Sheremetiev

FACTS AND PROCEEDINGS BELOW

A. Sheremetiev’s Claim for Damages and Federal Complaint On March 19, 2019, Sheremetiev filed and served a timely “claim for damages to person or property” with the County (the claim form). (Capitalization omitted.) The claim form described two incidents that Sheremetiev contended occurred while she was

2 detained at CRDF. First, on September 23, 2018, Sheremetiev fell while walking quickly to the showers, fracturing the patella in her left knee. Second, on February 13, 2019, Vallejo and another deputy ordered Sheremetiev to sleep in the top bunk of her bed, despite medical orders in Sheremetiev’s file prohibiting this. When Sheremetiev attempted to do so, she fell, injuring her head, neck and back. The claim form cites these incidents as the basis for the following causes of action: violations of the Eighth and Fourteenth Amendments to the United States Constitution, negligence, IIED, violation of the Bane Act, and other “federal and state claims.” (Capitalization omitted.) The County denied relief in response to the claim form. On August 7, 2019, Sheremetiev sued respondents in the United States District Court for the Central District (case No.…