Re: Re-emphasis of Claims, Request for Public Release of Records, and Settlement Proposal — Case No. 1:25-cv-04501-RMI

Dear Members of the Mendocino County Board of Supervisors,

I write to again emphasize the three primary claims detailed in my federal civil rights and ADA complaint against Mendocino County and its agents:

Deliberate Indifference to Serious Medical Needs and Violations of the ADA: Despite full knowledge of my epilepsy, seizure disorder, and post-surgical needs, County personnel consistently failed to provide timely and adequate medical care. This included the refusal to schedule urgent medical appointments and denial of prescribed medications for over four months, violating federally protected rights and constitutional standards.

Multiple Civil Rights Violations: These include violations of my First, Fourth, Fifth, Eighth, and Fourteenth Amendment rights through excessive bail, retaliatory solitary confinement, and physical and psychological abuse. These were compounded by fabricated charges, manipulated files, and unlawful parole holds designed to harass and extend my detention unlawfully.

Deprivation of Property Without Due Process: My lawfully owned personal property was unlawfully seized and destroyed without adherence to legal procedures or departmental policies, despite clear documentation of ownership from March 2020.

There is abundant evidence supporting these claims, including court transcripts, extensive video documentation, and signed witness statements — notably from former employees of the Mendocino County Sheriff’s Department. In light of the public interest and transparency required in such matters, I again formally request that all records, including video evidence, be released publicly.

My goal extends beyond personal redress. I seek meaningful institutional reforms within the Mendocino County jail system, with particular attention to improving the treatment and care of epileptic inmates and others with serious medical vulnerabilities. Such reforms are essential to prevent future harm and ensure compliance with federal disability laws.

Finally, I strongly urge the County to pursue reimbursement of damages through pension forfeitures of the employees found responsible for these violations. Holding individuals financially accountable will promote accountability and help relieve the County’s accumulating legal debt.

I remain willing to engage constructively toward a resolution before August 15th, 2025 that promotes justice, institutional reform, and transparency for the benefit of all. Again I call for the full release of my jail file, including medical and video records of dates in question.

Thank you for your serious consideration of these important issues. Below is a copy of the settlement offer sent to this board on 6-13-2025

Respectfully,

Joseph P. Hart
Plaintiff,
Case No. 1:25-cv-04501-RMI
Joseph P. Hart,
Plaintiff, Pro Se
v.
County of Mendocino, et al.,
Defendants. Case No. 1:25-cv-04501-RMI
NOTICE TO THE COURT REGARDING GOOD-FAITH SETTLEMENT
COMMUNICATION
Plaintiff Joseph P. Hart, appearing pro se, respectfully submits this Notice to the Court to advise
that on June 13, 2025, a formal Settlement Offer was mailed to the Defendants through
certified USPS correspondence. That submission, is included in this notice for the court records,
it was made in addition to previous attempts prior to the filing of this complaint, it was made in
good faith, is in accordance with the principles of judicial economy, restorative justice, and the
peaceful resolution of disputes as encouraged under the Federal Rules of Civil Procedure.
This offer, presented contemporaneously with the Court’s June 12, 2025 Order; authorizing U.S.
Marshal service of the Complaint, seeks not only to resolve the individual harms suffered by
Plaintiff, but also to serve the public interest through the implementation of targeted institutional
reforms. These reforms are designed to address systemic deficiencies in the treatment of inmates
with epilepsy and serious neurological conditions within Mendocino County correctional
facilities. The settlement proposal includes a total monetary amount of $750,000, accompanied
by specific donations to national and regional epilepsy advocacy organizations, and mandates the
adoption of humane medical policies within the county jail system. A complete copy of this letter
has been duly served upon all relevant parties, and these additional copies are being submitted to
the Court for inclusion in the official record.
This notice is respectfully filed to reaffirm the Plaintiff’s willingness to engage in constructive
dialogue and explore resolutions of this matter without unnecessary expenditure of judicial
resources. Plaintiff further believes that such settlement, if accepted, would represent a
meaningful step toward lasting institutional reform, motivation to act in compliance with
federal disability law, and the protection of vulnerable incarcerated individuals.
Thank you for your attention to this matter, which remains grounded in the lawful pursuit of
justice and the advancement of positive societal change.
Respectfully submitted, Plaintiff - Pro Se
Joseph P. Hart:_________________________________Date_______/_______/___________
Email: josephhart1188@gmail.com (707)-671-8945
PO BOX 1093, Covelo, CA, 95428
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FROM: Joseph P. Hart June 13th , 2025
Plaintiff,- Case No. 1:25-cv-04501-RMI

TO: Mendocino County Counsel, or to those whom it may concern,
501 Low Gap Rd # 1030,
Ukiah, CA 95482
Phone: (707) 234-6885 - Email: cocosupport@mendocinocounty.gov
Re: Proposed Settlement Offer to Resolve Case No. 1:25-cv-04501-RMI
United States District Court, Northern District of California
Joseph P. Hart v. County of Mendocino, et al
This correspondence is submitted as a formal and principled offer of settlement to fully
resolve all claims pending in United States District Court Case No. 1:25-cv-04501-RMI,
Joseph P. Hart v. County of Mendocino, et al.
The federal judiciary has long recognized that civil rights litigation serves as a constitutionally
protected and peaceful vehicle for enacting lawful social reform and justice. This proposal is
made in the spirit of that tradition, with the goal of achieving not only resolution of the horrific
harms I personally endured, but also catalyzing systemic improvements in the policies and
practices affecting inmates with medical vulnerabilities in Mendocino County correctional
facilities.
I respectfully submit the following total settlement proposal in the amount of $750,000,
contingent upon the implementation of specific institutional reforms and the following
distribution of funds:
Monetary Settlement and Distribution- to be paid by Certified Check or Money Order:
1. $400,000 — For Pain and Suffering Payable to: Joseph P. Hart
Delivery Address: Attn: Joseph P. Hart
c/o Hon. James P. Gray
ADR Services, Inc.
19000 MacArthur Boulevard, Suite 550
Irvine, California 92612
Delivery Method: Certified U.S. Mail, sealed envelope
2. $50,000 — For Personal Property Loss Payable to: Joseph P. Hart
Delivery Address: Same as above
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3. $200,000 — Donation to the ‘Baba Hari Har Ramji Epilepsy Initiative’
Payable to: Sonoma Ashram Foundation
Mailing Address:
Sonoma Ashram Foundation
Attn: Executive Director
1087 Craig Avenue
Sonoma, California 95476
Memo: “For Baba Hari Har Ramji Epilepsy Initiative”
Delivery Method: Certified U.S. Mail, sealed envelope
4. $50,000 — Donation to Josh Provides Epilepsy Assistance Foundation
Payable to: Josh Provides Epilepsy Assistance Foundation, Inc.
Mailing Address:
5428 Sundew Drive
Sarasota, Florida 34238
Memo: “General Support for Epilepsy Assistance”
Delivery Method: Certified U.S. Mail, sealed envelope
5. $50,000 — Donation to Epilepsy Foundation of Northern California
Payable to: Epilepsy Foundation of Northern California
Mailing Address:
601 Van Ness Avenue, Suite E104
San Francisco, California 94102
Memo: “Law Enforcement & Correctional Training Programs”
Delivery Method: Certified U.S. Mail, sealed envelope
Institutional Reforms Requested as Condition of Settlement:
In addition, the County of Mendocino shall adopt and publish policy reforms across all
correctional institutions under its jurisdiction, specifically addressing the care and treatment
of inmates with epilepsy and other serious neurological conditions:
1. Mandatory Medical Intake Evaluation for any known or declared epileptic individual
upon booking, including documentation of medical history and verification of current
prescriptions.
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2. Timely and Uninterrupted Access to Medication, ensuring antiepileptic drugs are
administered within 4 hours of intake and consistently maintained throughout custody.
3. Annual Correctional Staff Training in seizure recognition, ADA compliance,
appropriate emergency response, and protocols for managing Epileptic episodes among
vulnerable populations with Epilepsy Foundation of Northern California.
4. Specific Protocols for Grand Mal (Tonic-Clonic) Seizures to include:
o Immediate transport for MRI or appropriate neuroimaging after any such seizure event to
assess for traumatic brain injury or other complications.
o Provision of medical-grade padded bedding and protective headgear for inmates with a
known seizure history, particularly in restrictive housing or solitary confinement settings.
Closing Statement:
This settlement offer is made in good faith, grounded in principles of restorative justice, public
service, and lawful reform. It seeks not only to remedy the past, but to protect others from
future harm by promoting institutional accountability and improved medical practices.
Should this proposal be accepted in full by August 15th, 2025, I will execute a full release of
claims and stipulate to the dismissal of the above-captioned case with prejudice. Should this
proposal not be accepted by that date, I will seek full allowable damages under the law for all my
claims.
Thank you for your consideration and commitment to a constructive and lawful way to find
resolution to my traumatic experiences, and to move forward from these serious legal matters.
Respectfully,
Plaintiff, Joseph P. Hart v. County of Mendocino, et al
Federal Case No. 1:25-cv-04501-RMI