Case Document 1 Filed 11129112 Page 1 of 5 PagelD 1 RONALD C. HOOD JR. IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF FT. MYERS DIVISION 1-. Tuna CASE NUMBER: ALL DEFENDANTS ARE HEREBY (AKA: ERIKA DENISE Hoop) SUED IN THEIR OFFICIAL Plaintiff, CAPACITIES FOR ONGOING ACTIONS COMMITTED UNDER THE COLOR OF STATE LAW. V. DEPT. OF CHILDREN AND FAMILIES, TRIAL BY JURY IS DEMANDED. DAVID E. Secretag: of DCF, DANIEL MONTALDI SVPP Administrator Defendant(s), 4%:ch CIVIL RIGHTS COMPLAINT FORM FOR RESIDENTS FLORIDA CIVIL COMMITMENT CENTER 13619 SE HIGHWAY 70 ARCADIA FL. 34266-7861 El Yes No To the extent there are administrative remedies available at the what steps have you taken at the in an attempt to remedy the alleged violation(s)? Please attach any supporting documentation. Place of present detainment: Have you had your Jimmy Ryce Trial? The Plaintiff has ?led numerous Resident Communication Forms, several Resident Grievances, and wrote two (2) letters to DCF, David E. Wilkins, reguesting assistance with hislher ender identi disorder issue. see attached exhibitA . I- 249); Case Document 1 Filed 11/29/12 Page 2 of 5 PagelD 2 IV. Parties: In Part A of this section, indicate your full name in the first blank and your full mailing address in the second blank. A. Name of Plaintiff: RONALD C. HOOD JR., 990304 (AKA: ERIKA DENISE FLORIDA CIVIL COMMITMENT CENTER 13619 SE HIGHWAY 70 ARCADIA, FL. 34266-7861 Mailing Address: In Part of this section, indicate the full name of the ?rst Defendant. Also, fill in his/her mailing address, position, and where helshe is employed. For additional Defendants, use Parts and of this section for names, positions, and places of employments. B. Name of Defendant: Department of Children and Families Mailing Address: 1317 Winewood Blvd. Tallahassee, Fl. 32399-0700 Position: Controlling Authority for the Employed At: DCF Headguarters in Tallahassee, Florida C. Name of Defendant: David E. Wilkins Mailing Address: 1317 Wijnewog?lvd. Tallahassee, Fl. 32399-0700 Position: Secretau of DCF Employed At: DCF Headguarters in Tallahassee, Florida D. Name of Defendant: Daniel Montaldi Mailing Address: 1317 Winewood Blvd. Tallahassee, Fl. 32399-0700 Position: SVPP Administrator Employed At: DCF Headguarters in Tallahassee, Florida STATEMENT OF CLAIM: State what rights under the Constitution, laws, or treaties of the United States have been violated, and be Speci?c. If you intend to allege a number of related claims set forth each claim in a separate paragraph. Any claim that is not related to the same basic incident or issue must be addressed in a separate Civil Rights form. 1. The Plaintiff, Ronald Hood, also known as Erika Denise Hood, herein claims that DCF, by and through Secretary Wilkins and Administrator Montaldi, as well as by and through all previous Secretaries and SVPP Administrators, has violated her First, Eighth, and Fourteenth Amendment Rights through the simple expediency of not formulating nor adopting a policy for the treatment of Transgender People within the Florida Civil Commitment Center. Case Document 1 Filed 11/29/12 Page 3 of 5 Page-ID 3 Plaintiff Hood was born on May 15, 1972 to Mr. and Mrs. Ronald C. Hood Sr., as Ronald Chesteen Hood Jr. The Plaintiff has been denied her Right to Freedom of Expression under the Fifth Amendment of the United States Constitution. The Plaintiff has been denied her Right to Treatment for Gender Identity Disorder via the Exercise of Unreasonable Professional Judgment by DCF under the Eighth Amendment of the United States Constitution. The Plaintiff has been denied her Right to Treatment for Gender Identity Disorder via Deliberate Indifference to her Serious Medical Condition by DCF under the Eighth Amendment of the United States Constitution. The Plaintiff has been denied her Right to Treatment for Gender Identity Disorder via the denial of her Right to Due Process under the Fourteenth Amendment of the United States Constitution. STATEMENT OF FACTS: State as brie?y as possible the FACTS of your case. Describe how each named Defendant was involved. DO NOT MAKE ANY LEGAL ARGUMENTS 0R CITE ANY CASES OR STATUTES. State with as much speci?city the facts in the following manner: 1) name and position of person(s) involved, 2) Date(s), 3) Place(s), 4) Facts or event(s) giving rise to your claim, including involvement of each Defendant, 5) Nature and extent of injury physical injury or how you were harmed by the acts of the Defendant(s)). l. 2. On October 1, 2000, the Plaintiff arrived at the Florida Civil Commitment Center from the Florida Department of Corrections. Beginning in January, 2001, the Plaintiff has ?led numerous Resident Communication Forms and Grievance Forms requesting treatment for her Gender Identity Disorder. The Plaintiff has been diagnosed with GID (Gender Identity Disorder) since her incarceration in the FDOC. The Plaintiff?s records show that DCF knew of her GID Diagnosis since before her arrival at the on October 1, 2000. DCF has chosen to ignore this Serious Medical Condition (not just in the Plaintiff but in several other residents? cases as well) and has refused to provide form of therapy for the Plaintiff?s Serious Medical Condition of Gender Identity Disorder (GID). It is clear that DCF has never contemplated the formulation of a policy for the treatment of Transgender residents of the Florida Civil Commitment Center in that the Plaintiff wrote to Secretary David E. Wilkins of DCF and inquired as to whether or not DCF has a policy for this type of treatment. Nor has the Case Document 1 Filed 11129/12 Page 4 of 5 PagelD 4 Defendants ever expressed any concern for the treatment of this Serious Medical Condition that severely impacts the life of the Plaintiff. 5. Ms. Hood has been patient with the Department of Children and Families for several years and has even sought outside assistance through Dr. Fred 8. Berlin of the National Institute for the Study, Prevention and Treatment of Sexual Trauma in Baltimore, Maryland for her GID. 6. The several of the higher Federal Courts of the United States of America have ruled in recent years that transgender individuals have a constitutional right to treatment for Gender Identity Disorder. RELIEF REQUESTED: State brie?y what you want the Court to do for you. Again do not make any legal arguments or cite any cases or statutes.11- .. '41Iimim- bg_H1F$ Honorable, Closet-1L. Case Document 1 Filed 11/29/12 Page 5 of 5 PageID 5 I DECLARE UNDER THE PENALTY 0F PERJURY, pursuant to Fla. Stat. 92.525 State v. Shearer, 628 So. 2d 1102 (Fla. 1994) and Federal Statutes 28 U.S.C. 1746 that] have read the forgoing 0 and that the facts stated herein are true and correct. Signed this day of bla?e?abgc ,20 la . . maria- (p aintiff?s Signan