ROY GUTHRIE, CEO OF RENOVATE AMERICA DOES A MEAN SPIRITED DISAPPEARING ACT

Beware HERO FINANCING and RENOVATE AMERICA. Roy Guthrie will pretend he is financing your home repair, then pull the rug out from under you and revoke the financing, leaving you at the mercy of his contractors. His contractors will take your home away from you.

In a very unusual move unheard of in normal business practices, Roy Guthrie, CEO of RENOVATE AMERICA / HERO has made a conscious decision to harm my autistic son James by allowing his HERO contractor PETERSEN DEAN to get away with violations and hide the HERO FINANCING from Judge Murphy in Case BC661819 at Stanley Mosk Courthouse in Los Angeles. 

Mr. Guthrie's  company, RENOVATE AMERICA is famous for promising customers protection from bad contractors and frequently makes the claim in social media advertising such as the ad below:

In 2016 RENOVATE AMERICA / HERO warned me not to sign a contract that their contractor PETERSEN DEAN threatened me for months to sign. From November 2016 until January 2017 PETERSEN DEAN fixers hounded me to sign off even though the work was not completed, repairs were not made and the agreement to remove the solar panels was reneged upon by PETRSEN DEAN, even after H&R Block revealed I would not receive the promised $10,000+ tax credit, that it was a tax credit scam that would cause us to lose our home to HERO FINANCING a year after I signed off. 

HERO and PETERSEN DEAN agreed to remove the solar panels after they were caught red handed mid scam. The week in January 2017 that PETERSEN DEAN said they would remove the solar panels, they filed two MECHANICS LIENS instead and ROY GUTHRIE and his company HERO / RENOVATE AMERICA did an unheard of disappearing act. At first everyone I told about my financing "disappearing" thought I was mistaken. How can financing disappear? PETERSEN DEAN and RENOVATE AMERICA / HERO began by blocking me so I could not email them about my financing with them. They refused to take my calls and began destroying evidence that I was ever a customer.

Here is the HERO FINANCING email instructing me NOT to sign off. This employee was not aware that a new scam was in the making. Soon afterward this email all communications were cut off. ROY GUTHRIE and his company abandoned the tax credit scam for a new scam that defies logic. Roy Guthrie packed up his financing of the project and disappeared. 

Hello Jennifer,

After looking at your file, I do see that a case was submitted to our consumer protections department on your behalf to address your concerns.  An agent from the consumer protections department will be reaching out to you within 2 business days to address your concerns and assist you with reaching a resolution.  Do not sign off on any completion certificates if they are presented to you until the project is actually completed.  Thank you for keeping us updated. Please call us if you have additional concerns and please expect a call form an agent soon. Thank you for being a part of HERO.

Jackie Carreon I Program Services I O:855-HERO-411 I

Renovate America, Inc. I 15073 Avenue of Science I Ste 200 I San Diego, CA 92128

Roy Guthrie allowed his contractor to do things that the CONTRACTORS STATE LICENSE BOARD found to be violations and on May 23, 2018 the CSLB issued a citation that will remain on PETERSEN DEAN'S license for five years. Even with this citation, Roy Guthrie has remained in hiding and has refused to step forward and protect the consumer. 

Roy Guthrie is guilty of false advertising. Instead of telling homeowners that he has their back, he should be honest about his very mercurial financing and admit that if anything goes wrong with his contractors, HERO / RENOVATE AMERICA financing will disappear without a trace and leave the customer at the mercy of the contractor with no financing. Roy Guthrie revokes the financing and never looks back. His people block the customer on social media, block the customer from emailing about their missing financing and refuses to take any phone calls.

My autistic son James and I might lose our home to PETERSEN DEAN. I don't know if Roy Guthrie will get a kickback from PETERSEN DEAN for agreeing to step aside to allow PETERSEN DEAN to execute a second con after the first con was interrupted by H&R Block revealing it was a scam. PETERSEN DEAN and ROY GUTHRIE are truly partners in crime.

My son and I may end up homeless but at least we were able to get a CITATION placed on PETERSEN DEAN'S license for the next 5 years to warn consumers to beware. We are so hurt by two years of being bullied, threatened and living in fear of homelessness that we might not survive if a large law firm does not pick up our case soon. Wish us luck, renewed health and safe journey because we need these things. Thank you for hearing our story.

CEO ROY GUTHRIE MADE A CONSCIOUS CHOICE TO HARM AN AUTISTIC YOUNG MAN

RENOVATE AMERICA / HERO CEO ROY GUTHRIE IS DELIBERATELY HARMING AN AUTISTIC YOUNG MAN

ROY GUTHRIE

ROY GUTHRIE revoked the financing for a home improvement project to cover up a tax credit scam. He has been allowing his contractor PETERSEN DEAN to torment the young Autistic man JAMES and his mother JENNIFER MARSHALL for years, forcing the boy to live in a gutted home with no heat or air conditioning. ROY GUTHRIE'S contractor filled the air vents with stucco powder, causing the autistic boy to develop a severe lung infection and then refused to pay the remediation contractor to clean the air vents, the young man's bedding, closet, stuffed animals and other possessions coated with the fine powder.

The autistic man, James Marshall, has been in a rapid downward spiral physically and emotionally ever since ROY GUTHRIE and PETERSEN DEAN came up with this second scam to cover up their first scam.

The years of toxic, unrelenting stress, lack of a kitchen, lack of a normal daily routine due to the complicated legal tasks his mother is forced to do to try to save their home WHILE she is his sole care-provider trying to take care of him, has caused permanent physical and psychological damage to James. 

Not only is ROY GUTHRIE fine with this on going injury, he is aware PETERSEN DEAN employees used the boy's health problems as leverage to try to force JENNIFER MARSHALL to sign forms that would allow HERO to foreclose on the home a year after the job was completed when the balloon would hit because there wasn't really a $10,000 tax credit. When mom wouldn't sign the forms, knowing it would be suicidal to do so, ROY GUTHRIE and GEORGE MILIONIS came up with a second scam that would allow PETERSEN DEAN to foreclose on the home without any signatures from JENNIFER MARSHALL. Invalid MECHANICS LIENS were filed and JENNIFER MARSHALL'S initials were electronically forged and deposited on documents different than the contract agreed to by JENNIFER MARSHALL. Attorneys SAM KARIMZADEH and GEORGE MILIONIS are trying to ram these fraudulent documents through the courts as fast as they can before JENNIFER MARSHALL can hire a law firm to represent her and her son.

This is the computer generated / forged signature. This is NOT my handwriting:

Below is computer generated / forged initials. This is NOT my handwriting

Below is my REAL signature:

Even with the CSLB finding PETERSEN DEAN in violation and placing a five year CITATION on PETERSEN DEAN'S license, Roy Guthrie continues to hide in the shadows and watch James Marshall being torn apart alive by PETERSEN DEAN'S ruthless attorneys GEORGE MILIONIS and SAM KARIMZADEH who are steam rolling James's mom in case BC661819 in the Stanley Mosk Courthouse. SAM KARIMSADEH wants to take James' home away from it so PETERSEN DEAN can sell it fast and destroy any record of the 2016 tax credit scam they had to abort when Jennifer Marshall's H&R Block tax preparer discovered the financing was a scam.

ROY GUTHRIE and GEORGE MILIONIS came up with a second scam to bury the first scam. 

Sam Karimzedah

Unfortunately, to bury the scam, they would have to put James Marshall through what would amount to a meat grinder. James Marshall will never fully recover, if he survives.

ATTORNEY GEORGE MILIONIOS HAS HIRED SAM KARIMZADEH TO REPLACE HIM

The new attorney is Sam Karimzadeh. He does not have a fax machine or a street address. I don't know if that was an attempt to make it impossible to serve documents so I would lose by default. Suppression of the financing, suppression of the facts is Petersen Dean's modus operandi.

George Milionis doesn't want to answer any questions Judge Murphy might ask him about the HERO FINANCING, so he has substituted in Sam Karimzadeh to be the attorney on the case. He has no fax machine. He has no street address. I can reach him by email. Sam Karimzadeh is upset with me for continuing to contact George Milionis's office. I am serving legal documents to George Milionis's street address. When required by the court to fax a document, I have to fax to George Milionis's office because the attorney on the case does not have a fax.

I found the new attorney on twitter, linkedin and on www.avvo.com

Sam Karimzadeh doesn't have a specialty listed in his bio but I can vouch that his specialty is taking homes away from the elderly and disabled by suppression of the financing. Like George Milionis, Mr. Karimzadeh wants to have a settlement conference where I am not allowed to mention to Judge Murphy that HERO/RENOVATE AMERICA was financing the job. Mr.Karimzadeh also does not want me to be able to tell the court that his client Petersen Dean was cited by the Attorney General/CSLB and the citation for not doing the job on our house correctly will be on their license record for five years. Sam Karimzadeh wants to appear liberal on twitter but in real life he believes in using the techniques President Trump and Russia use...disinformation, suppression,  and intimidation.

My son James is very ill now. I am asking Judge Murphy if I may have an extension until August 1, 2018 to take James to doctors and then make calls to attorneys to ask them to represent me and James in this case, to amend my ANSWER to the complaint and file a CROSS COMPLAINT to officially add RENOVATE AMERICA/HERO FINANCING to this case so justice can be served.

******************************

SAM KARIMZADEH

I PRAY THAT PETERSEN DEAN'S LICENSE WILL BE REVOKED

I pray that PETERSEN DEAN'S license will be revoked so that they can never again harm a family the way they have taken away our lives and hurt my autistic son James so badly for two years and counting....

Dear Sam Karimzadeh, (Attorney for Petersen Dean, Inc.)

You will also be asked in court how on earth the financing is not a party to this case.

How is Hero Financing not a party to this case?

Do you have proof that I qualified for a whopping $34,000.00 debt with a credit score of 420 as verified by all 3 credit bureaus and the Consumer Financial Protection Bureau records?

May I have a copy of this proof that I qualified me for $34,000 in Financing with Petersen Dean outside of the HERO program?

Will you please file that proof with the court or withdraw you invalid case and properly remove the invalid Mechanics Liens so my son can have his surgeries? You have tied up our equity long enough.

You are directly responsible for the downward spiral James is suffering.

Due to my credit score I only qualified for home equity HERO FINANCING and we agreed it would cost $20,000 with no more electric bill. None of figures given me were true, as documented by H&R Block.

Your client and HERO have destroyed records and that only makes you all look more guilty. There is still a paper trail and witnesses who will not lie for you.

I am asking you now but I know you are not permitted by your client to discuss the Hero Financing they were to be paid by. Can you prove your case other than wave about a contact that my signature and initials were wrongfully deposited up?  Lord knows how many versions you have of those contracts but not one of them is valid because no legitimate business could qualify me for a $34,000 loan in 2016. Prove to me and the court how that happened?

The court will require proof that I qualified for this massive debt with a credit score of 420.

This case is destroying my autistic son. Your client is directly responsible for what is happening to James, for making all his heath problems much worse and causing permanent damages such as teeth that can no longer be capped and saved.

The nonsense about calling the financing of the project “not a party to the litigation” is proof that you have no case and Petersen Dean had hoped I would not find out about BC661819 until it was over, which is the exact MO of the tax credit scam where homeowners don’t find out until a year later when it’s too late.

Just because this scam has worked so well for your client so many times before doesn’t mean they are as invincible as Petersen Dean men tried to scare me into believing when they threatened me and James in 2016 for MONTHS to try to force a signature.

You ask what I want yet you refuse to respond to anything that Petersen Dean has declared off limits.

I want Petersen Dean to have their license revoked for doing this to my son, for destroying a human life just to run a scam instead of earning money the honest way.

How many other lives has your client destroyed?

Sincerely,

Jennifer Marshall

On May 25, 2018, at 3:32 PM, Sam Karimzadeh skarimzadeh.sklaw wrote:

Ms. Marshall,

Your response is noted.  I will report that you have refused to attend the conference because non-parties to the litigation will not be present.  

Best Regards,

Sam Karimzadeh

On Thu, May 24, 2018 at 6:05 PM, Jennifer E Marshall <JLiz@ca.rr.com> wrote:

Mr Karimzadeh,

You are playing with my son’s life and you need to stand down and stop it.

Cease and desist your brazen, foolish attempt to pit me against Judge Murphy. For shame!

How dare you state that I don’t want to attend a settlement conference because of Judge Murphy? Your attempts to ingratiate yourself to him and make it appear I don’t like him as much as you do are shameful and highly unprofessional. You know I won’t attend because you won’t let HERO attend. Stop this foolishness.

I will attach your emails to my Case Management filing tomorrow in court.

You are clearly trying to create problems out of thin air.

You know very well that I have rejected the idea of a premature settlement conference because of who WON’T be there: HERO FINANCING. Why would you waste the courts time and antagonize my autistic son with a conference that excludes the truth and therefore can go no where?

Since you cannot tell the truth, there has to be a trial by jury. It’s not Judge Murphy’s fault you can’t discuss the HERO FINANCING and I have never once indicated that your short comings are his fault. Shame on you for throwing that mud against the wall in hopes it will stick.

Since the truth will not be attending your much desired settlement conference, neither will I.

In fact, I am grateful Judge Murphy is presiding and not you. You write as if you are the Judge. I will be attending the Case Management Conference by phone for James’s safety and I will listen to what Judge Murphy has to say about all of this. I believe he has the last word, not you.

You make light of my son’s serious condition, a condition caused by your client. You mock me for not being able to keep him alive and keep a time line you have chosen for me. You clearly do not care what happens to my son. You would push James into an early grave or a dismal institution for a meritless case that never should have been filed in court of law. I don’t think the court will share your heartless disregard for human life. James’s doctors will verify that this case is causing James tremendous harm. Time will verify that your case has no merit.

I need an attorney to replace me or my son might die. Cap Specialty can inform you how distressed James is this week. You need to stop trying to make me stay in pro per and stop wasting what little time I have that I should be searching for an attorney with, not responding to your insults. Your impudence is outrageous. You want me to consider your helping me take actions that are unwise and suicidal as “graciousness” on your part. You want to “help” me do things that will help your client and deny us justice. No thank you.

I am asking the Judge to allow me to hire an attorney to property amend the complaint. I am asking the court, not you personally.

You are not communicating with me. You are barking at me. You won’t discuss HERO FINANCING, which is key to this case. That is a red flag that speaks to your total lack of credibility. I do not trust you. I will listen to Judge Murphy, not a man who is not allowed to say the words “HERO FINANCING”.

Again, how do you sleep at night?

Sincerely,

Jennifer Marshall & son James

THE FIRST PETERSEN DEAN CITATION BY THE CSLB

This is the FIRST citation against PETERSEN DEAN, INC.

This is the beginning of the verification of a very long list of violations by PETERSEN DEAN, INC and RENOVATE AMERICA

This CSLB citation will remain on PETERSEN DEAN, INC's license for five years, a warning homeowners to beware. What is happening to us could happen to others.

Step by step we will try to stay alive and get our lives back. 

RENOVATE AMERICA / HERO is hiding. I must find an attorney to file a cross complaint against RENOVATE AMERICA / HERO to hold them accountable for letting their contractor PETERSEN DEAN violate their rules and for not protecting us like they promised they would.

PETERSEN DEAN'S ATTORNEY SLINGS SOME MUD

Mr Karimzadeh, 

You are playing with my son’s life and you need to stand down and stop it. 

Cease and desist your brazen, foolish attempt to pit me against Judge Murphy. For shame!

How dare you state that I don’t want to attend a settlement conference because of Judge Murphy? Your attempts to ingratiate yourself to him and make it appear I don’t like him as much as you do are shameful and highly unprofessional. You know I won’t attend because you won’t let HERO attend. Stop this foolishness. 

I will attach your emails to my Case Management filing tomorrow in court. 

You are clearly trying to create problems out of thin air. 

You know very well that I have rejected the idea of a premature settlement conference because of who WON’T be there: HERO FINANCING. Why would you waste the courts time and antagonize my autistic son with a conference that excludes the truth and therefore can go no where? 

Since you cannot tell the truth, there has to be a trial by jury. It’s not Judge Murphy’s fault you can’t discuss the HERO FINANCING and I have never once indicated that your short comings are his fault. Shame on you for throwing that mud against the wall in hopes it will stick. 

Since the truth will not be attending your much desired settlement conference, neither will I. 

In fact, I am grateful Judge Murphy is presiding and not you. You write as if you are the Judge. I will be attending the Case Management Conference by phone for James’s safety and I will listen to what Judge Murphy has to say about all of this. I believe he has the last word, not you. 

You make light of my son’s serious condition, a condition caused by your client. You mock me for not being able to keep him alive and keep a time line you have chosen for me. You clearly do not care what happens to my son. You would push James into an early grave or a dismal institution for a meritless case that never should have been filed in court of law. I don’t think the court will share your heartless disregard for human life. James’s doctors will verify that this case is causing James tremendous harm. Time will verify that your case has no merit. 

I need an attorney to replace me or my son might die. Cap Specialty can inform you how distressed James is this week. You need to stop trying to make me stay in pro per and stop wasting what little time I have that I should be searching for an attorney with, not responding to your insults. Your impudence is outrageous. You want me to consider your helping me take actions that are unwise and suicidal as “graciousness” on your part. You want to “help” me do things that will help your client and deny us justice. No thank you. 

I am asking the Judge to allow me to hire an attorney to property amend the complaint. I am asking the court, not you personally. 

You are not communicating with me. You are barking at me. You won’t discuss HERO FINANCING, which is key to this case. That is a red flag that speaks to your total lack of credibility. I do not trust you. I will listen to Judge Murphy, not a man who is not allowed to say the words “HERO FINANCING”. 

Again, how do you sleep at night? 

Sincerely, 

Jennifer Marshall & son James

On May 24, 2018, at 4:26 PM, Sam Karimzadeh  wrote:

Ms. Marshall,

I have received a response from you in a separate email, but it does not appear to directly address the issue of the stipulation to give you time to amend your answer find another attorney in exchange for merely attending the conference with Judge Murphy.  It appears you are inclined against appearing at a conference with Judge Murphy present. 

I want to be clear - I reiterate my offer to allow you until 8/1/2018 to file an amended answer and find an attorney in exchange for simply showing up to a conference hosted by Judge Murphy.  

I further wish to reiterate that you are not obliged to accept anything offered at the conference.  Whatever concerns you may have about the case or even the conference itself, I don't see why you couldn't raise those issues with the judge directly at the conference.  

Your first pleading was filed in November of 2017, six months ago.  The Court, on its own order, provided you with an extension to 23 APR to file a proper pleading.  A month later, you now ask for an additional two-month extension "in good faith."  All we are requesting is a meeting with the Judge to identify the issues moving forward.  Again, this creates no obligation on your behalf other than to simply show up.

I have taken every step to be collegial, professional, and courteous in working with you to resolve this dispute, and despite this, you refuse. Good faith is a two-way street, and I am more than willing to convince my client to give you yet another two months, provided you show me some good faith on your end by simply showing up to a meeting with the judge.   This is not a big ask to make.  How can we establish good faith if you refuse to do as little as showing up to a meeting? 

Again, I am happy to stipulate to a two-month extension so you can amend your answer and find an attorney on the condition you agree to show up to a conference with the judge.  Those are my terms.  Do we have an agreement? 

Best Regards,

Sam Karimzadeh, Esq. 

CASE MANAGEMENT: SOPHIE’S CHOICE

Dear Mr Karimzadeh, 
(Attorney replacing GEORGE MILIONIS representing PETERSEN DEAN.)

James is finally asleep after a very long bout of insomnia and screaming inconsolably. We have hundreds of witnesses in the community plus his doctors to testify as to James’s agony. A man a HOME DEPOT who has an autistic son said he is praying for James because his son would also not be able to bear this.

If James stays asleep long enough this morning, I will fill out a Case Management form and file it tomorrow with the court indicating you refused to discuss any of the items in my ANSWER to your COMPLAINT (copy of my answer attached).  All you did was try to advance your agenda and steer me towards accepting a crippling limited scope. 

Both you and George Milionis steadfastly refused to discuss the HERO FINANCING of this project, refused to discuss that HERO was to pay PETERSEN DEAN after removal of the solar panels and repairs. 

You did not “communicate”. You only sought to advance your agenda and had no interest in genuine communication. Your agenda was to keep the case as narrow as possible, exclude the HERO FINANCING and push me prematurely into a settlement conference that would require me to go in to it accepting life crippling losses for both me and my very injured autistic son. 

Your client has drastically and permanently altered James Marshall’s life with the deliberate stress your client warned me we would find unbearable, unimaginable. Petersen Dean employees said in 2016, while bargaining to get me to sign off prematurely and falsely with HERO FINANCING that the job was done and the price was acceptable. Petersen Dean men warned me what would happen if I did not sign those documents in 2016. The only bargaining chip they could find was my flesh and blood, my only child and they used his name and his health status in the specific threat. If this is not mafia / mobster style, what is? I was reminded that they knew James had a rough year in 2016 but he would suffer unimaginable stress if I did not sign off with HERO even though HERO instructed me NOT to sign off yet. HERO agreed with the solution of removing the solar panels after HR BLOCK confirmed I would not get a $10,000+ tax credit. Your client tried to bully me into a suicidal solution. Petersen Dean men and George Milionis tried to force me to sign a document they knew and I knew to be false. George Milionis ORDERED me to sign the false and incorrect document. 

Have you heard of the novel / Meryl Streep movie: SOPHIE’S CHOICE? Here is the main plot: 

“Sophie and Stingo flee to a hotel. She reveals to him that, upon arrival at Auschwitz, she was forced to choose which one of her two children would be gassed and which would proceed to the labor camp. To avoid having both children killed, she chose her son, Jan, to be sent to the children's camp, and her daughter, Eva, to be sent to her death.”

Your client blatantly gave me a “SOPHIE’S CHOICE”. George Milionis was shameless, fearless, as if no one would every find out that he cornered us and treated us like trapped animals and ORDERED me to choose who would destroy my son, him or HERO. He ordered me to sign off with HERO even though HERO and HR BLOCK, the San Pedro Police Department, Building & Safety and everyone told about it said do not sign off yet. George Milionis ORDERED me to sign an untrue document. George Milionis only gave the the choice of WHO would take our home away from us, him or HERO. He put his demand in writing as well as having PETERSEN DEAN goons make the threats over the phone with constant requests to meet me alone at the work site to “refresh” my thinking. Maybe this is not mobster like to you, but it is mobster like behavior as far as normal society is concerned. I do not know anyone who thinks this is normal business practices. Normal business don’t operate this way. HERO went into hiding after George Milionis started bullying me and ordering me to violate HERO rules. 

The FBI field officer asked me what HERO said or put in writing before disappearing like that. HERO just disappeared without a word of explanation. George Milionis will probably make something up before we go to trial, but there is NOTHING, not a word of explanation from HERO all of 2017 to date. Financing disappearing without a trace is mobster like. How is it NOT mobster like for the financing of a project to just suddenly disappear without a trace, as if it never was there after George Milionis decides the HERO rules do not apply to him and PETERSEN DEAN? 

I could not sign those false documents even with the blatant threats directly aimed at my son James ( which is WHY I called your client thug like and mafia like even though you don’t like those terms). If I signed those documents I would have been agreeing to allow HERO FINANCING to foreclose on our home in 2017 or early 2018 by agreeing to what HR BLOCK confirmed to be a tax credit scam. 

Your client gave us, in no uncertain terms, in writing, a COMMAND, a life destroying “SOPHIE’S CHOICE”. I was  ORDERED like a dog by your client to obey and forget what HR BLOCK confirmed and just accept HERO would take our home a year after the signing when the tax scam hit or accept MECHANICS LIENS would be put on our home and George Milionis would take our home. Your client ordered me to obey the way dogs are ordered to obey.

I was only given the choice as to WHO would make us homeless. I was told if I fought to save our home I would fail and only make it worse for my son, that it was beyond imagination what George Milionis would put us through. 

The unimaginable misery has changed my son. He cries out nonstop like an animal chewing off his own foot in a bear trap. He howls in agony because his world was taken away from him. George Milionis knew what would happen if he did this to an autistic person. He had his good cop bad cop goons, Kyle Smith and other men from Petersen Dean spell it out to me in case I was as addled by age as his salesman Dave Shanholtzer implied I was. They said my son’s name, they acknowledged James was sick and they said it would get worse for James if I did not sign the papers George Milionis ORDERED me to sign stating the job was finished when it wasn’t and that I approved of the price when it was suicidal to do so. AFTER I signed that I was completely satisfied, then I would be given $2000 that I could use towards over $6000 in repairs and unfinished work. I was ORDERED to sign, like I was George Milionis ‘s prisoner. My son was used as a bargaining chip by every Petersen Dean man who called me to “refresh my thinking”. How on earth is this NOT mobster like? 

ANSWER TO COMPLAINT:

https://1drv.ms/w/s!AmDCAdjIw9lXrgJWLgzXsw3FQWLs

Sincerely, 

Jennifer Marshall 

PS: Unfortunately James only slept briefly and woke screaming again. I will have to type the CASE MANAGEMENT STATEMENT very fast, in installments as I tend him. 

James’s doctors rightfully maintain James deserves 100% of my attention as his care-provider. I beg the court for more time to hire an attorney. CAS