Defendants have perpetrated under the guise of administrative discretion. EXHIBITS C C-1 Proof children are being abused and neglected and its being concealed from parents by not letting them ask questions WALTON’S EX PARTE WRIT OF ADMINSTRATIVE MANDAMUS From: "Wong, Mamie (HSA)" Date: February 21, 2024 at 2:15:48PM PST To: Denisha Walton , imoved04@qi Cc: ONE, BRENDON (CAT" Subject: Justin Walton Good afternoon — Yesterday, I was notified that Justin had an accident at his afterschool program and broke his arm. The agency is awaiting the incident report from the school and medical records. My apologies for the delay in notifying everyone. Mr. and Ms. Walton, in your virtual visit today and any court ordered visits, please do not ask Justin (or his siblings) about where he attends school or the location of his afterschool program or where he received medical care. This will end the visit. Other parameters that have been set by the agency, remains the same: a) not allowed to speak to the kids about their disclosures, discuss the case, tell the kids they will retum home or ask them to recant their disclosures; Q) not allowed to bring any electronics ofany kind into the in-person visit, i.e. phone, laptop, Ipad, Kindle, camera, gaming system, etc — they must leave phone in a designated table/space at the visit center. Note: if an any devices are pulled out for any reason or any recordings of any type, the visit will end immediately; @) not allowed to video or audio record or take pictures; Note: the visitation and Agency staff have not and do not consent to be recorded or have their pictures taken; (4) not to ask questions about the placement/caregiver or caregiver’s family/childcare provider; () not allowed to walk children to county vehicle (during in-person visits) Best, Mamie Wong, MSW Protective Services Supervisor, M140 Family and Children's Services Family Services Unit 0: 415-557-6213 C: 415-416-9155 (preferred) Motlina addroce: C-2 Proof plaintiff mom as a medical condition that makes it difficult for her to travel WALTON’S EX PARTE WRIT OF ADMINSTRATIVE MANDAMUS From: J Move Date: February 8, 2024 at 3:06:55 PM PST To: Denisha Walton Cet "Wong, Mamie (HSA)" , pweely.baybed15@gmail.com, waltona@sfusd.edu, Nevaeh Walton , Ryan Sheets , Andrew Yee , peggy@pofmap.com, "ONEILL, BRENDON (CAT)" Subject: Re: Walton visits for January 2024 Giving the current situation what do me and my wife need or have to do to get our kids back what steps do we need to take Sent from my iPhone On Jan 28, 2024, at 11:19PM, Denisha Walton wrote: Hi Mamie as u know | been in and out the hospital is it a way we can still get both in person visits for tomorrow please it’s been a lot going on and we don’t ask for much please Sent from my iPhone On Jan 24, 2024, at 4:43PM, Wong, Mamie (HSA) wrote: Good afternoon — The last visit with Jaylah is scheduled for Monday, 1/29/24, from 9am to 10:30am. This is the last visit that will be provided per the court order and will be supervised at 170 Otis. San Francisco, 94103. The visit with the children, Deja, Justin, Ikiyrah, Auni and Romelio is scheduled for Monday, 1/29/24, from 4pm to 5:30pm, located at the Concord library: 2900 Salvio St. Concord, CA 94519. Per the court order, this will be the last visit with Romello. Per usual, you must confirm the visit with me, via email, the day before (Friday, 1/26/24), by noon otherwise the visits is cancelled. Best, ‘Mamie Wong, MSW Protective Services Supervisor, M140 r Children’s Services Jo Voi EXHIBITSD D-1 - MOM’S ATTORNEY PEGGY PROMISSING THAT SHE WILL SCHEDULE FOR A NEW HEARING IF MOM HAS MEDICAL CERTIFICATE WALTON’S EX PARTE WRIT OF ADMINSTRATIVE MANDAMUS 10 On Fri, Jan 19, 2024 at 6:12PM Furst & Pendergast LLP wrote: | Fam sorry to hear about your illness. Unfortunately, the matter went forward without you or your husband. If you have a | medical certificate, | am willing to add the matter back to the calendar. However, since you have not had any in person visits ; With either Romello since August or with Jaylah since September, | could not establish a significant bond or relationship with \ you which would overcome the termination of parental rights. Peggy i 1 \ PETER A. FURST MARGARET A, PENDERGAST | FURST & PENDERGAST, | 646 24th AVENUE SAN FRANCISCO, CA 94121 Phone and FAX 415 749-3200 fop@pafmap.com On Mon, Jan 22, 2024 at 9:25AM Furst & Pendergast LLP wrote: i Denisho | The department will not agree to have the kids visit you at your home. At this point, Remello and Jaylah are going to be | adopted. Your parental rights were terminated last week. As ! explained you would get one final but that visit will not be at i your home, The screen shots you sent are not sufficient in my opinion to show that you were unable fo log on to court for the | hearing. If the only reason you want to add this to calendar is to ask for visits at your home, that is not a valid reason. i {can only add the matter to calendar if ! have some valid reason fo challenge the termination of parental rights. Since you have jot seen the children in months,there is no valid reason. You have the right to appeal the termination of parental rights. | Attached are the forms, please sign and return to me so | can file it. There are separate forms for each child as they have | different case numbers | ' Peggy I PETER A. FURST MARGARET A. PENDERGAST FURST & PENDERGAST, LLP 646 24th AVENUE | SAN FRANCISCO, CA 94121 Phone and FAX 415 749-3200 | fap@pafmap.com i 1 D-2 - MOM PROVIDES MEDICAL CERTIFICATE AND REQUESTS A REHEARING WALTON’S EX PARTE WRIT OF ADMINSTRATIVE MANDAMUS 10 1 On Mon, Jan 22, 2024 at 7:59AM Denisha Walton wrote: ‘ Hiean you please appeal that and put it back on the calendar please and we've been asking the kids start coming to the house for a visits | bocouse of my health issues ond yall never responded about that TaOY A | Lol ©] fu Geto) Vesa neltemal DB) pay oy exe)iaivagtcvelecy Future & eve Ge 27 UCSF Cardiology Endocrine 2024 Join by 12:50PM Starts at 1:00 PM Ee View After Visit Summary? JAN Emergency Department 20 UCSF Emergency Department BB View notes 2024 oe ee wae ~ View After Visit summarye JAN Patient Message oa —-———— 19 Kenneth Johnson JAN Hospital Outpatient Visit 2024 UCSF Cardiovascular Care & Prevention Center i 19 Xiaobing Yu 2024 UCSF Center for Pain Medicine Mt Zion ‘iew After Visit Summary® ——__-- , ES view after visit Summary® ae oe - - JAN Emergency Department o 1 18 UCSF Emergency Department JAN : Telephone Visit 2024 19 Damond Ng | 2024 uesr General Medicine at 1701 Divisadero an D-3 - ATTORNETS FAILING TO ADVOCATE AND OTHERISE REPORT MISCONDUCT OF THR AGENCY PROVING THEIR BREACH OF FIDUCIARY DUTIES IN THE PROCESS WALTON’S EX PARTE WRIT OF ADMINSTRATIVE MANDAMUS 1 12 aby) eee) Cai ietores YASH [oXci-t- 10 (ot) nf G peered aL) oe rly es2& ee eae, onan re ny Lier ur eee} =) aUici@t: Mote (-tks (ee Biren) od CNET|") NAee oles MPa) istoMmliUcWr-] gcM acto Otctoadtale R-M-Vanllae (site a o.4 Pry aS) UB ot-1 (Wom oe)4 om 2A 0R- ele EN U-M-TA N11 -1k-1e Vel me UC -\t tle) atom Bel Ware (Ye 9 Cod tl C-INE-) a ol-1d mm COLO E) (rer oats) Fe) com UL arte] ofcie-Telt-)-Lomcl|glercMUOLUR-1¢oMClaNuY||Ia\o mom O)ke\ Ze (om tare! frelcrat iia elMmaalm SL-LeeLaM SOM LUM ele R UR MI aTiclgtalc1 ice) a Raed ESATA Lela ccXe Mell mtn oR cast are MLM Uo) Tofoyanartcale tis (OOM MOM CEENTACICM exe] RTM Ate] DCRR OLR TIT ae \Uem-Balc niece k-tgt-) i creteny oa toa Wala ya ltd Matai IB Serco RU] Stones) 1D) C7 Ce Crowes ENO: RST AN MSU NIOLS10 MO BCL SVAD Nea Eee Rat aa BilsX Sie ee FE a ct SE aCe Re aaa oo nue ae eC LE Lal CEE alte nus OR ULE cata aLg See mee om RoR ALL Cee aL il Poorer Rac’ i — ee _ i = — ns A) Ls rme Mal -\tom Xerda Rel MYA| CORI oR Un -N a6) elle (0) et WALTON’S EX PARTE WRIT OF ADMINSTRATIVE MANDAMUS 12 13 3:23 ni! > Ga 1 eam Ce)/6 NIU leelelaia Pr Xooan VM al--com eel eed mae lO (MUS oe RSI) el- 10 (0) WALTON’S EX PARTE WRIT OF ADMINSTRATIVE MANDAMUS 14 15 skal) ncn os) CO ee AV CE-Teaecre| titi dint E-R-UaL-| pe aa va TREC URL Ld i=) 2) Pelee Ter Se eae cae) a fats ee =) LUE em te (ke (ta Toran Py ia) tit mae: Nee) RS rey UM olel[c\GoM eel teMaey(UAR-la(e Male \Ucm-laiiciice Bele me PILne Bn e Bom (ce(-1B Rn -E-L ici (oleae) Liter lfe la Eve MU LaNcoe) o-ieclalecciccre Rol Nel MeL R-1C-MOLE\ TL Nem Co Koo REN Fete nhtiny orm tlw ole ER LIeR (UB (el Rea B Loliold ea} ROcLAM LOlarccre ReLel@arm na * Page 80 of 109 Exhibit D-1 Tracy Police Exhibit D-2 Tracy Police Exhibit D-3 Tracy Police Exhibit E Exhibit E-1 Exhibit E-2 Exhibit E-3 Exhibit A-1 From: J Move ate: January 9, 4 at jOAM PST Fo: "Wong, Mam (HSA) Ce: Danisha Walton , Andrew Yee , Ryan Sheets heels @hotmail.com>, peggy. @patmap.com, *ONEILL, BRENOGN (CATY Subject: Re: Justin and Aunt Walton I'm just trying to contiem our visit for tomorow Sent trom my iPhone On a POE SB one mara ong 1@she igo Good evening ~ Justin and Auni will move into a foster-to-adoptive home this Sunday, 1/7/24. Best, Mamie Mamie Wong, MSW Pratective Services Supervisor, M140 . 0: 57-6213 116-9155 (preferred) Case 3:23-cv-04842-MMC Document 16 Filed 01/24/24 Page 81 of 109 Exhibit A-2 Fromm: |We ar Sent: Fi To: Denish: Vici in eshajustin200732@gmail.com>. J Mo : Ryan SP heatgacinal com>: peggy@pafmap.com; ONE! uh, BRENDON CAT! Bubjeot RE: Justin and Auni Wallon Good evening — This evening Justin and Auni were moved into another placement. There are no safety concerns and they are safe and well cared for. Best. Mamie ~ Mamie Wong, MSW Protective Services Supervisor, M140 oO: 5-557-6213 C4 16-9135 (preferred) Case 3:23-cv-04842-MMC Document16 Filed 01/24/24 Page 82 of 109 Exhibit A-3 pent rnin: Ye LEE Er 1D. suds 20m NI To: De ishe 2 We ron : justnwallanee iclou om t OF LL, 5 NOON (CA -Brendon.ONeill@sfcityatty.org See wy ayselaw @outlook.com>: Ryan Sheets ) thea pel Cas La f ARM E emu aL SR oan eT) a tig Gre Ea eee Pens OMAR CR Lie Ses ca nS i ees Ue ce a Peu i Rd Pe esie Menara Vero rur Renee aN Can sec Ro aOR CR RI RUC ACL ae Pra Ce SE-B ieee CRLLLL i Naa Ronkene Wars err na Ricca) | Bane tear ever oleate cy NPS eee CMe Man sey Ca eR Log be eee a fo} Olea erAc} PaO Ta aT | Siri -Rielss xtc. 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Be ee USE RL Pein cn ab ea een auc eas Pete ee are CONS Le eee ht eee Cue eu Ru aay Pro ean lia en Gi Be) Saeeaeesee cee a] ieee ri Case 3:23-cv-04842-MMC Document 16 Filed 01/24/24 Page 97 of 109 Exhibit Eves \ D-3 - Department of Police re se Accountability Tracy Police & os oy 33 ane AL ire pee eee eal! Pe a et SS = kv = Sm Submission Number: 16817-918-247-543 was submitted successfully on Monday, April 17, 2023 at 12:33:08 PM EDT — Thank you for conta oe, rain tates Seven na Excnano Sone Tea some Seonjaan Contin : = oom wor sc bone rogmnen Some tie mt rasa ray sea “ato an na “neu ‘ne! on (oye Gen eo eee trons nena occ weve we ion "30% “oo rapt tatoo a ora tot Mn ewer nett reton ‘Gane es tn sins et socero vis soem "Seren ne ‘one hssnrtayne oe Minponse Rupraroane iat wicomplinntdinte epecarsriand ‘mor What is your complaint about? Sm ave wntect tie option that bout dlewarih your conn owner - to tite supntementat infer ton ton vious cornptnint? be In your own words, describe the conduct or situation you are complaining about. eanmue @ Bene jon ana ot nase vite “ao eneoe ste of tamu ofwong9 svn atin ttt Sony aretaneerst myon forbe wang wo ko on we Yoram wr aad os Bonet tou untatty by social weeee vent wate tea sing tnnny'ee ase wrewang thusie iin woe paver md tone ete pene ane tes nary qui roudt we ase round, Wes i ntaching We toe mores Intormnistonn ara cette hc tes analy ban pan De fet to sal OF 1M Are you having or have you had difficulty getting access to your funds or securities? Unknown bid you wutter a tone? No - itor is you become auearn oF the conUwer? (mmsiyyyy) 2 “ (einen did the conduct buaiN? (My yyy - te ne conriuet ongoing? vue Mas ne dividual or firen aeknowiougad the conser? Yeu How did you learn about the conduct? You may select more than one answer. Soci modia (e.c Facebook, Twitter, ble: shat roams, and electronica comamuniti s of intere: Have you taken any action regarding your compiaint? You may select more than one ¥ answer. Comptained to firm: © raplained te out oe F6 tor Comptia to SEG; Complainad to law enforcement: Complained to other: Legat a nt efi ion: A ation: Other Provide details. fen Jf novce 0canes te ot not wi ont swrangiaaing oF ant cn review onfcnr Nanaia fortyWs aot onot niees owes sata Gib netsh on inacere thee Gun: (igi oF Pohees 5 fas i eh i. 5 an a aoe Case 3:23-cv-04842-MMC Document16 Filed 01/24/24 Page 98 of 109 Exhibit D-4 Pesca 8 Oe Peetu ga Wer) os (oyelofey. 7.2.8 ae = er) mL CALs BUCS ed TRC Ure ner ead ERD Mer Retiticc cet ey sles ber Tae la BSc ee Ra nea Peele OnE. 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