Law Suit against the Community Resource Officer of the Code Enforcement of Marion County, Oregon

Part I of III

Part II of III

Part III of III

Part IV of IV

 

 

 

 

Docket text:

Order. I have reviewed the amended complaint in this case.  Construing the amended complaint liberally and affording plaintiff the benefit of the doubt, Hebbe v. Pilar,627 F.3d 338,342 (9th Cir. 2010), the complaint now appears to state a claim for relief.  Specifically, the Court understands plaintiff to challenge Marion County's "ninety day rule" for Conditional Use Hardship Permits as having a disparate impact against individuals with disabilities whose serious medical needs may require them to be away from home for longer than ninety days at a time.  Plaintiff also alleges disparate treatment and disparate impact in connection with the Marion County Code Enforcement officer's statement to plaintiff's father that he would be liable to pay fines if he did not evict plaintiff's caregivers.  Plaintiff is advised that this Court has a pro bono attorney program.  Although there is no guarantee any attorney will agree to represent plaintiff, if plaintiff files a request for appointment of pro bono counsel, the Court will submit a request to the attorney pool to see if any lawyer is willing to take on representation.  Ordered on 1/12/2017 by Judge Ann L. Aiken.  Notice of this order was mailed to plaintiff, Bruce Wayne Henion. (rdr)

 

lib•er•al•ly

[ˈlib(ə)rəlē]

ADVERB

 

in large or generous amounts: "she quotes liberally from the Bible" •

 

"steaks liberally sprinkled with salt and pepper" •

 

"large firms contributed liberally to the relief fund" in a way that is not precise or strictly literal; loosely: "the law is interpreted liberally" •

 

"the obligations of treaties should be liberally construed" in a way that involves broadening a person's general knowledge and experience: "liberally educated students"

 

in a way that favors individual liberty and moderate political and social reform:

"I used to think more liberally"

 

-----------------------------------

 

I Submitted the request. It will be posted on my web site. My father sent the original letter from the Judge to me in the mail, and my step mother of 20 or more years who I love so much typed the Judges letter above for me as she doesn't have a scanner.

 

I added the definitions to try and understand why she didn't render a decision.

 

I'm guessing, if a attorney does take my case, it will be because the 90 day rural is discriminative against say a spinal cord injured veteran in the SCI Unit for 8 months, healing from a buttocks wound, his wife throw to the curve after 90 days of the absence of the QUAD Tennant, an example as a matter of argument.

 

I don't understand how the 90 day rule applies to a years hardship clause for mobile homes on exclusive farm land as in my case and others, yet others are subject to the 90 day rule outside farm land.

 

I can see where the Judge would have to reside over my case in open court, so both sides can bring forth their witness and testify.

 

Depositions as requested by both attorneys', etc. most likely will be necessary.

 

It's clear that self representation on a federal level requires an attorney and when supporting evidences is based on two different parties testimonies, under oath in a court room, with a Jury Trial, calling fourth witnesses to testify is the only way I'm thinking to resolve this case.

 

As I'm reading the Judges letter, she left the door open, provided I can locate an attorney, who is willing to conclude, that any such 90 day rule of care giver eviction, while a person is under going medical treatment in a Veteran Hospital, should be allowed to have their care giver stay in the residence until the return of the tenant QUAD from the Hospital.

 

In addition, there is the elimination of the process of law for me do to the fashion in which any such law was enforced and the failure to treat me on a one on one bases, rather then eliminating me from the process, denying me my civil rights and rights under the Disabilities Act.

 

In addition, no letter was ever sent to me, the Tennant, citing any such ghost law I was in violation of, but merely in proper law enforcement techniques, kind of like a Code Red no longer allowed in the Marines.

 

Marion County Enforcement of Oregon never got the memo, that you can't legally threaten legal action in an effort to force someone to do something, in order not to commence an investigation into whether the two in my residence were care givers, which falls back to the Code Enforcement Officers conduct of law enforcement, as either being appropriate behavior or not, for a county law enforcement officer, in what appears to be a county departmental supportive method of law enforcement, to include the execution of two separate Marion County Laws, that clearly are for to separate land usage areas of Marion County, i.e. exclusive farm land and everything else.

 

Yet a year under a doctors physicians certificate and history since 1990, should exclaim to anyone the tenants disability is on going.

 

And care givers fall under the jurisdiction of the doctors physicians certificate good for a year, over riding any such ghost law other then an over lapping law that is cited as being for all other areas then exclusive farm land where a mobile home is placed.

 

 

 

Applying for Pro Bono Representation

 

Details

 

If you are unable to pay for an attorney but would like legal representation in a pending, active civil suit in District Court, you may submit a Motion for Appointment of Pro Bono Counsel. The decision to appoint pro bono counsel lies with the judge presiding over your case. Judicial officers may order the appointment of counsel for all purposes or for other specific purposes, such as assistance in mediation or settlement conferences.

 

Appointment for a Specific Purpose

 

The Specific Purpose Appointment is used when a Judge appoints an attorney or law firm for the completion of a specific task. Common uses for this type of appointment include:

 

drafting an amended complaint;

preparing for and/or appearing at a mediation, settlement conference, or deposition; and

responding to a motion to dismiss or a motion for summary judgment.

 

You can expect an attorney to contact you if one is appointed to you. However, bear in mind that you have not been assigned an attorney for the entirety of your case. Within 14 days of the Order Appointing Pro Bono Counsel, the Court expects attorneys appointed for a Specific Purpose to:

 

determine if a conflict of interest exists or request removal from the case for a specific reason other than a conflict of interest; and

electronically file the Pro Bono Appointment Response Form accepting or declining the appointment.

 

After completion of the task(s) specified in the Order Appointing Pro Bono Counsel, the attorney/law firm appointed for a Specific Purpose Appointment will electronically file the Notice of Completion of Pro Bono Appointment. You will be expected to proceed pro se from that point forward.

 

Appointment for All Purposes

 

An Appointment for All Purposes is intended to provide you with legal counsel for the duration of the lawsuit. You can expect to hear from an attorney after one has been appointed to you. However, bear in mind that this person is not necessarily going to accept the appointment. Conflicts of interest, scheduling issues, or other factors may prevent the attorney from accepting this case. Within 14 days of the Order Appointing Pro Bono Counsel, the Court expects an attorney/law firm appointed for an All Purpose Appointment to:

 

determine if a conflict of interest exists or request removal from the case for a specific reason other than a conflict of interest; and

 

electronically file the Pro Bono Appointment Response Form accepting or declining the appointment.

 

Motion for Appointment of Pro Bono Counsel

 

https://www.ord.uscourts.gov/index.php/2015-02-10-16-10-22/applying-for-pro-bono

 

Melissa Dorothy Wischerath

Attorney at Law

 

Law Office of M. D. Wischerath 

OR: P.O. Box 12263 Eugene, Oregon 97440

NY: 333 Woodbridge Ave, Buffalo, NY 14214

Phone: (541) 600-4319 | 646) 765-0035

Website: www.mdwlaw.net

Skype: Melissa.Wischerath

 

From: info@ord.uscourts.gov <info@ord.uscourts.gov>

Sent: Friday, March 10, 2017 11:07 AM

To: nobody@ord.uscourts.gov

Subject: Activity in Case 6:16-cv-01918-AA Henion v. Marion County Code Enforement et al Pro Bono Appointment Response Form

 

This is an automatic e-mail message generated by the CM/ECF system. Please DO NOT RESPOND to this e-mail because the mail box is unattended.

 

 ***NOTE TO PUBLIC ACCESS USERS*** Judicial Conference of the United States policy permits attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees apply to all other users. To avoid later charges, download a copy of each document during this first viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply.

 

U.S. District Court

 

District of Oregon

Notice of Electronic Filing

 

The following transaction was entered by Wischerath, Melissa on 3/10/2017 at 11:07 AM PST and filed on 3/10/2017

 

Case Name:  Henion v. Marion County Code Enforement et al

Case Number: 6:16-cv-01918-AA

Filer: Bruce Wayne Henion

Document Number: 16 

 

Docket Text:

 

Pro Bono Appointment Response. Representation is accepted as specified in the Order Appointing Pro Bono Counsel. Filed by Bruce Wayne Henion. (Related document(s): Order on Motion for Appointment of Counsel[11], Order Appointing Pro Bono Counsel, [12].) (Wischerath, Melissa)

 

6:16-cv-01918-AA Notice has been electronically mailed to:

 

 Melissa D. Wischerath     melissa@mdwlaw.net, mwischerath@gmail.com

 

6:16-cv-01918-AA Notice will not be electronically mailed to:

 

The following document(s) are associated with this transaction:

Document description:Main Document

Original filename:Not Available

Electronic document Stamp:

 [STAMP ordStamp_ID=875559790 [Date=3/10/2017] [FileNumber=5780021-0] [

 0bcd3a6d1d720aefc3b3ab49dd0529d194f283322cdba45805229ea1d9d86078f36695

 4aaa754b000b97a5ee87d6f623dfdffbe9c8c4cf9f20d7ef0773374f75]]

 

I'm very happy, I now have a chance to make a difference.

 

Home was bought and paid for by me, placed in 1990 or 92, rebuilt after a fire min 2002 and in 2014, remodeled by my work comp ins. co. and has never had an elapse in the renewal.

 

My father believes the Code Enforcement Officer violated his civil rights as well, in regards to un lawful entrance into the farm with out notification or permission to take pictures.

 

Frankly, a rather difficult one to enforce, yet my father exclaims the fine is $10,000.00 for a state agency to break the entering private property no trespassing signs without notice when not serving a warrant or in pursuit of a felon.

 

This Code Enforcement Officer from the time she entered the farm in November 2015, to include my house with out notification or permission to be in my face, lying in my bed, showing up in force, that is, with several sheriff deputies at my door, scarring one of three care givers in the house and on the property at the time, to open the door, is a practice of the way business is conducted.

 

I'm after a 90 day rule that has no jurisdiction over an annual renewal of a hardship clause on a mobile home, verses camp trailer or RV parked next to another's house in all areas other then Exclusive Farm Land Usage;

 

90 day law is discriminative in any area of Marion County where a doctor is involved;

 

The county has no authority over care givers whether the tenant is home or not, provided no violation of the annual renewal took place and had there been a violation, it was the obligation of the county to investigate, that would involve a scheduled visit to my house in my absence, hearing, etc.;

 

But the grand offense was the way in which she chose to enforce what she believed the law required, chiefly, threats and avoiding inter action with me, the disabled person the hardship clause was for.

 

It should be noted however, that when folks are dis located, or loose a place to live as a result of county actions, the ripple affect of those harmed multiplies. http://rleeermey.org/viewtopic.php?t=30014&postdays=0&postorder=asc&start=0

 

Dear Governor Kate Brown

Last year I ASKED you for help. You refused to respond to me. Had you responded we could have worked together to solve issues I raised. Now, it’s up to federal court. I allege much, but the entire state of Oregon is guilty of discrimination until a law is changed, and the way my father and I have been treated by Marion County is appalling. To have served my country in the navy, medically discharged, service connected, receiving 100 percent care at the SCI Unit, Veterans Hospital and being severally disabled to boot, forced out of my home and farm that is paid for, and now my father and stepmother as well, with threats of $2,500.00 a day fines and for what, three trailers that have been on the farm twenty years, a couple of classic transams’ that have no current tags, one a parts car and a Ag building built in 1995 or 1998, as small as a large bedroom used as a drying room for hazel nuts, and your agency is going to take our farm and kick us to curb.

I've got a news flash for you Governor, your going to get national and before I'm done, international review of your states discrimination toward the severely disabled. Your Sheriff thinks he can deny me my civil rights and your state itself practices discrimination against severely disabled, so in my perspective you’re all a bunch of discriminative folks until you change a law that discriminates against severely disabled persons, and to you and your state counties, know this, before I'm done, those severely disabled whom you have discriminated against will finally have a voice.

 

You could have intervened but you chose not to.

 

Fortunately for you and Marion County and all counties in Oregon, only a few citizens of Oregon read your facebook comments and the news doesn’t care about how severely disabled are treated in Oregon. Disabled Veterans are treated like crap and if your severely disabled don’t live in Marion County because this county will take federal money to provide accommodations they deliberately refuse to provide severely disabled and disabled veterans.

 

When you’re agencies code enforcement officer came after my 79 year old father, threatening eviction and confiscation of my grandfather and grandmothers farm now passed away, who through a Trust provided for my father and I place to live, myself over the years investing 100,000.00 dollars or more in my home on the farm owned by the Trust now, sickens me to no end after hearing of the threats to my sister and father.

 

Discriminating against me is one thing, as I have laws that protect me, but throwing me to the curb, well that’s another thing, but now my father and step mother as well.

 

It won’t stand.

 

I’m an old salt, but I haven’t begun to fight yet. Before I’m done, the Sheriff will either be impeached by the people or forced to resign and that Code Enforcement Officer, she will be labeled what she is.

 

We Americans claim were compassionate when in reality severely disabled persons are cast to the side, discriminated against and their lives are put in harms way do to a discriminative law and Marion County in particular for excluding me from procedural law, deliberately not making accommodations which the State of Oregon requires, as does the Federal Government and threats, forcing my father to evict my care givers while I’m in the VA Hospital out of my house so I couldn’t return and still can’t because the farm is desired by the state of Oregon.

 

I’m now facing a fourth operation in order to urinate, the third urological operation to help me pee. I was seen at the SCI Unit, VA Hospital, La Jolla, Ca. today.

 

Well Governor, before you take our farm, you’re in for a fight you will loose because no one has the right to discriminate against severely disabled persons, and if the Federal Government can’t force you to stop threatening my father and sister, me, myself and I, and if you can discriminate against me in the fashion and method you’re state agency is enforcing codes and or failure to provide accommodations to me, a severely disabled person and a disabled veteran, then folks, those of you who are severely disabled, in the State of Oregon, you have no civil rights.

 

One thing for sure, if the federal can’t force your state into compliance, or Marion County, why should you’re state counties receive further federal funding if you refuse to change your actions of code enforcement

 

The way I see it, if you don’t want to abide by the law, then that in it’s self is a criminal act, so you’re all a bunch of crooks and discrimination your agency proudly and deliberately expresses through policies, methods, speech and mannerism toward and against severely disabled and elderly, is going to reach up and bite you all where it counts, you’re political careers.

 

I will not be raped of my civil rights under federal law and you’re agency will suffer the outcome of a jury trial in the U. S. District Court, Eugene, Oregon.

 

Since you can delete this comment, it will be posted on the world wide net.

 

Before I’m done, folks are going to know about my case from New York to Iran or Salem, Oregon to Russia, Israel to Iraq and beyond.

 

Maybe the American People will here of my case from another country as U. S. Media outlets could care less.

 

That attitude helps no one nor does doing nothing.

 

I’m tried, and now my biggest fight of my life ahead of me, 35 years a disabled veteran and 32 years a QUAD or the Veterans Administration Diagnosis of Tetraplegia, also known as quadriplegia C5/C6 Status suggests I’m on my way out, but even though I’m FUBAR, I’m going to fight you to my last breath.

 

I have forwarded the following complaint to the following House of Representatives of the State of Oregon.

 

Hi

 

Eventually you will find it necessary to sound off about an Oregon law that discriminates against severally disabled folks like me.

 

I'm asking you to consider carefully my allegations and the harm one law does to severally disabled folks in Oregon.

 

I was hoping to avoid this action last year but in face of now being homeless, even though my home and family farm is paid for, forced out by Marion County by not allowing care givers in my home to await my arrival from a VA Hospital I'm suing for in federal court and to over throw  an Oregon law that discriminates against severally disabled folks.

 

I'm reporting, you decide

 

Bruce Wayne Henion

http://www.uscarrierhistory.com

 

Wed 07/06/2017 07:38

To: Rep.TeresaAlonsoLeon@oregonlegislature.gov; Rep.JeffBarker@oregonlegislature.gov; Rep.PhilBarnhart@oregonlegislature.gov; Rep.GregBarreto@oregonlegislature.gov; Rep.CliffBentz@oregonlegislature; Rep.DeborahBoone@oregonlegislature.gov; Rep.KnuteBuehler@oregonlegislature.gov; Rep.JanelleBynum@oregonlegislature.gov; Rep.BrianClem@oregonlegislature.gov; Rep.MargaretDoherty@oregonlegislature.gov; Rep.SalEsquivel@oregonlegislature.gov; Rep.PaulEvans@oregonlegislature.gov;  Rep.JulieFahey@oregonlegislature.gov; Rep.DavidGomberg@oregonlegislature.gov; Rep.ChrisGorsek@oregonlegislature.gov; Rep.MitchGreenlick@oregonlegislature.gov; Rep.JodiHack@oregonlegislature.gov; Rep.CedricHayden@oregonlegislature.gov; Rep.DallasHeard@oregonlegislature.gov; Rep.KenHelm@oregonlegislature.gov; Rep.DiegoHernandez@oregonlegislature.gov; Rep.PaulHolvey@oregonlegislature.gov; Rep.JohnHuffman@oregonlegislature.gov; Rep.MarkJohnson@oregonlegislature.gov; Rep.BillKennemer@oregonlegislature.gov; Rep.AlissaKenyGuyer@oregonlegislature.gov; Rep.TinaKotek@oregonlegislature.gov; Rep.RickLewis@oregonlegislature.gov; Rep.AnnLininger@oregonlegislature.gov; Rep.CedricHayden@oregonlegislature.gov; Rep.DallasHeard@oregonlegislature.gov; Rep.KenHelm@oregonlegislature.gov; Rep.DiegoHernandez@oregonlegislature.gov; Rep.PaulHolvey@oregonlegislature.gov; Rep.JohnHuffman@oregonlegislature.gov; Rep.MarkJohnson@oregonlegislature.gov; Rep.BillKennemer@oregonlegislature.gov; Rep.AlissaKenyGuyer@oregonlegislature.gov; Rep.TinaKotek@oregonlegislature.gov; Rep.RickLewis@oregonlegislature.gov; Rep.AnnLininger@oregonlegislature.gov; Rep.JohnLively@oregonlegislature.gov; Rep.SheriMalstrom@oregonlegislature.gov; Rep.PamMarsh@oregonlegislature.gov; Rep.CaddyMcKeown@oregonlegislature.gov; Rep.SusanMclain@oregonlegislature.gov; Rep.MikeMcLane@oregonlegislature.gov; Rep.MarkMeek@oregonlegislature.gov; Rep.NancyNathanson@oregonlegislature.gov; Rep.MikeNearman@oregonlegislature.gov; Rep.RonNoble@oregonlegislature.gov; Rep.RobNosse@oregonlegislature.gov; Rep.AndyOlson@oregonlegislature.gov; Rep.JulieParrish@oregonlegislature.gov;

Rep.CarlaPiluso@oregonlegislature.gov; Rep.BillPost@oregonlegislature.gov; Rep.KarinPower@oregonlegislature.gov;

Rep.DanRayfield@oregonlegislature.gov; Rep.JeffReardon@oregonlegislature.gov; Rep.EWernerReschke@oregonlegislature.gov; Sanchez@oregonlegislature.gov; Rep.GregSmith@oregonlegislature.gov; Rep.BarbaraSmithWarner@oregonlegislature.gov; Rep.DavidBrockSmith@oregonlegislature.gov; Rep.JaneenSollman@oregonlegislature.gov; Rep.SherrieSprenger@oregonlegislature.gov; Rep.DuaneStark@oregonlegislature.gov; Rep.RichVial@oregonlegislature.gov; Rep.GeneWhisnant@oregonlegislature.gov; Rep.JenniferWilliamson@oregonlegislature.gov; Rep.GeneWhisnant@oregonlegislature.gov; Rep.JenniferWilliamson@oregonlegislature.gov; Rep.CarlWilson@oregonlegislature.gov; Rep.BradWitt@oregonlegislature.gov; melissa@mdwlaw.net;

btybp7@gmail.com; dreamcatcher3998@yahoo.com; .rollercoaster_song_girl@yahoo.com

 

Law Suit against the Community Resource Officer of the Code Enforcement of Marion County, Oregon - Baman47 Health 2016

http://rleeermey.org/viewtopic.php?t=30014

 

From: WSP Server <DBSServer@dbsinfo.net> on behalf of Preferred Process Servers <Service@SalemProcessServer.com>
Sent: Thursday, June 1, 2017 3:59:03 PM
To: Melissa Wischerath
Subject: PAT Status on (MARION COUNTY CODE ENFORCEMENT)

To: Melissa D. Wischerath
Attorney at Law

This is an automated message relating to:
Our Job Number: 2017001897
Your Reference Number:
Party to be Served: MARION COUNTY CODE ENFORCEMENT
Case Info: Oregon 6:16-CV-01918-AA
BRUCE WAYNE HENION vs.
MARION COUNTY CODE ENFORCEMENT, et al.

Recipient was SERVED on Jun 1 2017 3:00PM
Type of Service: PUBLIC BODY

Documents: Summons in a Civil Action, Case Assignment Order, Complaint

Original Service Address: MARION COUNTY CODE ENFORCEMENT, MARION COUNTY SHERIFF'S OFFICE, 100 HIGH STREET NE, SALEM, OR 97301

Service Details: served a PUBLIC BODY by delivering a true copy of the Summons in a Civil Action, Case Assignment Order, Complaint to SGT. JASON WICKAM as COMMUNITY SERVICES SUPERVISOR at the above address.

Attachments:
Link to Affidavit Link to Invoice


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SECOND AMENDED COMPLAINT.

Page 1 of 15

 

Melissa D. Wischerath

OSB # 130194

Law Office of M.D. Wischerath

P.O. Box 12263

Eugene, OR 97440

(541) 600-4319 | (646) 765-0035 |

melissa@mdwlaw.net

Attorney for Plaintiff

 

UNITED STATES DISTRICT COURT

DISTRICT OF OREGON

EUGENE DIVISION

 

BRUCE WAYNE HENION,

 

Plaintiff,

 

v.

 

Case No.: 6:16-cv-01918-AA

 

MARION COUNTY CODE ENFORCMENT,

MARION COUNTY SHERIFF’S OFFICE,

and LAURA PEKAREK, in her official

capacity as Code Enforcement Officer of the

Marion County Sheriff’s Office.

 

Defendants.

 

COMPLAINT

 

Americans with Disabilities Act

42 U.S.C. § 12101 et seq.

 

Section 504 of the Rehabilitation Act of 1973

29 U.S.C. § 794 et seq.

 

ORS §§ 659A.142 (5)(a), 659A.145 (g)

 

JURY TRIAL REQUESTED

 

Case 6:16-cv-01918-AA Document 18 Filed 05/31/17 Page 1 of 16

SECOND AMENDED COMPLAINT.

Page 2 of 15

 

INTRODUCTION

 

This action is brought against Defendant Marion County Sheriff’s Office (MCSO), Marion County Code Enforcement (MCCE) and its code enforcement officer, Laura Pekarek, in her official capacity as Code Enforcement Officer of MCCE, to remedy a pattern and practice of discrimination against individuals with Conditional Use Hardship Permits, particularly those with 1) long term medical care needs that require extended stays away from their residence for longer than three

 

(3) months, and 2) significant physical disabilities that require a team of round the clock, dedicated in-home care attendants to reside with individuals with Conditional Use Hardship Permits. MSCO and MCCE discriminated against persons by reason of his disability by failing to take simple, no-cost, reasonable measures to accommodate persons who rely on Conditional Use Hardship Permits to access housing.

 

The State’s Exclusive Farm Use Zones (EFU) codified at ORS § 215.283 (1) (i), provides that “[w]ithin three months of the end of the hardship, the manufactured dwelling or recreational vehicle shall be removed or demolished or, in the case of an existing building, the building shall be removed, demolished or returned to an allowed nonresidential use.” "Hardship" means a medical hardship or hardship for the care of an aged or infirm person or persons. OAR 660-033-0130.

 

It is clear from the statute and implementing regulations that a conditional use hardship permit terminates within three months of the end of the medical hardship.

 

Nevertheless, it has been MCCE’s and MCSO’s unlawful pattern, policy and/or practice to require the family members of individuals with Conditional Use Hardship Permits to evict in home care attendants during an extended hospitalization and/or

 

Case 6:16-cv-01918-AA Document 18 Filed 05/31/17 Page 2 of 16

 

SECOND AMENDED COMPLAINT.

Page 3 of 15

 

medical stay of more than three (3) months, and to threaten termination of a Conditional Use Hardship Permits based on the individual’s absence from the residence during an extended hospitalization and/or medical stay of more than three

 

(3) months.

 

JURISDICTION AND VENUE

 

1. This is an action for declaratory and injunctive relief, brought pursuant to the Americans with Disabilities Act (‘the ADA”), 42 USC § 12101 to 12213, specifically Title II of the ADA and Section 504 of The Rehabilitation Act of 1973, 29 USC § 794 et. seq.

 

2. This court has jurisdiction over this action under 28 USC §1331 and 1343 for claims arising under the ADA and Section 504 of the

Rehabilitation Act.

 

3. This court has jurisdiction to issue a declaratory judgment pursuant to 28 USC §§2201 and 2202.

 

4. Defendants have a place of business in this District and transact business in this District, and a substantial portion of the acts giving rise to this action occurred in this District. Venue is proper in this District pursuant to 28 U.S.C. § 1391(b).

 

5. As a substantial portion of the acts or omissions giving rise to this action occurred in Marion County, divisional venue is proper in this Division pursuant to LR 3-2.

 

Case 6:16-cv-01918-AA Document 18 Filed 05/31/17 Page 3 of 16

SECOND AMENDED COMPLAINT.

Page 4 of 15

 

PARTIES

 

Defendant Marion County Sheriff’s Office

 

6. The Marion County Sheriff’s Office (“MCSO”) is a Marion County local government body whose responsibility is to provide administrative support to the Marion County Code Enforcement Division. MCSE is a public entity under Title II of the ADA as defined in 28 USC § 12131(I) and 28 CFR §35.104. MCSE is a recipient of federal financial assistance under 29 USC §794. MCSE uses said federal financial assistance in its program activities, including national priority safety programs.

 

Defendant Marion County Code Enforcement Division

 

7. The Marion County Code Enforcement Division (“MCCE”) is an Operations Division of the Marion County Sheriff’s Office, whose responsibility is to respond to complaints of possible violation of various ordinances for unincorporated areas of the County.

 

Defendant Laura Pekarek

 

8. Laura Pekarek is the Code Enforcement Officer for Marion County Sheriff’s Office. Ms. Pekarek is sued in her official capacity, is responsible for administering code enforcement in Marion County, and for the violations alleged herein.

 

Plaintiff Bruce Wayne Henion

 

9. Plaintiff is a 58-year-old veteran. On February 5, 1985, Plaintiff was

severely disabled with tetraplegia—partial or total loss of use of all four limbs and

 

Case 6:16-cv-01918-AA Document 18 Filed 05/31/17 Page 4 of 16

 

SECOND AMENDED COMPLAINT.

Page 5 of 15

 

torso—also known as quadriplegia C5 Status. Due to the extent of his disability and his loss/impairment in controlling his bowel and bladder, he relies extensively and exclusively on a team of 24/7 home care attendants to undertake even the most basic tasks. Plaintiff is unable to get out of bed in the morning without undergoing an approximately four (4) hour morning medical bowel program that is coordinated by his home care attendants. He relies on his home care attendants for everything and anything, from getting in and out of bed, accessing food, water, and bathing, and navigating every step of life.

 

10. Due to the severity of Plaintiff’s medical needs, he requires round-theclock care from a team of several qualified in-home care providers.

 

11. Plaintiff requires at least two (2), and preferable three (3) to four (4) in-home care attendants for three (3) daily 8-hour shifts, and a fourth back-up in the event that one care attendant is sick, is unavailable, or quits.

 

12. Plaintiff requires skilled in home care attendants who are trained to meet his medical needs, and are willing to work and live with him to meet his financial needs.

 

13. Plaintiff is unable to stand up unless he is at a standing table with a Hoyer lift, which requires significant assistance from his in home care attendants. He has not walked by himself for thirty-five (35) years.

 

14. Plaintiff’s father, David Henion, is 79-years-old. Though he lives on the Property, given his age, and his own personal health needs, he is unable to provide the support and assistance that his son, Plaintiff, requires to live in his home.

 

Case 6:16-cv-01918-AA Document 18 Filed 05/31/17 Page 5 of 16

 

SECOND AMENDED COMPLAINT.

Page 6 of 15

 

15. Plaintiff’s stepmother, Betty Henion, is 79-years-old. Though she lives on the Property, given her age, and her own personal health needs, she is unable to provide the support and assistance that Plaintiff requires to live in his home.

 

16. Plaintiff’s manufactured home is custom retrofitted so as to support his disability and medical needs.

 

FACTUAL ALLEGATIONS

 

17. The Lester & Alice Henion Trust is the fee simple owner of the 18- acre agricultural property (“The Property”) located at 3339 Jefferson-Scio Drive SE, Jefferson, OR 97352 on which Mr. Henion’s manufactured home is located.

 

18. Plaintiff’s father, David Henion, and his wife, Betty Henion, reside in the permanent house on the property.

 

19. The Property’s code is A93A, “agriculture, general diversified, class 3, with 1 house.”

 

20. The Property’s class is 551, “specially assessed farm land, improved, and zoned Exclusive Farm Use (EFU).

 

21. In 1990, Plaintiff brought his manufactured home onto the Property by obtaining a Conditional Use Hardship Permit, which has been renewed on an annual basis, because of his qualifying permanent medical hardship.

 

22. Currently, Plaintiff has a valid Conditional Use Hardship Permit for his manufactured home located on the Property.

 

23. In addition to Plaintiff’s manufactured home, there are approximately

 

Case 6:16-cv-01918-AA Document 18 Filed 05/31/17 Page 6 of 16

SECOND AMENDED COMPLAINT.

Page 7 of 15

 

ten (10) improvements on the Property, which include, one (1) permanent house (built in 1940), one (1) farm related general purpose agricultural building (built in 1998) used for hazelnut and canning purposes, and two (2) trailers that have been used for farm purposes for over 20 years.

 

24. Currently, one trailer is used as a chicken coop, and the other is used for farm related storage of tools and equipment.

 

25. On or around November 5, 2015, Ms. Pekarek arrived on the Property for a code enforcement inspection related to alleged solid waste violations. At the time of the inspection, Plaintiff was in bed, ill, incoherent and naked, however, attempted to engage in a discussion with Ms. Pekarek to resolve the alleged violations. At the time of the inspection, no written citations were issued; however, Ms. Pekarek gave verbal instructions to Plaintiff to clean up various waste on the Property. Shortly thereafter, Plaintiff hired additional people to perform the clean up as instructed to the best of his ability.

 

26. At the time of the November 5, 2015 inspection, David and Betty Henion were on an extended five (5) month vacation in Texas.

 

27. In November of 2015, Plaintiff resided in his manufactured home located on the Property with three (3) in-home care attendants.

 

28. The in home care attendants shared the 24/7 shifts required to care for Plaintiff. One in-home care attendant served as the main supervisor and Plaintiff’s primary caregiver.

 

Case 6:16-cv-01918-AA Document 18 Filed 05/31/17 Page 7 of 16

SECOND AMENDED COMPLAINT.

Page 8 of 15

 

29. In addition to the three (3) in-home care attendants who resided with Plaintiff, Plaintiff’s guest was visiting and staying in a 5th wheel trailer on the Property. Shortly after the November 2015 code enforcement inspection, acting on instructions from Ms. Pekarek, Plaintiff asked his guest to leave, and the guest took his 5th wheel trailer with him.

 

30. In December of 2016, after several emergency room visits, Plaintiff’s primary home attendant took Plaintiff to the emergency room at the Veteran’s Hospital in La Jolla, CA. He was to be seen for his annual appointment at the Spinal Cord Injury Unity in January, however, his sickness required an emergency visit.

 

31. When Plaintiff departed for the emergency room, he left two (2) inhome attendants at his house to await his return.

 

32. In December of 2016, Plaintiff spent two (2) weeks in the emergency room, and was scheduled for an operation in April of 2016 to address the underlying medical problems that precipitated the emergency visit.

 

33. During the two-week emergency medical stay, Plaintiff received a Foley catheter as a temporary medical service, and was scheduled for an operation in April of 2016 to address the underlying medical problems that precipitated the emergency visit.

 

34. Approximately, one year later on March 2, 2016 Ms. Pekarek sent a letter addressed to David Henion that set forth the alleged violations she saw on February 11, 2016, when she inspected the the Property.

 

Case 6:16-cv-01918-AA Document 18 Filed 05/31/17 Page 8 of 16

SECOND AMENDED COMPLAINT.

Page 9 of 15

 

35. In April of 2016, Plaintiff returned to the Veteran’s Hospital in La Jolla, CA for his scheduled operation. He spent nearly a month in the SCI unit, and was released in May.

 

36. In May of 2016, Plaintiff thought his father, David Henion, was going to take him home to Oregon to recover from his surgery with the assistance of his inhome care attendants. However, when Plaintiff’s father arrived at the SCI unit Plaintiff was informed that his father had evicted Plaintiff’s in-home care attendants, because Ms. Pekarek, in her capacity on behalf of MCCE and MCSO, verbally stated to David Henion, “that if the caregivers did not leave we would lose the Conditional Use Hardship Clause” and Plaintiff would be without a home when he returned.

 

37. On July 15, 2016 Plaintiff sent a tort notice to Marion County Legal Counsel, and the Marion County Board of Commissioners notifying Defendants of his intent to file a lawsuit against Defendants related to violations of his civil liberties under Federal and State disability laws.

 

38. Plaintiff was scheduled for and underwent a third operation in August of 2016 at the Veteran’s Hospital in La Jolla, CA.

 

39. Plaintiff has no control over the Veteran’s Association scheduling of operations, nor the length of time his recovery will take in between operations.

 

40. To date, Plaintiff has been unable to return to his manufactured home in Oregon due to the ongoing actions, letters, threats and intimidation by Ms. Pekarek, in her capacity on behalf of MCCE and MCSO. He currently resides in Mexico with his primary caregiver.

 

Case 6:16-cv-01918-AA Document 18 Filed 05/31/17 Page 9 of 16

SECOND AMENDED COMPLAINT.

Page 10 of 15

 

41. Plaintiff is unable to reside in his manufactured home without having qualified in-home care attendants in place at all times, even during extended medical stays, and the ability to renew his Conditional Use Hardship Permit.

 

42. Recently, Ms. Pekarek, in her capacity on behalf of MCCE and MCSO, has verbally and in writing, informed Plaintiff’s family members of her intention to impose a daily fine of $500.00-$1000.00 a day for code violations on the Property, and renewed her intention to terminate Plaintiff’s Conditional Use Hardship Permit and/or evict future in home care attendants.

 

43. Plaintiff and members of Plaintiff’s family have requested reasonable accommodations from Ms. Pekarek, MSCO, and MCCE, in order for Plaintiff to return to the Property without any ongoing actions, letters, threats and intimidation related to his use and occupancy on the Property.

 

44. Ms. Pekarek, MSCO, and MCCE have denied Plaintiff and members of Plaintiff’s family’s requests for reasonable accommodations.

 

45. Ms. Pekarek, MSCO, and MCCE have addressed the violations, threats, and actions to members of Plaintiff’s family, due to the fact that Plaintiff does not own the Property, and currently resides in Mexico.

 

46. Plaintiff will be directly harmed in the event that his Conditional Use Hardship Permit is terminated, and/or daily fines are assessed against the Property.

 

47. Plaintiff has suffered emotional and financial harms, because of the expense of retraining in home attendants, relocation costs to Mexico, and his inability

 

Case 6:16-cv-01918-AA Document 18 Filed 05/31/17 Page 10 of 16

SECOND AMENDED COMPLAINT.

Page 11 of 15

to live near family.

 

FIRST CLAIM FOR RELIEF

 

THE AMERICANS WITH DISABILITIES ACT

 

48. Plaintiff incorporates by reference the allegations of paragraphs 1 through 46 above.

 

49. Title II of the ADA prohibits a public entity from excluding a person with a disability from participating in, or denying the benefits of, the goods, services, programs and activities of the entity or otherwise discriminating against a person on the basis of disability. 42 USC § 12132.

 

50. At all times relevant to this action MCCE and MCSO were and are public entities within the meaning of Title II of the ADA and provides a code enforcement and permit program, service or activity to the general public.

 

51. At all times relevant to this action, the Plaintiff was a qualified individual with a disability within the meaning of Title II of the ADA and meet the essential eligibility requirements for the receipt of the services, programs or activities of provided by MCCE and MCSO.

 

52. From November 2015 to date, Defendants have failed to provide reasonable accommodations to Plaintiff and/or his family members, have disproportionately burdened disabled individuals, implemented policies that resulted in the disparate treatment and disparate impact against individuals with disabilities whose serious medical needs may require them to be away from home for longer than ninety days at a time, and/or require in home care attendants.

 

Case 6:16-cv-01918-AA Document 18 Filed 05/31/17 Page 11 of 16

SECOND AMENDED COMPLAINT.

Page 12 of 15

 

53. As a direct and proximate result of Defendants’ violations of Title II of the ADA, Plaintiff was injured as set forth herein and will continue to suffer injury until Defendants are required to, and have, come into compliance with the requirements of the ADA.

 

54. At times relevant to this complaint, Defendants’ had notice that an accommodation was required, and deliberately failed to act upon that knowledge.

 

SECOND CLAIM FOR RELIEF

 

SECTION 504 OF THE REHABILITATION ACT OF 1973

 

55. Plaintiff incorporates by reference the allegations of paragraphs 1 through 46 above.

 

56. Section 504 of the Rehabilitation Act of 1973, 29 U.S.C. §794, and the regulations promulgated thereunder, prohibit discrimination against people with disabilities by recipients of federal funding. Section 504 provides, in pertinent part, that:

 

No otherwise qualified handicapped individual…shall, solely by reason of his or her handicap, be excluded from the participation in, be denied the benefits of, or be subjected to discrimination under any program or activity receiving Federal financial assistance […].

 

57. Defendants have received substantial federal financial assistance at all relevant times.

 

58. Plaintiff is an otherwise qualified handicapped individual within the meaning of Section 504 of the Rehabilitation Act.

 

59. Defendants have discriminated against Plaintiff in programs and

 

Case 6:16-cv-01918-AA Document 18 Filed 05/31/17 Page 12 of 16

SECOND AMENDED COMPLAINT.

Page 13 of 15

 

activities receiving federal financial assistance solely because of the disability of plaintiff, and all others similarly situated, in violation of 29 U.S.C. §794 and the regulations promulgated thereunder.

 

60. As a proximate result of Defendants’ violations of Section 504, the Plaintiff has been injured as set forth herein and will continue to suffer injury until MSCE and MCSO is brought into compliance with 29 U.S.C.§794 requirements.

 

61. Because Defendants’ discriminatory conduct presents a real and immediate threat to plaintiff, his safety and his ability to equally access reasonable accommodations, and to equally access public services declaratory and injunctive relief are appropriate remedies.

 

62. At times relevant to this complaint, Defendants’ had notice that an accommodation was required, and deliberately failed to act upon that knowledge.

 

THIRD CLAIM FOR RELIEF

 

ORS §§ 659A.142 (5)(a), 659A 145 (g)

 

63. Plaintiff incorporates by reference the allegations of paragraphs 1 through 62 above.

 

64. Defendants’ refused to make reasonable accommodations in rules, policies, practices or services when the accommodations were necessary to afford the individual with a disability equal opportunity to use and enjoy a dwelling in violation of ORS §659A 145 (g).

 

65. Defendants’ denied an individual the benefits of the services, programs or activities of local government and/or made a distinction, discrimination or restriction because the individual has a disability in violation of ORS § 659A.142

 

Case 6:16-cv-01918-AA Document 18 Filed 05/31/17 Page 13 of 16

SECOND AMENDED COMPLAINT.

Page 14 of 15

 

(5)(a).          

 

PRAYER FOR RELIEF

WHEREFORE, Plaintiffs pray for relief as follows:

 

66. A declaration that Defendants’ policy, pattern and/or practice of requiring individuals and/or the family members of individuals with Conditional Use Hardship Permits to evict in home care attendants during an extended hospitalization and/or medical stay of more than three (3) months discriminates against Plaintiff and fails to comply with the requirements of Title II of the ADA and Section 504 of the Rehabilitation Act of 1973 and Oregon disability laws;

 

67. A declaration that Defendants’ policy, pattern and/or practice of threatening to terminate a Conditional Use Hardship Permits based on the individual’s absence from the residence during an extended hospitalization and/or medical stay of more than three (3) months discriminates against Plaintiff and fails to comply with the requirements of Title II of the ADA and Section 504 of the Rehabilitation Act of 1973 and Oregon disability laws; 68. An order and judgment enjoining Defendants from enforcing and/or threatening to enforce any and all open code enforcement violations at the Property;

 

69. An order and judgment enjoining Defendants from violating Title II of the ADA and Section 504 of the Rehabilitation Act of 1973 and Oregon disability laws, including anti-retaliation provisions that prohibit retaliation or discrimination against anyone, disabled or not, on the basis of that person's

 

Case 6:16-cv-01918-AA Document 18 Filed 05/31/17 Page 14 of 16

SECOND AMENDED COMPLAINT.

Page 15 of 15

 

efforts to oppose unlawful discriminatory practices;

 

70. An order and judgment requiring Defendants issuance of a variance or accommodation related to any and all open code enforcement violations at the Property;

 

71. An order and judgment requiring Defendants to change their policy, pattern and/or practice regarding enforcement and termination of Conditional Use Hardship Permits.

 

72. Enter judgment in favor of Plaintiff in an amount of money damages to be proven at trial;

 

73. Award plaintiff’s reasonable attorneys’ fees, litigation expenses and costs;

 

74. All such other and further relief as the Court deems just and proper.

 

Respectfully submitted this 31st day of May, 2017.

 

/s/ Melissa D. Wischerath

Melissa D. Wischerath

OSB # 130194

P.O. Box 12263

Eugene, OR 97440

(541) 600-4319 | (646) 765-0035 |

melissa@mdwlaw.net

Case 6:16-cv-01918-AA Document 18 Filed 05/31/17 Page 15 of 16

􀀂􀀆􀀊􀀋􀀈􀀇􀀈􀀅􀀄􀀋􀀆􀀁􀀉􀀇􀀁􀀃􀀆􀀊􀀌􀀈􀀅􀀆􀀁􀀍􀀁

 

CERTIFICATE OF SERVICE

 

I certify that I electronically filed a true, full and exact copy of Plaintiff’s Second Amended Complaint with the Clerk of Court using the CM/ECF system.

 

DATED: Mar 31, 2017.

 

/s/ Melissa D. Wischerath

Melissa D. Wischerath

OSB # 130194

P.O. Box 12263

Eugene, OR 97440

Telephone: (541) 600-4319

melissa@mdwlaw.net

M li D Wi h th

 

Case 6:16-cv-01918-AA Document 18 Filed 05/31/17 Page 16 of 16

 

You think you can trample on my civil rights and I won’t fight back to my last breath, man, Marion County Supervisors your own Planning Commission has no clue as to what your Code Enforcement Officer is doing, but the Sheriff does, don't you Sir? Three trailers that have been on a well maintained, beautiful farm for twenty plus years as the biggest solid waste violation resulting in confiscation of our homes and farm that’s paid for with property taxes current at all times, my gosh, what happened to a hearing? What happened to allowing me the tenant, to respond to what the county has done and continues to do? Well my response is pretty clear now don't you think?

 

I believe her in-ability to understand her full capacity of the law she ignored or the ADA will be her down fall. Her fullest intentions were to disrupt, tear down, cripple all and any persons related to the  Name HENION.  I believe she solely hates... The Disable Act that has been put in place to solely PROTECT AND SECURE THE FACT... THAT DISCRIMINATION AGAINST ANYONE DISABLED...  TOWARDS ANY UN-FORTUNATE PERSON WHO LIVES WITH AN DISABILITY.  I am going to research her life like you suggested with records tonight. I myself understand as I have suffered though my back surgery, and on-going pain. When you fell to the ground, and mom called me and informed me of the accident. I have held it in all these years. I hurt inside when I see you strapped to that chair. I always wanted to wave a magic wand and make you not have to live that way. I have watched you struggle and never could understand why this happened to my Brother. As I grew older, and came to understand more I realized the human life is what we make it. It can be amazing or we can feel sorry for ourselves and roll in self pity. I have watched you grow beyond this. Even in a chair, you continued to start up business's like the Si Mi, Trucks, and write books. The Navy Book is amazing. Hours and hours of love and time you have put in it. My Brother whom I love deeply, has written an amazing book. Wow... Looking back on my life with all its trials and tests, as you have too, it kept me so busy that my time was so focused that I wanted more time to just talk to you and spend more time with you. So I know how we can fix this. We will spend eternity with each other in the kingdom of God. This whole happening that has happen to you as well as Dad and Betty-(Mom) has been unfair and undo hardship placed upon the family in general. Dad calls me 3 times a day worried and trying to figure it all out. Which I enjoy the calls and, I can here the frustration in his voice too. Sometimes I have some hope for him, and other times nothing.  He and Betty (Mom) is and has had stress placed on them to the fullest. Shame on Laura who wears the power pants and seems to lack understanding and fairness.  She acts like a Generic Modified Chemical with no Conscience.  Darkness is surrounding our world and God is our hope. We can't give up. As for the Media, I am going to email them your WEBSITE AND AVIDATIVE. Daddy gave me the list of whom you sent all your letters too. Wow and fantastic. I will forward it too.

I love you

Your Sister Judy Henion Allen

 

Efforts to oppose unlawful discriminatory practices - 6/19/2017

 

There are many issues facing severely disabled persons, discrimination can be in many forums. Today I’m reporting, you decide. The web links I provide house the entire story and evidences, yet it is my intention to purposely document before you the most current activities on you’re public site so every severely disabled person in Oregon may be notified of an Oregon Law that discriminates against severely disabled persons. Furthermore, not everyone will click on a web link on facebook sites and if I’m going to allege things before the U. S. District Court, Eugene, Oregon and the public, you can believe I’ll drag with me my current activities, especially since I’m declaring through a law suit filed yesterday by my attorney, that entire state within every county is not in compliance of federal laws relating to discrimination against severely disabled persons. I‘m giving you the opportunity to publicly respond because I know you will respond to issues that have substance. I begin with my letter to Governor Kate Brown, a personal friend to my uncle, Loyd Henion, Democrat Delegate, so you can believe she knows of my story and case, with comments from me, posted on her facebook.

 

Attorney General of America Sessions

 

Your the top law official in America and I thought the Governor of Oregon and her Attorney General were the top law officials of Oregon, but last year when they were notified of discrimination practices of Marion County and an unlawful and discriminative state law violating ADA, neither an investigation or CONCERN was gifted, not even liberally.

 

I’m thinking it must not be the duty of the Governor or Attorney General of Oregon to uphold the ADA in its state.

 

A fair and balanced law would take into consideration civil liberties and not discriminate against severely disabled person(s) or disabled veterans.

 

I feel abandoned, full of despair, homeless, but most of all, raped of my civil liberties. To know you’re not wanted because your severely disabled is the most awful feeling I’ve ever had.

 

It makes me cry inside, but my astonishment of such lack of human compassion makes me want to fight.

 

I served a country that has no ears to the cry of discrimination, and while discrimination is apparent in all walks of life, some how being called a gimp and being treated like one is so dissatisfying, that one does everything they can to bring attention to the plight of those discriminated against.

 

And still, the media cares not. Will the top law official care?

 

Questions I asked the President on his facebook page:

 

Mr. President - If counties in Oregon receive federal funding to accommodate through services or programs severely disabled and they don’t do it, and if they violate the ADA, should federal funds be allocated to Oregon Counties?

 

Mr. President – If a state in the Union has a law that discriminates against severely disabled persons, isn’t it the duty of the Attorney General of America to sound off?

 

Mr. President, while my personal civil rights have been denied me and discrimination on going because I’m disabled, allegations easily proven, my federal law suit will set forth the evidences of my claims, yet a unlawful and discriminative law must be dealt with, other wise as a severely disabled person(s), we have no civil rights in Oregon.

 

I hope and pray you ask your Attorney General to look into Oregon’s discriminative law that discriminates against severely disabled persons.

 

 

Law Suit against the Community Resource Officer of the Code Enforcement of Marion County, Oregon

Part III of IV

 USS CORAL SEA (CV 43)

Operations Evening Light and Eagle Claw, A Sailors tale of his Tour of duty in the U.S. Navy (August 1977 to February 1983)

 

A Sailors tale of his Tour of duty in the U.S. Navy (August 1977 to February 1983) - Operation Evening Light and Eagle Claw - (24 April 1980)

 

Book - ISBN NO.

978-1-4276-0454-5

EBook - ISBN NO.

978-1-329-15473-5

 

Operations Evening Light and Eagle Claw (24 April 1980) Iran and Air Arm History (1941 to Present)

 

Operations Evening Light and Eagle Claw (24 April 1980) Iran and Air Arm History (1941 to 2016)

 

Book ISBN NO.

To Be Announced

EBook ISBN NO.

978-1-329-19945-3

 

USS CORAL SEA CV-42, CVB-43, CVA-43 & CV-43 HISTORY, AND THOSE AIRCRAFT CARRIERS OPERATING WITH CORAL SEA  Vol. I (10 July 1944 to 31 December 1975)

 

USS CORAL SEA CV-42, CVB-43, CVA-43 & CV-43 HISTORY, AND THOSE AIRCRAFT CARRIERS OPERATING WITH CORAL SEA Vol. I

(10 July 1944 to 31 December 1975)

 

Book ISBN NO.

To Be Announced

EBook ISBN NO.

978-1-329-54596-0

 

USS CORAL SEA CV-42, CVB-43, CVA-43 & CV-43 HISTORY, AND THOSE AIRCRAFT CARRIERS OPERATING WITH CORAL SEA DURING HER TOUR OF SERVICE Vol. II (1 January 1976 to 25 August 1981)

 

USS CORAL SEA CV-42, CVB-43, CVA-43 & CV-43 HISTORY, AND THOSE AIRCRAFT CARRIERS OPERATING WITH CORAL SEA DURING HER TOUR OF SERVICE Vol. II

(1 January 1976 to 25 August 1981)

 

Book ISBN NO.

To Be Announced

EBook ISBN NO.

978-1-329-54790-2

 

USS CORAL SEA CV-42, CVB-43, CVA-43 & CV-43 HISTORY, AND THOSE AIRCRAFT CARRIERS OPERATING WITH CORAL SEA DURING HER TOUR OF SERVICE Vol. III (20 August 1981 to 26 April 1990)

 

USS CORAL SEA CV-42, CVB-43, CVA-43 & CV-43 HISTORY, AND THOSE AIRCRAFT CARRIERS OPERATING WITH CORAL SEA DURING HER TOUR OF SERVICE Vol. III

(20 August 1981 to 26 April 1990)

 

Book ISBN NO.

To Be Announced

EBook ISBN NO.

978-1-329-55111-4

 

USS Abraham Lincoln (CVN-72) History Vol. I (27 December 1982 to 6 May 2003)

 

USS Abraham Lincoln (CVN-72) History Vol. I  (27 December 1982 to 6 May 2003)

 

Book - ISBN NO.

To Be Announced

EBook - ISBN No.

978-1-365-73794-7

 

USS Abraham Lincoln (CVN-72) History Vol. II (7 May 2003 to 13 January 2010)

 

USS Abraham Lincoln

(CVN-72) History Vol. II

(7 May 2003 to 13 January 2010)

 

Book - ISBN NO.

To Be Announced

EBook - ISBN NO.

978-1-365-74027-5

 

USS Abraham Lincoln (CVN-72) History Vol. III (14 January 2010 to 31 December 2012)

 

 

USS Abraham Lincoln

(CVN-72) History Vol. III

(14 January 2010 to 31

December 2012)

 

Book - ISBN NO.

To Be Announced

EBook - ISBN No.

978-1-365-74145-6

 

USS Abraham Lincoln (CVN-72) History of Refueling and Complex Overhaul (RCOH)  (1 January 2013 to 2017)

 

USS Abraham Lincoln

(CVN-72) History of

Refueling and Complex

Overhaul (RCOH)

(1 January 2013 to 2017

Sea Trials) Volume IV

 

Book - ISBN NO.

To Be Announced

EBook - ISBN No.

978-1-365-74587-4

 

U. S. AIRCRAFT CARRIER SHIP HISTORY (1920 to 2016)

 

U. S. AIRCRAFT CARRIER SHIP HISTORY (1920 to 2016)

 

Book - ISBN NO.

978-1-4276-0465-1

EBook - ISBN NO.

978-1-365-25019-4

Library of Congress

Control Number: 

2008901616

(Book Version)

 

U. S. AIRCRAFT CARRIERS REDESIGNATED AND OR RECLASSIFIED (1953 to 2016)

 

U. S. AIRCRAFT

CARRIERS

REDESIGNATED

AND OR

RECLASSIFIED

(1953 to 2016)

 

BOOK - ISBN NO.

978-1-4276-0452-1

EBook - ISBN NO.

978-1-365-25041-5

Library of Congress

(Book Version)

2008901619

 

ENERGY QUEST AND U. S. AIRCRAFT CARRIER DEPLOYMENT HISTORY INVESTMENT CAPITAL REQUIRED TO PUBLISH 55 EIGHTH HUNNDRED PAGE BOOKS AND EBOOKS (48 Navy Books)

 

ENERGY QUEST AND U. S. AIRCRAFT CARRIER DEPLOY. HISTORY INVESTMENT CAPITAL REQUIRED TO PUBLISH 55 EIGHTH HUNNDRED PAGE BOOKS, EBOOKS & CD’s

(48 Navy Books)

 

Book - ISBN NO.

To Be Announced

EBook - ISBN No.

978-1-365-26038-4