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2-25-2007

The State Bar of California
1149 South Hill Street
Los Angeles, California 90015-2299

Eric R. McClendon,

Complaint Analyst

RE: Inquiry Number 07-10624

Respondent: Ted Eugene Richards,

I filed my first worker compensation case #144733 in 2-88 and a Serious and Willful in 2-89 working for Kaiser Foundation Hospital and then TPMG-Kaiser clinic with subsequent cases 223817-227450-254463. There were more DWC-1's filled out between 1990-1992 for other injuries but TPMG did not process them lawfully. I had several worker comp hearings regarding the Serious & Willful in 2005 in front of the WCAB Judge Esther Volkan, 2424 Arden Wy, Sacramento California 95812.

Ted Eugene Richards filed a Motion to have penalties and sanctions filed against me and Judge Volkan said she would penalize and sanction for me wanting to go forward for my Serious and Willful Trial until I finally told her that I needed all of my records which have not been to given thus far.

The last hearing I explained to Judge Volkan that I had not been given ALL of my records during my trial of 2000 on all the above cases as promised by TPMG-Kaiser defense attorney Michael Powers and Ted Richards.

From the beginning of my filing of my worker comp cases and an employment civil suit vs Kaiser and TPMG I come to discover that not all of my records were given to me in my worker comp OR civil suit cases.

Since the last worker comp hearing I have requested ALL of my records to go forward to my Serious & Willful Trial.

Ted Eugene Richards stated at the last hearing in 2005 he would go after me for Penalties & Sanctions to go forward with my Serious & Willful trial.

I would like justification as to why my property-records can be withheld by attorney Ted Richards and production of sound reason with no sound reason must be justified.

I have made numerous attempts by court appearance, email, phone calls and a visit to Ted Richards office-witness Cathon-Rhoades-adams. At this meeting 3-08-2006, Ted Richards had substantial records at this visit but failed to show all but two pages and did not attempt to give me copies.

I have attempted to subsequently get these properties/all my records and Ted Richards stated in 6-2006 that Kaiser would not give them to him and he said during a phone call that I would have to file a DOR-Declaration of Readiness to get the records. My last phone call to him was in 8-2006 and Ted Richard said he would get my records after Labor Day 2006. I have not heard from him since. I have been the one to pursue him to get my properties/records. Ted Richards has been retained by Kaiser Foundation Hospital Plan and Michael Powers for TPMG had failed to bring these properties/records to my 2000 Workers’ Compensation Appeals Board Trial and is thus preventing me from going forward to my Serious & Willful Trial by not giving me all of my properties/records.

Rule 5-220-Suppression of Evidence

Included will be a copy of an email to Ted Richards and copies and 2 WCAB *hearing dates set in 2005. Because of hardship at this time I am unable to go to the WCAB on 2424 Arden Way, Sacramento, Ca. 95812 to copy the last hearing date and Ted Richards Motion for penalties and sanctions if I go forward to my Serious & Willful Trial


Sincerely,

Dina Padilla

cc'd COPIES VIA CERTIFIED AND REG US. MAIL TO BELOW,
U.S. ATTORNEY DIRECTOR OF THE  AG OFFICE  &
U.S. AG OFFICE-ATTENTION PHILLIP KEARNEY, BOTH AT 450 GOLDEN GATE AVE,  11TH FLR. SAN FRANCISCO, CA.94102
CBA DIRECTOR- SHELDON SLOAN, 1149 SOUTH HILL RD., LOS ANGELES, CA.90015-2299






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