Case No. D-504-CV-202300223
Re: Case No. D-504-CV-202300223
STATE OF NEW MEXICO
COUNTY OF CHAVES
FIFTH JUDICIAL DISTRICT COURT
Chase Xander
4 Krenzell Rd.
Dexter NM 88230
plaintiff,
vs. Case No.
AMERICAN MEDICAL RESPONSE AMBULANCE SERVICE, INC.
123 EAST MARCY ST., SUITE 101,
Santa Fe, NM 87501
EASTERN NEW MEXICO MEDICAL CENTER INC.
405 W Country Club Rd,
Roswell, NM 88201
defendants,
COMPLAINT FOR MALPRACTICE HARASSMENT BATTERY AND
DISCRIMINATION RESULTING IN PERSONAL AND EMOTIONAL INJURY
STATEMENT OF CLAIM
Your Honor, I the plaintiff Chase Xander acting as pro se, bring this matter to your court.
JURISDICTION
This is the correct jurisdiction because all counts of this complaint physically occurred in the
county of Chaves NM or from the Roswell NM offices of the defendants which is in the
jurisdiction of this district court.
This is also the correct jurisdiction because the damages are over $10,000.00
FACTS
1
That this action is being brought under both the New Mexico Personal Injury and New Mexico
Statutes governing actions involving medical malpractice and violations of 2016 New Mexico
Statutes
Chapter 59A - Insurance Code Article 57 - Patient Protection.
That Defendants Eastern New Mexico Medical Center hereby to be named as ENMMC and
American Medical Response Ambulance Service hereby to be named AMR are New Mexico
corporations providing medical services to the citizens of New Mexico, including Chase
Xander, with their places of businesses located at ENMMC
Chase Xander was a patient and a client of ENMMC and EMR at the time of the actions listed
in this complaint.
That at all times relevant, the Defendants employed various medical providers, EMT’s, nurses
and medical staff, when they rendered and failed to render medical care to the Plaintiff Chase
Xander.
They failed to follow the applicable standard of medical care during their care and treatment of
the plaintiff Chase Xander which proximately resulted in physical and emotional injury to
Chase Xander resulting in permanent injury.
The Chaves County District court is the right venue and jurisdiction for this case because of the
nature of this case to include medical malpractice.
2
That the acts of medical malpractice leading to the injury of Chase Xander occurred on or
around March 8th 2022, when I caught covid and EMR responded to my house. And on or
around August 7th 2022, when EMR responded and I received medical service at ENMMC.
That the standard of medical care applicable to Defendant for the medical care and treatment it
provided to Chase Xander included: 1) on or about March 8th 2022 when I had covid and AMR
responded to my home, I was given orders by the emt that was discriminating by refusing to
come inside my room to provide care and demanded that I go outside to my porch. After
complying with the discriminating demand I was refused service. I was also unable to take the
ambulance to the hospital because as shown by the August 7th incident I knew ENMMC would
not follow protocol and I would be left over 20 miles from my home with no way to get home.
2) On the incident on or around August 7th I was in need of emergency medical service. AMR
responded and took me to the hospital. On the way the female EMT on AMR’s ambulance
threatened to ‘punch me in the face’ multiple times. 3) After being treated at ENMMC the
nurse Greg demanded I leave the hospital immediately or he would call security. He did not
allow me time to dress or get my items out of the hospital and as always refused to follow the
hospital’s protocol when discharging patients which is to call their insurance company to tell
them the patient was discharged so that transportation could be arranged.
I will also be providing documents to prove this has been a pattern of practice from both
defendants for over a decade.
That as a direct and proximate result of the Defendant’s failure to provide the proper medical
care mentioned in paragraph number above, and by breaching the applicable standard of
medical care owed to Chase Xander, by and through its employees/servants, Chase Xander was
left with out a care giver for the most part of the year and have suffered mentally and physically
because of it.
That all of the injuries and damages sustained by Chase Xander resulted from the negligent
actions and breaches of the applicable standards of medical care by the Defendants by and
through its employees and agents, without any act or omission on the part of the Chase Xander,
or on the part of any of the Plaintiffs herein, directly thereunto contributing.
That as a direct and proximate result of the negligent actions and breaches of the applicable
standards of medical care by Defendant, Chase Xander suffered physical injuries, conscious
pain and suffering, and other damages.
COUNT I: Medical Malpractice/Negligence
COUNT II: Discrimination
COUNT III: Harassment and Battery
The Plaintiffs re-allege and incorporate by reference herein all of the allegations contained in
paragraphs 20-55 above.
That on or about March 8th 2022, and thereafter, the Defendants by and through their
employees/servant/agents breached the applicable standard of medical care owed to Chase
Xander, which directly caused physical and emotional injury which is ongoing.
That as a direct result of the negligence and breaches of the applicable standard of medical care
by the Defendant, by and through its nurses, employees, and medical staff, resulting in ongoing
physical and emotional damage to Chase Xander.
WHEREFORE:
The Plaintiff Chase Xander asks the court to impose an immediate emergency injunction on
both Defendants requiring them to provide the medical standard of care required by their
practice and to refrain from all discrimination, harassment and battery in the future.
To award the Plaintiff $250,000.00 from each of the defendants ENMMC and AMR for the
pain and suffering and humiliation suffered.
To award the plaintiff $10,000.00 as per the patient protection act from each defendant for each
of the 3 causes of injury.
Respectfully submitted,
Chase Xander
/ s/ Chase Xander
Pro Se
COUNTY OF CHAVES
FIFTH JUDICIAL DISTRICT COURT
Chase Xander
4 Krenzell Rd.
Dexter NM 88230
plaintiff,
vs. Case No.
AMERICAN MEDICAL RESPONSE AMBULANCE SERVICE, INC.
123 EAST MARCY ST., SUITE 101,
Santa Fe, NM 87501
EASTERN NEW MEXICO MEDICAL CENTER INC.
405 W Country Club Rd,
Roswell, NM 88201
defendants,
COMPLAINT FOR MALPRACTICE HARASSMENT BATTERY AND
DISCRIMINATION RESULTING IN PERSONAL AND EMOTIONAL INJURY
STATEMENT OF CLAIM
Your Honor, I the plaintiff Chase Xander acting as pro se, bring this matter to your court.
JURISDICTION
This is the correct jurisdiction because all counts of this complaint physically occurred in the
county of Chaves NM or from the Roswell NM offices of the defendants which is in the
jurisdiction of this district court.
This is also the correct jurisdiction because the damages are over $10,000.00
FACTS
1
That this action is being brought under both the New Mexico Personal Injury and New Mexico
Statutes governing actions involving medical malpractice and violations of 2016 New Mexico
Statutes
Chapter 59A - Insurance Code Article 57 - Patient Protection.
That Defendants Eastern New Mexico Medical Center hereby to be named as ENMMC and
American Medical Response Ambulance Service hereby to be named AMR are New Mexico
corporations providing medical services to the citizens of New Mexico, including Chase
Xander, with their places of businesses located at ENMMC
Chase Xander was a patient and a client of ENMMC and EMR at the time of the actions listed
in this complaint.
That at all times relevant, the Defendants employed various medical providers, EMT’s, nurses
and medical staff, when they rendered and failed to render medical care to the Plaintiff Chase
Xander.
They failed to follow the applicable standard of medical care during their care and treatment of
the plaintiff Chase Xander which proximately resulted in physical and emotional injury to
Chase Xander resulting in permanent injury.
The Chaves County District court is the right venue and jurisdiction for this case because of the
nature of this case to include medical malpractice.
2
That the acts of medical malpractice leading to the injury of Chase Xander occurred on or
around March 8th 2022, when I caught covid and EMR responded to my house. And on or
around August 7th 2022, when EMR responded and I received medical service at ENMMC.
That the standard of medical care applicable to Defendant for the medical care and treatment it
provided to Chase Xander included: 1) on or about March 8th 2022 when I had covid and AMR
responded to my home, I was given orders by the emt that was discriminating by refusing to
come inside my room to provide care and demanded that I go outside to my porch. After
complying with the discriminating demand I was refused service. I was also unable to take the
ambulance to the hospital because as shown by the August 7th incident I knew ENMMC would
not follow protocol and I would be left over 20 miles from my home with no way to get home.
2) On the incident on or around August 7th I was in need of emergency medical service. AMR
responded and took me to the hospital. On the way the female EMT on AMR’s ambulance
threatened to ‘punch me in the face’ multiple times. 3) After being treated at ENMMC the
nurse Greg demanded I leave the hospital immediately or he would call security. He did not
allow me time to dress or get my items out of the hospital and as always refused to follow the
hospital’s protocol when discharging patients which is to call their insurance company to tell
them the patient was discharged so that transportation could be arranged.
I will also be providing documents to prove this has been a pattern of practice from both
defendants for over a decade.
That as a direct and proximate result of the Defendant’s failure to provide the proper medical
care mentioned in paragraph number above, and by breaching the applicable standard of
medical care owed to Chase Xander, by and through its employees/servants, Chase Xander was
left with out a care giver for the most part of the year and have suffered mentally and physically
because of it.
That all of the injuries and damages sustained by Chase Xander resulted from the negligent
actions and breaches of the applicable standards of medical care by the Defendants by and
through its employees and agents, without any act or omission on the part of the Chase Xander,
or on the part of any of the Plaintiffs herein, directly thereunto contributing.
That as a direct and proximate result of the negligent actions and breaches of the applicable
standards of medical care by Defendant, Chase Xander suffered physical injuries, conscious
pain and suffering, and other damages.
COUNT I: Medical Malpractice/Negligence
COUNT II: Discrimination
COUNT III: Harassment and Battery
The Plaintiffs re-allege and incorporate by reference herein all of the allegations contained in
paragraphs 20-55 above.
That on or about March 8th 2022, and thereafter, the Defendants by and through their
employees/servant/agents breached the applicable standard of medical care owed to Chase
Xander, which directly caused physical and emotional injury which is ongoing.
That as a direct result of the negligence and breaches of the applicable standard of medical care
by the Defendant, by and through its nurses, employees, and medical staff, resulting in ongoing
physical and emotional damage to Chase Xander.
WHEREFORE:
The Plaintiff Chase Xander asks the court to impose an immediate emergency injunction on
both Defendants requiring them to provide the medical standard of care required by their
practice and to refrain from all discrimination, harassment and battery in the future.
To award the Plaintiff $250,000.00 from each of the defendants ENMMC and AMR for the
pain and suffering and humiliation suffered.
To award the plaintiff $10,000.00 as per the patient protection act from each defendant for each
of the 3 causes of injury.
Respectfully submitted,
Chase Xander
/ s/ Chase Xander
Pro Se
Re: Case No. D-504-CV-202300223
But the judge gave me an extension to amend along with one chance to not piss him off again 
while ruling in my favor of course. That entire court was a traumatic experience. I am just calming down.
while ruling in my favor of course. That entire court was a traumatic experience. I am just calming down.Re: Case No. D-504-CV-202300223
That also came with an order of decorum to me Oo don't worry judge i know fancy legal words and have zero intention of ever ever making you mad again if i can help it
Re: Case No. D-504-CV-202300223
1. STATE OF NEW MEXICO
2. COUNTY OF CHAVES
3. FIFTH JUDICIAL DISTRICT COURT
4.
5. Chase Xander
8. plaintiff,
9.
10. vs. Case No. D-504-CV-2023-00223
11.
12. CORPORATE SERVICE COMPANY aka
13. AMERICAN MEDICAL RESPONSE AMBULANCE SERVICE, INC.
14. formerly known as Superior Ambulance
15. 111 East Broadway,
16. Hobbs, NM 88240
ROSWELL HOSPITAL CORPORATION aka
17. EASTERN NEW MEXICO MEDICAL CENTER INC.
18. 405 W Country Club Rd,
19. Roswell, NM 88201
20. defendants,
21.
22. AMENDED COMPLAINT FOR MALPRACTICE/NEGLIGENCE/MISCONDUCT
23.
24.
25. STATEMENT OF CLAIM
26.
27. Your Honor, I the plaintiff Chase Xander acting as pro se, bring this matter to your court.
28.
29. JURISDICTION
30. This is the correct jurisdiction because all counts of this complaint physically occurred in the
31. county of Chaves NM or from the Roswell NM offices of each of the defendants which is in the
32. jurisdiction of this district court.
33.
34. This is also the correct jurisdiction because the damages are over $10,000.00
35.
36. That this action is being brought under both the New Mexico Personal Injury and New Mexico
37. Statutes governing actions involving medical malpractice and violations of 2016 New Mexico
38. Statutes Chapter 59A - Insurance Code Article 57 - Patient Protection. ‘In New Mexico, you may bring a medical malpractice lawsuit for an injury you suffered against a licensed healthcare provider based upon their negligence, misconduct, errors or omissions, or breach of contract in the rendering of healthcare, medical services, nursing services or other health-related services.’
39.
40. That Defendants of ROSWELL HOSPITAL CORPORATION aka EASTERN NEW MEXICO MEDICAL CENTER INC. hereby to be named as ENMMC and CORPORATE SERVICE COMPANY aka American Medical Response Ambulance Service INC formerly know as Superior Ambulance hereby to be named AMR are New Mexico corporations providing medical services to the citizens of New Mexico, including Chase Xander, with their places of businesses located at ENMMC
41.
42. Chase Xander was a patient and a client of ENMMC and AMR at the time of the actions listed
43. in this complaint.
44.
45. That at all times relevant, the Defendants employed various medical providers, EMT’s, nurses
46. and medical staff, when they had a duty to rendered and failed to render medical care to the Plaintiff Chase Xander.
47.
48. They failed to follow the applicable standard of medical care during their care and treatment of
49. the plaintiff Chase Xander which proximately resulted in physical and emotional injury to
50. Chase Xander resulting in permanent injury.
51. The Chaves County District court is the right venue and jurisdiction for this case because of the
52. nature of this case to include medical malpractice.
53.
54. PATTERN OF PRACTICE OF NEGLIGENCE AND MISCONDUCT
55. Judge Hudson, from 2007 until 2020 I was a competitive gamer on MMORP and strategy games. It is a very hard industry on females, they always get harassed and sexually assaulted. I made sure I never gave any information on myself not my gender not my real life situation family etc, the only information I gave was that I was old as dirt.
56.
57. Around 2012 the gaming forum I was part of ‘tribal wars’ from innogames found out I was female and found out I had one daughter they did not find out I had other children. The employees and agents of innogames started stalking my daughter passing out her picture threatening to rape and kill her, and that is when I started teaching myself law because no attorney would take the international case without a huge down payment. As seen in case D-504-CV-201600293.
58.
59. Since I was unable to get legal help I tried reporting the felonies that were happening to me to the authorities.
60.
61. The authorities including the defendants participated in counts of Federal Case No. 2:16-CV-01402-GBW-SMV I settled out of court with the sheriffs. The defendants of AMR formerly known as superior ambulance were present and participated in the damages and have participated in this behavior for the last 10 years. Creating a hostile medical environment that has put my life in serious danger for the last 10 or more year.
62.
63. When I tried to report the felonies to the sheriffs they thought it was hilarious that someone as poor and neruodivergent as me could possibly be involved in a multi million dollar corporation who was committing criminal activity against me and my family. So the sheriffs/deputies/emts mocked and made fun of me, falsely arrested and detained me on multiple occasions. And took me to ENMMC by ambulance or sheriff on NUMEROUS occasions where I was falsely detained because the sheriffs told medical I was crazy. And I was illegally held and falsely detained in the sunrise unit of ENMMC multiple times and abused by certain EMT’s from AMR formally known as superior ambulance, as well.
64.
65. Together all authorities abused me for years because I have no witnesses and they thought I could never do a legal thing about it. The abuse misconduct and negligence I have suffered at the hands of both defendants has had a severe and chronic effect on my health, and puts my life in danger to this day.
66.
67. Once I was able to settle the federal case, the sheriffs and law enforcement have stopped their abuse for the most part but the defendants never have. I have tried to settle this out of court since before 2017 with ENMMC and AMR has refused contact. Therefore the only way to stop the abuse is in your courtroom. See Exhibit 1
68. 2
69. FACTS COMMON TO ALL COUNTS
70. That the acts of medical malpractice leading to the injury of Chase Xander occurred on or
71. around March 8th 2022, when I caught covid and EMR responded to my house. And on or
72. around August 7th 2022, when EMR responded and I received medical service at ENMMC.
73.
74. That the standard of medical care applicable to Defendant for the medical care and treatment it
75. provided to Chase Xander included:
76.
77. 1) on or about March 8th 2022 when I had covid and AMR (SEE EXHIBIT 2 a lapel cam footage from the sheriffs easily accessible to council as I put in a demand for preservation shortly after the incident.)
78. responded to my home, I was given orders by the emt Jon Doe (to be named in a future complaint) that was discriminating by refusing to
79. come inside my room to provide care and demanded that I go outside to my porch. After
80. complying with the discriminating demand I was refused service. I was also unable to take the
81. ambulance to the hospital because as shown by the August 7th incident I knew ENMMC would
82. not follow protocol and I would be left over in a town I don’t even live in 20 miles from my house with no way to get home.
83.
84. 2) On the incident on or around August 7th I was in need of emergency medical service. AMR the ambulance service paid for by my insurance responded and took me to the hospital. On the way the female EMT Jane Doe (to be named on a future complaint) on AMR’s ambulance said she wanted to ‘punch me in the face’ multiple times. Upon arrival at the hospital I told the nurses of ENMMC what happened, which in misconduct and negligently they probably did not take down the information.
85.
86. In response to AMR submitting my medical records without a release. The defendants AMR are lying to the court- I am a 55 year old disable woman who can barley walk down my porch have never once been violent to any medical service worker as proven by the fact I have never been arrested for any such a thing and the sheriffs are OVERLY present on any call for an ambulance to my house. SEE Federal Case No. 2:16-CV-01402-GBW-SMV as as testament to the defendants misconduct, Also at the time of the incident I was barely surviving my heart rate and blood pressure were at critical limits medical records will show this.
87. After being improperly diagnosed by Dr Doe, ENMMC who is covered and paid by my insurance company, the nurse Greg Doe (to be named in a future complaint) demanded I leave the hospital immediately or he would call security. He did not allow me time to dress or get my items out of the hospital and as always refused to follow the hospital’s protocol when discharging patients which is to call their insurance company to tell them the patient was discharged so that transportation could be arranged. Greg Doe’s misconduct was intentional and or negligent. As a patient I am not able to tell my insurance I was discharged, this needs to come from the hospital itself. And when in sunrise unit of ENMMC after discharge no patients are allowed to leave until arrangements are made BY ENMMC with your insurance company if you have no other ride home. And either it is their protocol or every time I was in sunrise I was detained illegally waiting for ride arrangements to be made.
88.
89. 3) That together both defendants conspired intentionally and or negligently to create a hostile medical condition that put my life in danger. AMR refused to treat me at my home for any condition including covid, and I was unable to take an ambulance to the hospital or be discharged in a town I don’t even live in 30ish miles home. That both defendants had Proximate cause to realize such negligence would result in named harm.
90.
91. That on each count the defendants named had (1) a professional duty owed to the patient; (2) breach of such duty; (3) injury caused by the breach; and (4) resulting damages to be proven at trail.
92.
93. That all of the injuries and damages sustained by Chase Xander resulted from the negligent actions and breaches of the applicable standards of medical care by the Defendants by and through its employees and agents, without any act or omission on the part of the Chase Xander, or on the part of any of the Plaintiffs herein, directly thereunto contributing.
That as a direct and proximate result of the negligent actions and breaches of the applicable
94. standards of medical care by Defendant, Chase Xander suffered physical injuries, conscious
95. pain and suffering, and other damages.
96.
97. COUNT I: Medical Malpractice/Negligence/Misconduct AMR
The Plaintiffs re-allege and incorporate by reference herein all of the allegations contained in lines 75-81 That the Defendants by and through their employees/servant/agents breached the applicable standard of medical care owed to Chase Xander, which directly caused physical and emotional injury which is ongoing. That as a direct result of the negligence and breaches of the applicable standard of medical care by the Defendant, by and through its nurses, employees, and medical staff, resulting in ongoing physical and emotional damage to Chase Xander. And that damages will be proven by medical records during discovery.
WHEREFORE, the Plaintiff claims monetary damages against AMR individually in an amount to claimed below, plus costs, legal fees at $200. per hour for doing the work of an entire legal team, and for any further relief that this Honorable Court determines necessary and appropriate.
98.
99. COUNT II: Medical Malpractice/Negligence/Misconduct AMR and ENMMC
The Plaintiffs re-allege and incorporate by reference herein all of the allegations contained in lines 82-86 the Defendants by and through their employees/servant/agents breached the applicable standard of medical care owed to Chase Xander, which directly caused physical and emotional injury which is ongoing. That as a direct result of the negligence and breaches of the applicable standard of medical care by the Defendant, by and through its nurses, employees, and medical staff, resulting in ongoing physical and emotional damage to Chase Xander. And that damages will be proven by medical records during discovery. That as a direct result of the negligence and breaches of the applicable standard of medical care by the Defendant, by and through its nurses, employees, and medical staff, resulting in ongoing physical and emotional damage to Chase Xander. And that damages will be proven by medical records during discovery.
WHEREFORE, the Plaintiff claims monetary damages against AMR and ENMMC individually in an amount to claimed below, plus costs, legal fees at $200. per hour for doing the work of an entire legal team, and for any further relief that this Honorable Court determines necessary and appropriate.
100. COUNT III: Medical Malpractice/Negligence/Misconduct AMR and ENMMC
101. The Plaintiffs re-allege and incorporate by reference herein all of the allegations contained in lines 87-88 That the Defendants by and through their employees/servant/agents breached the applicable standard of medical care owed to Chase Xander, which directly caused physical and emotional injury which is ongoing. That as a direct result of the negligence and breaches of the applicable standard of medical care by the Defendant, by and through its nurses, employees, and medical staff, resulting in ongoing physical and emotional damage to Chase Xander. And that damages will be proven by medical records during discovery. The medical care I received was Below standard care and I was battered by ENMMC employee Nurse Greg Doe. Battery does not have to be a physical assault as long as the actions resulted in physical injury which it did. Universal Citation: NM Stat § 30-3-4 (2021) Battery is the unlawful, intentional touching or application of force to the person of another, when done in a rude, insolent or angry manner. Whoever commits battery is guilty of a petty misdemeanor. (greg doe forcefully demanded I leave and threatened me and my property resulting in physical and emotional injury)
102. WHEREFORE, the Plaintiff claims monetary damages against AMR and ENMMC individually in an amount to claimed below, plus costs, legal fees at $200. per hour for doing the work of an entire legal team, and for any further relief that this Honorable Court determines necessary and appropriate.
103.
104. WHEREFORE:
105. 1. The Plaintiff Chase Xander asks the court to impose an immediate emergency injunction on both Defendants requiring them to provide the medical standard of care required by their practice and to refrain from all discrimination, harassment and battery in the future.
106.
107. 2. To award the Plaintiff $250,000.00 from each of the defendants ENMMC and AMR for the pain, suffering and humiliation inflicted. Intentional and or neglectful infliction of physical and mental pain.
108.
109. 3. To award the plaintiff $10,000.00 as per the patient protection act from each defendant for each of the 3 causes of injury.
110.
4. To award plaintiff a fair rate for legal fees and costs.
111.
5. For a Judicial order for a lie detector test given to me and handled through indigent where I can pay the court back. This will be required because on most occasions I was alone and the defense has already proven they are willing to lie or commit federal crimes by breach of hippa and tampering with mail.
112.
113. Appendage: My informal pronouns are any, but since I have to be formal my pronouns are ze/zir.
114. Your Honor, I will be asking for accommodations for the SEVERE emotional disabilities I have. I do not expect this to be a get out of jail free card, I can and will behave appropriately in and out of your court. But the facts are that I am SEVERELY and LIFE THREATENINGLY disabled and neurodivergent. As seen by councils telling the court I said ‘what a rush’. I will respond neurodivergently on occasion, and if I am in a flashback, I have little control over what I say (that will not happen). I hope the court and council would read the symptoms of Post Traumatic Stress Disorder from the mayo clinic- https://www.mayoclinic.org/diseases-con ... c-20355967 and for council and the court to take my disability which can be life threatening for me, into consideration. So far the only special needs I have asked from the court is telephonic hearings. To prevent panic attacks.
115.
116.
117. Respectfully submitted,
118. Chase Xander
119. / s/ Chase Xander
120. Pro Se
2. COUNTY OF CHAVES
3. FIFTH JUDICIAL DISTRICT COURT
4.
5. Chase Xander
8. plaintiff,
9.
10. vs. Case No. D-504-CV-2023-00223
11.
12. CORPORATE SERVICE COMPANY aka
13. AMERICAN MEDICAL RESPONSE AMBULANCE SERVICE, INC.
14. formerly known as Superior Ambulance
15. 111 East Broadway,
16. Hobbs, NM 88240
ROSWELL HOSPITAL CORPORATION aka
17. EASTERN NEW MEXICO MEDICAL CENTER INC.
18. 405 W Country Club Rd,
19. Roswell, NM 88201
20. defendants,
21.
22. AMENDED COMPLAINT FOR MALPRACTICE/NEGLIGENCE/MISCONDUCT
23.
24.
25. STATEMENT OF CLAIM
26.
27. Your Honor, I the plaintiff Chase Xander acting as pro se, bring this matter to your court.
28.
29. JURISDICTION
30. This is the correct jurisdiction because all counts of this complaint physically occurred in the
31. county of Chaves NM or from the Roswell NM offices of each of the defendants which is in the
32. jurisdiction of this district court.
33.
34. This is also the correct jurisdiction because the damages are over $10,000.00
35.
36. That this action is being brought under both the New Mexico Personal Injury and New Mexico
37. Statutes governing actions involving medical malpractice and violations of 2016 New Mexico
38. Statutes Chapter 59A - Insurance Code Article 57 - Patient Protection. ‘In New Mexico, you may bring a medical malpractice lawsuit for an injury you suffered against a licensed healthcare provider based upon their negligence, misconduct, errors or omissions, or breach of contract in the rendering of healthcare, medical services, nursing services or other health-related services.’
39.
40. That Defendants of ROSWELL HOSPITAL CORPORATION aka EASTERN NEW MEXICO MEDICAL CENTER INC. hereby to be named as ENMMC and CORPORATE SERVICE COMPANY aka American Medical Response Ambulance Service INC formerly know as Superior Ambulance hereby to be named AMR are New Mexico corporations providing medical services to the citizens of New Mexico, including Chase Xander, with their places of businesses located at ENMMC
41.
42. Chase Xander was a patient and a client of ENMMC and AMR at the time of the actions listed
43. in this complaint.
44.
45. That at all times relevant, the Defendants employed various medical providers, EMT’s, nurses
46. and medical staff, when they had a duty to rendered and failed to render medical care to the Plaintiff Chase Xander.
47.
48. They failed to follow the applicable standard of medical care during their care and treatment of
49. the plaintiff Chase Xander which proximately resulted in physical and emotional injury to
50. Chase Xander resulting in permanent injury.
51. The Chaves County District court is the right venue and jurisdiction for this case because of the
52. nature of this case to include medical malpractice.
53.
54. PATTERN OF PRACTICE OF NEGLIGENCE AND MISCONDUCT
55. Judge Hudson, from 2007 until 2020 I was a competitive gamer on MMORP and strategy games. It is a very hard industry on females, they always get harassed and sexually assaulted. I made sure I never gave any information on myself not my gender not my real life situation family etc, the only information I gave was that I was old as dirt.
56.
57. Around 2012 the gaming forum I was part of ‘tribal wars’ from innogames found out I was female and found out I had one daughter they did not find out I had other children. The employees and agents of innogames started stalking my daughter passing out her picture threatening to rape and kill her, and that is when I started teaching myself law because no attorney would take the international case without a huge down payment. As seen in case D-504-CV-201600293.
58.
59. Since I was unable to get legal help I tried reporting the felonies that were happening to me to the authorities.
60.
61. The authorities including the defendants participated in counts of Federal Case No. 2:16-CV-01402-GBW-SMV I settled out of court with the sheriffs. The defendants of AMR formerly known as superior ambulance were present and participated in the damages and have participated in this behavior for the last 10 years. Creating a hostile medical environment that has put my life in serious danger for the last 10 or more year.
62.
63. When I tried to report the felonies to the sheriffs they thought it was hilarious that someone as poor and neruodivergent as me could possibly be involved in a multi million dollar corporation who was committing criminal activity against me and my family. So the sheriffs/deputies/emts mocked and made fun of me, falsely arrested and detained me on multiple occasions. And took me to ENMMC by ambulance or sheriff on NUMEROUS occasions where I was falsely detained because the sheriffs told medical I was crazy. And I was illegally held and falsely detained in the sunrise unit of ENMMC multiple times and abused by certain EMT’s from AMR formally known as superior ambulance, as well.
64.
65. Together all authorities abused me for years because I have no witnesses and they thought I could never do a legal thing about it. The abuse misconduct and negligence I have suffered at the hands of both defendants has had a severe and chronic effect on my health, and puts my life in danger to this day.
66.
67. Once I was able to settle the federal case, the sheriffs and law enforcement have stopped their abuse for the most part but the defendants never have. I have tried to settle this out of court since before 2017 with ENMMC and AMR has refused contact. Therefore the only way to stop the abuse is in your courtroom. See Exhibit 1
68. 2
69. FACTS COMMON TO ALL COUNTS
70. That the acts of medical malpractice leading to the injury of Chase Xander occurred on or
71. around March 8th 2022, when I caught covid and EMR responded to my house. And on or
72. around August 7th 2022, when EMR responded and I received medical service at ENMMC.
73.
74. That the standard of medical care applicable to Defendant for the medical care and treatment it
75. provided to Chase Xander included:
76.
77. 1) on or about March 8th 2022 when I had covid and AMR (SEE EXHIBIT 2 a lapel cam footage from the sheriffs easily accessible to council as I put in a demand for preservation shortly after the incident.)
78. responded to my home, I was given orders by the emt Jon Doe (to be named in a future complaint) that was discriminating by refusing to
79. come inside my room to provide care and demanded that I go outside to my porch. After
80. complying with the discriminating demand I was refused service. I was also unable to take the
81. ambulance to the hospital because as shown by the August 7th incident I knew ENMMC would
82. not follow protocol and I would be left over in a town I don’t even live in 20 miles from my house with no way to get home.
83.
84. 2) On the incident on or around August 7th I was in need of emergency medical service. AMR the ambulance service paid for by my insurance responded and took me to the hospital. On the way the female EMT Jane Doe (to be named on a future complaint) on AMR’s ambulance said she wanted to ‘punch me in the face’ multiple times. Upon arrival at the hospital I told the nurses of ENMMC what happened, which in misconduct and negligently they probably did not take down the information.
85.
86. In response to AMR submitting my medical records without a release. The defendants AMR are lying to the court- I am a 55 year old disable woman who can barley walk down my porch have never once been violent to any medical service worker as proven by the fact I have never been arrested for any such a thing and the sheriffs are OVERLY present on any call for an ambulance to my house. SEE Federal Case No. 2:16-CV-01402-GBW-SMV as as testament to the defendants misconduct, Also at the time of the incident I was barely surviving my heart rate and blood pressure were at critical limits medical records will show this.
87. After being improperly diagnosed by Dr Doe, ENMMC who is covered and paid by my insurance company, the nurse Greg Doe (to be named in a future complaint) demanded I leave the hospital immediately or he would call security. He did not allow me time to dress or get my items out of the hospital and as always refused to follow the hospital’s protocol when discharging patients which is to call their insurance company to tell them the patient was discharged so that transportation could be arranged. Greg Doe’s misconduct was intentional and or negligent. As a patient I am not able to tell my insurance I was discharged, this needs to come from the hospital itself. And when in sunrise unit of ENMMC after discharge no patients are allowed to leave until arrangements are made BY ENMMC with your insurance company if you have no other ride home. And either it is their protocol or every time I was in sunrise I was detained illegally waiting for ride arrangements to be made.
88.
89. 3) That together both defendants conspired intentionally and or negligently to create a hostile medical condition that put my life in danger. AMR refused to treat me at my home for any condition including covid, and I was unable to take an ambulance to the hospital or be discharged in a town I don’t even live in 30ish miles home. That both defendants had Proximate cause to realize such negligence would result in named harm.
90.
91. That on each count the defendants named had (1) a professional duty owed to the patient; (2) breach of such duty; (3) injury caused by the breach; and (4) resulting damages to be proven at trail.
92.
93. That all of the injuries and damages sustained by Chase Xander resulted from the negligent actions and breaches of the applicable standards of medical care by the Defendants by and through its employees and agents, without any act or omission on the part of the Chase Xander, or on the part of any of the Plaintiffs herein, directly thereunto contributing.
That as a direct and proximate result of the negligent actions and breaches of the applicable
94. standards of medical care by Defendant, Chase Xander suffered physical injuries, conscious
95. pain and suffering, and other damages.
96.
97. COUNT I: Medical Malpractice/Negligence/Misconduct AMR
The Plaintiffs re-allege and incorporate by reference herein all of the allegations contained in lines 75-81 That the Defendants by and through their employees/servant/agents breached the applicable standard of medical care owed to Chase Xander, which directly caused physical and emotional injury which is ongoing. That as a direct result of the negligence and breaches of the applicable standard of medical care by the Defendant, by and through its nurses, employees, and medical staff, resulting in ongoing physical and emotional damage to Chase Xander. And that damages will be proven by medical records during discovery.
WHEREFORE, the Plaintiff claims monetary damages against AMR individually in an amount to claimed below, plus costs, legal fees at $200. per hour for doing the work of an entire legal team, and for any further relief that this Honorable Court determines necessary and appropriate.
98.
99. COUNT II: Medical Malpractice/Negligence/Misconduct AMR and ENMMC
The Plaintiffs re-allege and incorporate by reference herein all of the allegations contained in lines 82-86 the Defendants by and through their employees/servant/agents breached the applicable standard of medical care owed to Chase Xander, which directly caused physical and emotional injury which is ongoing. That as a direct result of the negligence and breaches of the applicable standard of medical care by the Defendant, by and through its nurses, employees, and medical staff, resulting in ongoing physical and emotional damage to Chase Xander. And that damages will be proven by medical records during discovery. That as a direct result of the negligence and breaches of the applicable standard of medical care by the Defendant, by and through its nurses, employees, and medical staff, resulting in ongoing physical and emotional damage to Chase Xander. And that damages will be proven by medical records during discovery.
WHEREFORE, the Plaintiff claims monetary damages against AMR and ENMMC individually in an amount to claimed below, plus costs, legal fees at $200. per hour for doing the work of an entire legal team, and for any further relief that this Honorable Court determines necessary and appropriate.
100. COUNT III: Medical Malpractice/Negligence/Misconduct AMR and ENMMC
101. The Plaintiffs re-allege and incorporate by reference herein all of the allegations contained in lines 87-88 That the Defendants by and through their employees/servant/agents breached the applicable standard of medical care owed to Chase Xander, which directly caused physical and emotional injury which is ongoing. That as a direct result of the negligence and breaches of the applicable standard of medical care by the Defendant, by and through its nurses, employees, and medical staff, resulting in ongoing physical and emotional damage to Chase Xander. And that damages will be proven by medical records during discovery. The medical care I received was Below standard care and I was battered by ENMMC employee Nurse Greg Doe. Battery does not have to be a physical assault as long as the actions resulted in physical injury which it did. Universal Citation: NM Stat § 30-3-4 (2021) Battery is the unlawful, intentional touching or application of force to the person of another, when done in a rude, insolent or angry manner. Whoever commits battery is guilty of a petty misdemeanor. (greg doe forcefully demanded I leave and threatened me and my property resulting in physical and emotional injury)
102. WHEREFORE, the Plaintiff claims monetary damages against AMR and ENMMC individually in an amount to claimed below, plus costs, legal fees at $200. per hour for doing the work of an entire legal team, and for any further relief that this Honorable Court determines necessary and appropriate.
103.
104. WHEREFORE:
105. 1. The Plaintiff Chase Xander asks the court to impose an immediate emergency injunction on both Defendants requiring them to provide the medical standard of care required by their practice and to refrain from all discrimination, harassment and battery in the future.
106.
107. 2. To award the Plaintiff $250,000.00 from each of the defendants ENMMC and AMR for the pain, suffering and humiliation inflicted. Intentional and or neglectful infliction of physical and mental pain.
108.
109. 3. To award the plaintiff $10,000.00 as per the patient protection act from each defendant for each of the 3 causes of injury.
110.
4. To award plaintiff a fair rate for legal fees and costs.
111.
5. For a Judicial order for a lie detector test given to me and handled through indigent where I can pay the court back. This will be required because on most occasions I was alone and the defense has already proven they are willing to lie or commit federal crimes by breach of hippa and tampering with mail.
112.
113. Appendage: My informal pronouns are any, but since I have to be formal my pronouns are ze/zir.
114. Your Honor, I will be asking for accommodations for the SEVERE emotional disabilities I have. I do not expect this to be a get out of jail free card, I can and will behave appropriately in and out of your court. But the facts are that I am SEVERELY and LIFE THREATENINGLY disabled and neurodivergent. As seen by councils telling the court I said ‘what a rush’. I will respond neurodivergently on occasion, and if I am in a flashback, I have little control over what I say (that will not happen). I hope the court and council would read the symptoms of Post Traumatic Stress Disorder from the mayo clinic- https://www.mayoclinic.org/diseases-con ... c-20355967 and for council and the court to take my disability which can be life threatening for me, into consideration. So far the only special needs I have asked from the court is telephonic hearings. To prevent panic attacks.
115.
116.
117. Respectfully submitted,
118. Chase Xander
119. / s/ Chase Xander
120. Pro Se
Re: Case No. D-504-CV-202300223
For NOT AN ATTORNEY that looks pretty damn good to me
Re: Case No. D-504-CV-202300223
Look at this it is why Judge Hudson got mad at me Oo BUT it was not just me, the attorneys for ENMMC keep throwing fits and i was just responding, but now i won't make that mistake again. BEFORE a motion i have to ask the attorneys if they object then i can file a motion. But they were NOT asking me if i object before their motions. Judge Hudson just loves to get mad at me
EVENT DATE EVENT DESCRIPTION EVENT RESULT PARTY TYPE PARTY # AMOUNT
09/27/2023 REPLY P 1
Reply To Defendant ENMMC's Answers And Motion To Dismiss
09/22/2023 REPLY D 2
ENMMC's Reply to Mtn to Dismiss
09/22/2023 NTC: COMPLETION OF BRIEFING D 2
Notice of Completion of Briefing
09/22/2023 REQUEST FOR HEARING/ SETTING D 2
Request for Hearing
09/07/2023 REPLY P 1
Reply To Defendant ENMMC's Motion To Dismiss
09/01/2023 REPLY P 1
Reply to Defendant ENMMC's Reply to Motion to Admit Exhibits into Evidence
09/01/2023 ANSWER D 2
Defendant Eastern New Mexico Medical Center's Answer to Complaint
09/01/2023 MTN: MOTION D 2
Defendant Eastern New Mexico Medical Center's Motion for Partial Dismissal of Plaintiff's Claims for Discrimination, Battery, Harassment, Civil Conspiracy for Hostile Medical Condition, Attorney's Fees, and Claims Barred by the Applicable Statute of Limitations
09/01/2023 CERTIFICATE OF SERVICE P 1
Certificate of Service - for Defendant Eastern New Mexico Medical Center's First Set of Interrogatories and Requests for Production to Plaintiff Chase Xander
09/01/2023 NTC: NOTICE D 1
Notice of Withdrawal of Defendant American Medical Response Medical Service Inc's Motion for Summary Judgment on Plaintiff's Claim for Medical Malpractice and Negligence and Motion to Dismiss Plaintiff's Claims for Discrimination, Battery, and Harassment, Filed on July 31, 2023
08/28/2023 REPLY P 1
Reply To Defendant AMR'S Answer To Amended Complaint
08/24/2023 NTC: HEARING (MOTION)
09/29/2023 @ 1:30PM - JMH
08/22/2023 REPLY P 1
Reply To Defendant AMR'S Claims On HIPAA
08/21/2023 REQUEST FOR HEARING/ SETTING D 1
RFH MTD & Sched Conf
08/21/2023 MTN: MOTION D 1
MTD Re Amd Complaint
08/21/2023 ANSWER D 1
Ans to Amd Complaint
08/11/2023 COMPLAINT (NON-OPENING) P 1
Amended Complaint For Malpractice/Negligence/Misconduct
08/08/2023 ORD: ORDER
Order Directing Filing of Amended Complaint and Responsive Pleadings
08/08/2023 ORD: ORDER DENYING
Order: Denying Motions without Prejudice as Non-Conforming; Deeming Pleadings of No Effect; and Establishing Expectation for Decorum
08/07/2023 SUPPLEMENTAL INFORMATION
Supplement To Notice To Court
08/07/2023 REPLY P 1
Reply To Defendant Notice Of Joiner
08/07/2023 REPLY P 1
Reply To Defendants Motion For Injunction
08/07/2023 REPLY P 1
Reply To Response To Reply To Motion For An Injunction Joined By Both Defense Parties
08/07/2023 RESPONSE P 1
Response To Reply To Motion To Strike And Motion For Sanctions
08/04/2023 RESPONSE D 1
Defendant American Medical Response Medical Service Inc's Response To Plaintiff's Motion To Admit Exhibit 4 Into Evidence
08/04/2023 RESPONSE D 1
Defendant American Medical Response Medical Service INC's Response To Plaintiff's Motion To Admit Exhibit 3 Into Evidence
08/04/2023 RESPONSE D 1
Defendant American Medical Response Medical Service Inc's Response To Plaintiff's Motion For Sanctions 3
08/04/2023 NTC: COMPLETION OF BRIEFING D 1
NOCB MTD MSJ
08/04/2023 REPLY
Defendant American Medical Response Medical Service INC's Reply In Support Of Motion For Summary Judgment On Plaintiff's Claim For Medical Malpractice And Negligence And Motion To Dismiss Plaintiff's Claims For Discrimination, Battery And Harassment
08/04/2023 MTN: MOTION D 1
American Medical Response Medical Service INC's Notice Of Intent To Join ENMMV's Motion For Injunction To Protect Defendant From Future Vexatious And Oppressive Litigation
08/04/2023 REPLY P 1
Reply To Defendants Response To Motion To Admit Exhibits
08/04/2023 MTN: MOTION P 1
Motion For An Extension
08/04/2023 CORRESPONDENCE P 1
Supplement To Reply To Motion For Summary Judgment
08/04/2023 REQUEST P 1
Request For Accomodations
08/04/2023 AFFIDAVIT P 1
Affidavit From Plaintiff
08/04/2023 REPLY P 1
Reply To Motion For Summary Judgment
08/04/2023 MTN: MOTION P 1
Motion To Admit Exhibit 4
08/04/2023 RESPONSE
Defendant ENMMC's Consolidated Response to Plaintiff's Three Motions to Admit Exhibits
08/04/2023 MTN: MOTION P 1
Motion For Sanctions 3
08/03/2023 NTC: NOTICE D 2
ENMMC's Notice of Supplementation in Support of its Motion for Injunction to Protect Def from Future Vexatious and Oppressive Litigation
08/03/2023 MTN: To Impose Sanctions P 1
Motion for Sanctions
08/03/2023 MTN: MOTION P 1
Motion to Admit Exhibit 3 Into Evicence
08/03/2023 RESPONSE D 2
Defendants Response to "Motion to Strike"
08/03/2023 MTN: MOTION TO AMEND/ MODIFY P 1
Motion to Add Tampering with Mail to Complaint
08/03/2023 MTN: MOTION P 1
Motion to Admit Exhibit 2 into Evidence
08/02/2023 MTN: MOTION P 1
Motion To Strike
08/01/2023 RESPONSE
Defendant American Medical Response Medical Service INC.'s Response To Plaintiff's Motion To Set Aside And Motion To Dismiss Specific Defendants Without Prejudice
08/01/2023 REQUEST FOR HEARING/ SETTING D 1
RFH re MSJ & MTD
08/01/2023 REPLY P 1
Reply To Defendants Motion For Injunction And Waiver Of Rights To Attorney
08/01/2023 MTN: MOTION P 1
Motion To Admit Exhibit 1 Into Evidence
07/31/2023 CERTIFICATE OF SERVICE
COS 1st Rogs & RFP to Plf
07/31/2023 MTN: MOTION D 1
Defendant American Medical Response Medical Service INC'S Motion For Summary Judgment On Plaintiff's Claim For Medical Malpractice And Negligence And Motion To Dismiss Plaintiff's Claims For Descrimination, Battery And Harassment
07/31/2023 ANSWER D 1
Defendant American Medical Response Service INC'S Answer To Plaintiff's Complaint
07/17/2023 SUMMONS RETURN P 1
Served by Certified Mail 7/14/23
07/03/2023
06/29/2023 RESPONSE D 2
Defendant Eastern New Mexico Medical Center's Response to Plaintiff's Second Motion for Leave to Amend Her Complaint and Plaintiff's "Reply to Response to Defendant's Motion for Injunction"
06/16/2023 NTC: HEARING (MOTION)
8/7/23 @ 1:00 PM, Judge Hudson
06/13/2023 SUPPLEMENTAL INFORMATION
Supplement to Reply in Response to Defendants Response in Support of Motion for Injunction to Protect Defendant from Future Vexatious and Oppressive Litigation
06/13/2023 REPLY P 1
Reply in Response to order to Serve Defendants by their Registered Information
06/13/2023 REPLY P 1
Reply in Response to Defendants Response in Support of Motion for Injunction to Protect Defendant from Future Vexatious and Oppressive Litigation
06/13/2023 MTN: FOR LEAVE P 1
Motion for Leave to Amend with Amended Complaint
06/06/2023 MTN: MOTION P 1
Motion To Dismiss Specific Defendants Without Prejudice
06/06/2023 MTN: MOTION P 1
Motion For A Hearing
05/26/2023 REQUEST FOR HEARING/ SETTING
Request for Hearing
05/26/2023 NTC: COMPLETION OF BRIEFING
Notice of Completion of Briefing
05/26/2023 REPLY
Defendant Eastern New Mexico Medical Center's Reply in Support of it's Motion for Injunction to Protect Defendant from Future Vexatious and Oppressive Litigation
05/24/2023 ORD: ORDER
Order Requiring Service On Registered Agent And Allowing Free Service In Lea County
05/23/2023 NTC: HEARING (MOTION)
8/7/23 @ 9:00 AM, Judge Hudson
05/22/2023 NTC: NOTICE P 1
Notice To Court
05/16/2023 ORD: ORDER DENYING
05/15/2023 MTN: MOTION P 1
Motion For Sanctions
05/11/2023 REPLY P 1
Reply To Motion To Dismiss And Request For Injunction
05/10/2023 REQUEST FOR HEARING/ SETTING D 2
Request for Hearing
05/10/2023 NTC: COMPLETION OF BRIEFING D 2
NCOB - ENMMC's Mtn to Dismiss
05/10/2023 REPLY
ENMMC's Reply to Mtn to Dismiss
05/08/2023 RESPONSE D 2
ENMMC's Obj to P's Mtn to Amend & Mtn for Injunction to Protect Def from Future Vexatious and Oppressive Litigation
04/25/2023 REPLY P 1
Reply To Motion To Dismiss
04/25/2023 MTN: MOTION P 1
Motion For Leave To Amend
04/24/2023 MTN: TO DISMISS
ENMMC's Mtn to Dismiss for Failure to State a Claim
04/14/2023
03/23/2023 ORD: Order For Free Process Granted P 1
Order on Application for Free Process
03/23/2023 Application for Free Process P 1
Application for Free Process and Affidavit of Indecency
03/23/2023 OPN: COMPLAINT P 1
Complaint for Malpractice Harassment, Battery, and Discrimination Resulting in Personal and Emotional Injury
Re: Case No. D-504-CV-202300223
Almost time to amend this puppy to include Nurse Greg from ENMMC and Courtney King and Jasmine Reglado EMT's for AMR. You really thought you could get away with anything forever didn't you? I was far too poor too alone and too CRAZY to ever do anything about the abuse. GUESS WHAT, you judged wrong and now the LAW is going to come down HARD on my side. Your abuse is OVER.
Luke MaKarral and James Leach I WOULD LOVE TO GET YOU ON THE STAND AND TELL MY JUDGE HOW YOU TWO BIG STRONG MEN NEED POLICE PROTECTION FROM AN OLD LADY WHO CAN BARELY GET OFF HER PORCH. Ya big men face me in court if you ever do it again. But since i have to let this be dismissed i will get your last little buddies who came to my house with a cop esscort for discrimination in a FEDERAL court. FUN TIMES!
Luke MaKarral and James Leach I WOULD LOVE TO GET YOU ON THE STAND AND TELL MY JUDGE HOW YOU TWO BIG STRONG MEN NEED POLICE PROTECTION FROM AN OLD LADY WHO CAN BARELY GET OFF HER PORCH. Ya big men face me in court if you ever do it again. But since i have to let this be dismissed i will get your last little buddies who came to my house with a cop esscort for discrimination in a FEDERAL court. FUN TIMES!
Re: Case No. D-504-CV-202300223
Luke MaKarral and James Leach and Courtney King and Jasmine Reglado EMT's for AMR.
I am legally suing the hell out of some of you individually and of course as employees from the questionable corporation American Medical Response.
See problem is this- there were multiple entities involved in my abuse for the last 10ish years. Chaves County Sheriffs are one of them, as soon as their attorney seen the proof of what was done to me they settled quickly even tho it was slow in federal court. He helped me through the steps if i didn't know like with discovery or a unneeded motion. He also convinced me that some of my claims were unwarranted by showing me the law that proved it. One thing he did was never complain to the judge how i was not acting how he wanted instead he worked with me brilliantly then we settled. Good Job Dan Macke as shown in the federal case that i included in the complaint for the time that all offenders come to my house to do nothing but harass assault and intimidate me, possibly falsely arresting me to punish me for calling the ambulance for an infection from a serious burn on my leg.
All of that will be included in the discovery.
So since the sheriffs participated in the abuse and harassment and knew it they settled so they are out of it. Who else were involved??? Who else tried to intimidate me by bringing MULTIPLE medical and law enforcement who even blocked off my road for a while.
AMR were involved you were right up in it and physically and verbally harassing me as well multiple times. AMR formally Superior Ambulance were sued by me (easily found on case look up) but it was dismissed because i let it go thinking if they knew i could sue they would not do their bullshit again. That was not the case. You still want to discriminate me first by asking for an escort for an old sick hurt woman the ONLY reason IS for harassment and intimidation with a DISGUSTING wish your escorts will arrests me, that has NEVER happened legally and you almost killed me once with the help of New Mexico Medical Center.
New Mexico Medical Center also participated by falsely detaining me because i told them and the Sheriffs that a German Corporation and their Investors were stalking harassing and even sending letters saying they were watching me so. I told them how the investors were a Billion Dollar Corporation Then everyone every single person from the hospital to American Medical Response's EMTs and the Sheriffs and most of the medical staff at ENMMC as well decided i was out of my mind. And it didn't matter if i was or not because i was for sure poor and alone, what could i do right?
What i can do is stand up for the right of every poor disabled intoxicated alone patient you have decided you can treat any way you want. Threaten to punch me in the face on multiple occasions is nothing to the abuse you have put me AND OTHERS SIMULAR TO ME for the last 10 years and i will prove it without one doubt and i can't wait to see all of you in court, try to get out abusing an old crippled handicap lady who is alone. Guess you like to abuse the ones who are alone most, it is lots of fun, i have seen in your faces. i want so see your faces in court and all can be right with the world.
I am legally suing the hell out of some of you individually and of course as employees from the questionable corporation American Medical Response.
See problem is this- there were multiple entities involved in my abuse for the last 10ish years. Chaves County Sheriffs are one of them, as soon as their attorney seen the proof of what was done to me they settled quickly even tho it was slow in federal court. He helped me through the steps if i didn't know like with discovery or a unneeded motion. He also convinced me that some of my claims were unwarranted by showing me the law that proved it. One thing he did was never complain to the judge how i was not acting how he wanted instead he worked with me brilliantly then we settled. Good Job Dan Macke as shown in the federal case that i included in the complaint for the time that all offenders come to my house to do nothing but harass assault and intimidate me, possibly falsely arresting me to punish me for calling the ambulance for an infection from a serious burn on my leg.
All of that will be included in the discovery.
So since the sheriffs participated in the abuse and harassment and knew it they settled so they are out of it. Who else were involved??? Who else tried to intimidate me by bringing MULTIPLE medical and law enforcement who even blocked off my road for a while.
AMR were involved you were right up in it and physically and verbally harassing me as well multiple times. AMR formally Superior Ambulance were sued by me (easily found on case look up) but it was dismissed because i let it go thinking if they knew i could sue they would not do their bullshit again. That was not the case. You still want to discriminate me first by asking for an escort for an old sick hurt woman the ONLY reason IS for harassment and intimidation with a DISGUSTING wish your escorts will arrests me, that has NEVER happened legally and you almost killed me once with the help of New Mexico Medical Center.
New Mexico Medical Center also participated by falsely detaining me because i told them and the Sheriffs that a German Corporation and their Investors were stalking harassing and even sending letters saying they were watching me so. I told them how the investors were a Billion Dollar Corporation Then everyone every single person from the hospital to American Medical Response's EMTs and the Sheriffs and most of the medical staff at ENMMC as well decided i was out of my mind. And it didn't matter if i was or not because i was for sure poor and alone, what could i do right?
What i can do is stand up for the right of every poor disabled intoxicated alone patient you have decided you can treat any way you want. Threaten to punch me in the face on multiple occasions is nothing to the abuse you have put me AND OTHERS SIMULAR TO ME for the last 10 years and i will prove it without one doubt and i can't wait to see all of you in court, try to get out abusing an old crippled handicap lady who is alone. Guess you like to abuse the ones who are alone most, it is lots of fun, i have seen in your faces. i want so see your faces in court and all can be right with the world.