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“Clicking” the “BLUE TEXT “ will DAVID BELL
take you to the APPLICABLE DOCUMENTS VS
AGRAQUEST, INC.
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PAMELA GAIL MARRONEʼS CONNECTIONS RGA AGR
IN THE CASE OF DAVID BELL: NE O ER (
RO RST
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MARRONE ORGANIC INNOVATIONS (renamed 007
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ANN LʼS JUDICIA
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AFFILIATIONS UZ BEL IM:
GE S AVID CLA BIAS
AGRAQUEST LAW FIRM OF MORRISON & FOERSTER JUD
ER ON D ATION ing
LIBERTY MUTUAL INSURANCE (Agraquest’s ORD OMP
ENS noth
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( workers compensation carrier at time KER t sha is clai
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E VS ES
T N W R E *KARRIUKU S B NS JU AN AN NS
TIM QU NS IA S
IC N LA OR RST ONS CA IO Z G IO
AGRAQUEST, INC. RAATIO YSATIO M OE TI H EMP TION W AT SU DU AT
AGOL PHOL F LA Y OLA OL OL
VI VI VI
O VI VI VI
1998 BEGAN EMPLOYMENT AT
AUG 10 AGRAQUEST
(1) PROJECT; LAGINEX
1999 TOLD SUPERVISOR “SICK”, NONE REPORT NONE REPORT OF
JAN CLOCKED OUT & SOUGHT OF INJURY/ INJURY/ILLNESS
EMERGENCY MEDICAL ILLNESS * N O C U LT U R E S O F
18,21 ,22 CARE
(2, 3, 4) INFECTION
JAN 25 SINUS SURGERY * N O C U LT U R E S O F
(5) SCHEDULED INFECTION
JAN 28 PRESCRIPTION
(6)
FEB 3
1ST SINUS SURGERY * N O C U LT U R E S O F
(7) $20,878.00 INFECTION
APRIL ?
METAL FLEW IN EYE; REPORTED REPORTED
(8) TAKEN TO ER ??? ???
JUNE 1 TEMPORARY POSITION
(9) ENDED
2000 REQUESTED COPY OF
FEB 3 EMPLOYEE FILE IGNORED IGNORED
(10)
2002 2ND SINUS SURGERY NONE REPORT OF
SEPT 12 $42,531.25 INJURY/ILLNESS
(11) (4)
2003 IMMUNOGLOBULIN
JUNE 3 INFUSIONS BEGIN
(12)
OCT 3
SENT EMPLOYEE’S CLAIM LISTED WRONG
(13) FOR WORKERS’ INSURANCE
COMPENSATION BENEFITS CARRIER
OCT 23 CLAIM DENIED
(14) *PUT IN
*Reply !omPreferred EMPLOYEE FILE
Employers Insurance IGNORED
“CLAIM DENIED” LABOR CODE
5402
2004 3RD SINUS SURGERY
FEB 3
(15)
FEB 5 CLAIM DENIED
(16) *2nd reply !om Preferred “15 DAYS LATE”
Employers insurance IGNORED
“claim denied” LABOR CODE
5402
MAY 13 CONTACTED WCIRB;
(17) REQUESTED NAME OF
INSURANCE CARRIER
MAY 19 *Reply !om
(18) WCIRB - insurance carrier was
Golden Eagle / Liberty Mutual
JUN 16 EMPLOYEE
(19) FILE SUBPOENAED
JUN 21 SUBPOENAED EMPLOYEE
(20) FILE COPIED
JUL 14 CLAIM DENIED DENIAL DENIAL DENIAL *195
(21) *195 DAYS LATE” *195 DAYS LATE” *195 DAYS LATE” DAYS LATE”
*Reply !om Liberty Mutual IGNORED LABOR
CODE
IGNORED
LABOR CODE
IGNORED LABOR CODE IGNORED
Insurance Co. 5402 LABOR CODE
“CLAIM DENIED” 5402 5402 5402
AUG 2 SUBPOENAED EMPLOYEE
(22) FILE RECEIVED
2005 BAD FAITH;
*Ho%ie Ruthkowski letter’s; 1 and DENIAL
JAN 21
(23, 24) 2 UNTIMELY
2006 REQUESTED LIST OF IGNORED IGNORED
JUL 29 HAZARDS AT WORKPLACE
AUG 8
“OUTSIDE THE
(25) *Reply !om Liberty Mutual PURVIEW OF
on Worker Right-To -Know laws WORKERS
COMPENSATION”
AUG 31 OBJECTION TO IGNORED IGNORED IGNORED
(26) DECLARATION OF
READINESS TO PROCEED
OCT 4 MOTION TO COMPEL IGNORED IGNORED IGNORED IGNORED
(27) DISCOVERY
OCT 10
*Reply !om Liberty Mutual IRRELEVANT
(28) TO CLAIM
on Motion to Compel Discovery
OCT 20 WCAB ORDER OF
(29) MICROBES AT AGRAQUEST
NOV 14
“THOUGHT”
(30) TO HAVE BEEN
*Reply !om Liberty Mutual PRESENT
NOV 11 4TH SINUS SURGERY
(31)
2007 DEMAND LETTER OF IGNORED IGNORED
AUG 15
HAZARDS IGNORED
(32)
AUG 15 REQUEST TO TAKE OFF IGNORED IGNORED IGNORED
(33) CALENDAR &
REOPEN DISCOVERY
SEP 10
WORKERS’ COMPENSATION JUDICIAL BIAS JUDICIAL BIAS & JUDICIAL
‘TRIAL’ PERJURY & CONFLICTS CONFLICTS OF BIAS &
*PRESIDING JUDGE; UNDER OATH OF INTEREST INTEREST CONFLICTS
SUZANNE F. DUGAN OF INTEREST
OCT 4
*Judge Suzanne F. Dugan’s IN
(34) spouse; Michael T. Dugan’s VIOLATION
Employer; PBS&J Company OF CAL CODE
co-sponsored UC Davis’s OF CIVIL
Science Fair with Agraquest, PROCEDURE
Law office of Morrison & SECTIONS
Foerster, and Marrone Organic 641
Innovations
OCT 12
JUDICIAL BIAS JUDICIAL BIAS & “APPLICANT
(35) & CONFLICTS CONFLICTS OF SHALL TAKE
*Judge Suzanne F. Dugan’s INTEREST NOTHING BY
OF INTEREST WAY OF HIS
ORDER
CLAIM”
Y
RT L
ES CE IBE UA S,
DAVID BELL FI N *L UT HI E F
E LIN T OF ISO R M AT S & DG NE
JU AN AN NS
VS ES N W R E
*KARRIUKU S B NS
TIM QU NS IA S
SIC ION
LA OR RST ONS CA IO Z G IO
AGRAQUEST, INC. RAATIO Y T M OE TI H EMP TION W AT SU DU AT
AGOL PHOLA F LA
O Y OLA OL OL
VI VI VI VI VI VI
2007 MOTION/PETITION FOR
RECONSIDERATION
NOV 3
(36) *filed 1 day before deadline
in Sacramento, CA; -
accepted as “TIMELY”
NOV 19
(37) *Liberty Mutual answer to JUDICIAL JUDICIAL BIAS & JUDICIAL
BIAS & CONFLICTS OF BIAS &
petition for reconsideration CONFLICTS INTEREST CONFLICTS
OF OF INTEREST
INTEREST
NOV 21 *Judge Suzanne F. JUDICIAL BIAS JUDICIAL BIAS & JUDICIAL BIAS
(38) Dugan report and & CONFLICTS CONFLICTS OF & CONFLICTS
recommendation on OF INTEREST INTEREST OF INTEREST
Petition for
Reconsideration
2008 WCAB OPINION & ORDER JUDICIAL BIAS JUDICIAL BIAS & JUDICIAL BIAS
JAN 3 DENYING PETITION FOR & CONFLICTS CONFLICTS OF & CONFLICTS
(39) RECONSIDERATION OF INTEREST INTEREST OF INTEREST
JAN 23
2ND
(40) MOTION/PETITION FOR JUDICIAL JUDICIAL BIAS & JUDICIAL
BIAS & CONFLICTS OF BIAS &
RECONSIDERATION INTEREST
CONFLICTS CONFLICTS
OF OF INTEREST
*filed 5 day’s before deadline INTEREST
in Sacramento, CA;
deemed; “UNTIMELY”
MARCH 4
WCAB OPINION & ORDER JUDICIAL BIAS JUDICIAL BIAS & JUDICIAL BIAS
DISMISSING PETITION FOR & CONFLICTS CONFLICTS OF & CONFLICTS
(41) RECONSIDERATION OF INTEREST INTEREST OF INTEREST
REFERENCES
(1) AGRAQUEST JOB OFFER & LETTER OF RECOMMENDATION: Employment duration for 6 months to one year as an Assistant
( ( ( Researcher / Microbiologist
(2) IMMEDIATE CARE MEDICAL CLINIC; DR. DOROTHY PETERSON; prescribed Zithromax: Sacramento Ear, Nose &
$ $ Throat; DR. KEVIN MCKENNAN (chart notes) & DR. NANCY APPELBLATT (chart notes); PRESCRIPTIONS ORDERED
$ $ FOR DAVID BELL
(3) CALIFORNIA LABOR CODES 5402 - KNOWLEDGE OF INJURY; Injury results in lost time beyond the employee's work shift at
$ the time of injury or which results in medical treatment beyond first aid... - 5401 (b) - NOTICE OF POTENTIAL ELIGIBILITY
( FOR BENEFITS; The employer shall provide, personally or by first-class mail, a claim form (DWC 1) and a notice of potential
$ eligibility for benefits - 6409.1. (a) (b) Every employer shall file a complete report of every occupational injury or occupational
$ illness, as defined in subdivision (b) of Section 6409; As used in this section, "occupational illness" means any abnormal condition
$ or disorder caused by exposure to environmental factors associated with employment, including acute and chronic $illnesses or
$ diseases which may be caused by inhalation, absorption,ingestion, or direct contact.
(T
$ CALIFORNIA CODE OF REGULATIONS $ ITLE 3. FOOD AND AGRICULTURE) DIVISION 6. PESTICIDES AND PEST
$ CONTROL OPERATIONS DIVISION 6. $PESTICIDES AND PEST CONTROL OPERATIONS CHAPTER 2. PESTICIDES; SUBCHAPTER 1.
$ PESTICIDE REGISTRATION - ARTICLE 8. REEVALUATION CRITERIA; VI. ADVERSE EFFECTS DISCLOSURE 6221. $REEVALUATION
$ CRITERIA.The director shall also $reevaluate a pesticide when certain factors have been found such as, but not limited to: (a)
$ $ PUBLIC OR WORKER HEALTH HAZARD.
FEDERAL REGISTER REPORTING REQUIREMENTS FOR RISK/BENEFIT INFORMATION - UNREASONABLE ADVERSE
$ EFFECTS PESTICIDE REGISTRATION NOTICE 98-3; GUIDANCE ON FINAL FIFRA (FEDERAL INSECTICIDE, FUNGICIDE AND
$ RODENTICIDE ACT); SECTION 6(A) (2): APRIL 3, 1998 - REGULATIONS FOR PESTICIDE PRODUCT REGISTRANTS - TECHNICAL
$ CORRECTIONS TO 6(A)(2) REGULATIONS - FEDERAL REGISTER - JUNE 19, 1998 (63 FR 33580 REPORTING THE VARIOUS TYPES OF
( ADVERSE EFFECTS EPA ADVERSE EFFECTS REPORTING; FIFRA 6 (A) (2) NOTICE OF CLASS DETERMINATION 1-99 –
$ DISCLOSURE OF ADVERSE EFFECTS INFORMATION – DECEMBER 15, 1999 (64 FR 70019) FIFRA SECTION 10 (D)(1)
$ REGARDING SAFETY AND EFFICACY INFORMATION APPLY TO ADVERSE EFFECTS INFORMATION SUBMITTED UNDER 6
$ (A)(2). THE CLASS DETERMINATION AFFIRMS THAT WITH THE EXCEPTION OF INFORMATION THAT DISCLOSES
$ MANUFACTURING PROCESSES, METHODS FOR DETECTING INERT INGREDIENTS, OR THE IDENTITY ( INERT INGREDIENTS OF
( (PROVISIONS OF 10(D)(1)(A), (B), AND (C)), SAFETY AND EFFICACY INFORMATION IS NOT ENTITLED TO CONFIDENTIAL
( TREATMENT.
(4) CALIFORNIA; LABOR CODE 6409.1; 6409.2 6409.3. In no case sha% the treatment administered for pesticide POISONING OR A
( ( CONDITION SUSPECTED AS PESTICIDE POISONING BE DEEMED TO BE FIRST AID TREATMENT. - HEALTH AND SAFETY
$ $ $ CODE; SECTION 105200
(5) $ DR. NANCY APPELBLATT SCHEDULED SINUS SURGERY
(6) DR NANCY APPELBLATT PRESCRIPTION FOR BELL
(7) OPERATIVE REPORT - SURGERY BILLINGS
(8) TAKEN TO SUTTER HOSPITAL EMERGENCY ROOM IN DAVIS; THE WORKERS’ COMPENSATION RATING BUREAU [WCIRB}
$ $ GAVE AGRAQUEST A 74% EXPERIENCE MODIFICATION RATE AS THERE WAS ONLY 1 CLAIM IN 3 YEARS.
(9) LAGINEX PROJECT ENDING; RECEIVED $1,440.00 SEVERANCE PAY
(10) LETTER TO CHRIS RUSSELL OF MORRISON & FOERSTER - CALIFORNIA DEPARTMENT OF INDUSTRIAL RELATIONS -
$ $ PERSONNEL FILES AND RECORDS; California law requires $ that employers allow employees and former employees access
$ $ to their personnel files and records that relate to the employee’s performance or to any grievance concerning the employee.
(11) 2ND SINUS SURGERY BILLINGS (DR. NANCY APPELBLATT)
(12) IVIG INFUSIONS; DEFINITION - 2003 - 2005 IVIG INFUSIONS; BILLINGS
(13) BELL SENT AGRAQUEST ‘DWC 1’ CLAIM FORM - AGRAQUEST SENT FORM TO PREFERRED EMPLOYER’S INSURANCE
$ $ COMPANY - CALIFORNIA INSURANCE CODES 1871.4; PENALTIES FOR MAKING FALSE OR FRAUDULENT WRITTEN OR ORAL
( ( STATEMENTS; (a) It is unlawful to do any of the following: (1) Make or cause to be made any knowingly false or fraudulent
$ $ material statement or material representation for the purpose of obtaining or denying any compensation
(14) CLAIM DENIED BY PREFERRED EMPLOYER’S INSURANCE COMPANY; “DATE OF INJURY PREDATES POLICY PERIOD”.
$ $ DENIAL LETTER PUT IT BELL’S EMPLOYEE FILE
(15) MAYO CLINIC - SCOTTSDALE, ARIZONA BILLINGS
(16) "NO CLAIM HAS BEEN FILED", "SENT TO PREFERRED EMPLOYERS IN ERROR" AND "NO COVERAGE / POLICY
$ $ $ $ CANCELED"
(17, 18 ) CARRIER WAS: GOLDEN EAGLE INSURANCE CORPORATION/LIBERTY MUTUAL INSURANCE; POLICY PERIODS
$ $ $ FROM 6/1/1998-6/1/1999 AND 6/1/1999-6/1/2000
(19, 20, 22) AMERICAN DATAMED AFFIDAVIT (Pursuant to Cal evidence code 1560, 1561) custodian of records: Agraquest; Denise
$ $ $ $ C. Manker
(21) LIBERTY MUTUAL DENIAL OF CLAIM - CALIFORNIA LABOR CODE 5402 (b); If liability is not rejected within 90 days after
( ( the date the claim form is filed under SECTION 5401, THE INJURY SHALL BE PRESUMED COMPENSABLE UNDER THIS
p
( ( DIVISION. The $resumption of this subdivision is rebuttable only by evidence discovered subsequent to the
day
$ $ 90-$ period.
(22) COVER OF SUBPOENAED EMPLOYEE FILE
(23, 24) 1ST HOLLIE RUTHKOWSKI LETTER TO DANIEL N. REICH/LIBERTY MUTUAL INSURANCE -
$ $ 2ND HOLLIE RUTHKOWSKI LETTER TO DANIEL N. REICH/LIBERTY MUTUAL; “not only do you have no statute of
( ( limitations defense, Liberty Mutual did not timely deny liability for this claim”.
(25) LAW OFFICES OF KATCHIS, HARRIS & YEMPUKU - DANIEL N. REICH; “I am not familiar with the “Workers Right to
( ( Know Law” as you put it in your letter. even if there is such a law, I would think that your request is over broad, and
( ( likely outside the purview of workers compensation”
(26) OBJECTION TO DECLARATION OF READINESS TO PROCEED; “As requested prior, please provide me a complete list of all
( ( biological (insects, fungi and bacterium) and chemical hazards present in the laboratories at Agraquest, Inc. in
( ( compliance with the Workers’ Right to Know Laws”. [As has been stated in the 7/29/2006 letter to Daniel Reich] I ask
( ( the court to enforce my “workers right-to-know” rights (including but not limited to) Federal and State Codes and
( ( Laws; OSHA “Hazard Communication Regulation” (29 CFR, Section 1910.1200, the California “Hazard
( ( ( ( Communication Regulation” (T8 CCR, Section 5194, and the “Pesticides and Workers Safety
( ( ( ( ( Requirements” (T3 CCR. Ch. 6, Subch.3, Group e, Section 6700....”
RIGHT TO KNOW LAWS
[Code of Federal Regulations] [Title 29, Volume 6] [Revised as of July 1, 2009] From the U.S. Government
Printing Office via GPO Access [CITE: 29CFR1910.1020][Page 91-101] TITLE 29--LABOR CHAPTER XVII--
OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION, DEPARTMENT OF LABOR PART
1910_OCCUPATIONAL SAFETY AND HEALTH STANDARDS (CONTINUED)--Table of Subpart Z_Toxic
and Hazardous Substances Sec. 1910.1020 Access to $ employee exposure and medical records.
CAL/OSHA REGULATION; GENERAL INDUSTRY SAFETY ORDER 3204, “You have the right to see and copy your medical
physical agents” “Records of exposure to toxic
records and records of exposure to toxic substances or harmful (
substances or harmful physical agents of other employees with work conditions similar to yours.”
CALIFORNIA’S RIGHT TO KNOW LAW AND HAZARDS COMMUNICATIONS STANDARD: Subchapter 7. General Industry
Safety Order Group 16. Control of Hazardous Substances; Article 109. Hazardous $ Substances and Processes §5194. Hazard
Communication. (e) Written Hazard Communication Program. (3) The employer shall make the written hazard
communication program ( available, upon request, to employees, their designated representatives, the Chief, and
NIOSH, in accordance with the requirements of section 3204(e).
UNITED STATES DEPARTMENT OF LABOR; OSHA: HAZARD COMMUNICATION (HAZCOM [4]) - Also known as the
"Right to Know" standard, was issued as 29CFR1910.1200 on November 25, 1983 (48 FR 53280)
[CODE OF FEDERAL REGULATIONS] [Title 29, Volume 6] [Revised as of July 1, 2009] From the U.S. Government
Printing Office via GPO Access [CITE: 29CFR1910.1020]
[Page 91-101] TITLE 29--LABOR CHAPTER XVII--OCCUPATIONAL SAFETY AND HEALTH
ADMINISTRATION, DEPARTMENT OF LABOR PART 1910_OCCUPATIONAL SAFETY AND HEALTH
STANDARDS (CONTINUED)--Table of Subpart Z_Toxic and Hazardous Substances Sec. 1910.1020 Access to
employee exposure and medical records.
(27) MOTION TO COMPEL DISCOVERY
(28) RESPONSE TO MOTION TO COMPEL
(29) WCAB JUDGE VOLKAN’S ORDER OF MICROORGANISMS AT AGRAQUEST WORKPLACE
(30) ANSWER TO WCAB ORDER - DAVID BELL’S MEDICAL RELATED TO AGRAQUEST’S MICROORGANISMS
(31) 4TH SINUS SURGERY DOCUMENTS
(32) LAW OFFICE OF OVERTON & OVERTON LETTER OF DEMAND
(33) LETTER REQUESTING “TAKE OF CALENDAR” & REOPEN DISCOVERY - LAW OFFICE OF OVERTON & OVERTON LETTER TO
( ( JUDGE (ROBINSON OF THE WCAB
(34) UNIVERSITY OF CALIFORNIA; EXPLORIT SCIENCE CENTER’S 16TH ANNUAL SCIENCE FAIR AND SILENT AUCTION -
$ $ CALIFORNIA CODE OF CIVIL PROCEDURE - SECTION 638-645.2 :: CHAPTER 6. OF REFERENCES AND TRIALS BY
( ( ( REFEREES; SECTION 641: (e) Interest on the part of the person in the event of the action, or in the main question involved in the action.
( ( ( (f) Having formed or expressed an unqualified opinion or belief as to the merits of the action. (g) The existence of a state of mind in the
( ( ( potential referee evincing enmity against or bias toward either party.
(35) WORKERS’ COMPENSATION APPEALS BOARD: ISSUES OFF THE RECORD; EXHIBITS ; SUMMARY OF EVIDENCE; FINDING
$ $ OF FACTS; OPINION ON DECISION
(36) 1ST MOTION/PETITION FOR RECONSIDERATION - EXHIBIT MISTAKENLY LEFT OUT OF EXHIBITS "UNTIMELY
D
( ( DENIAL: HOLLIE RUTHKOWSKI ESQ; ( ECEMBER 31, 2004 LETTER: CC: DAVID A BELL; MELISSA BROWN, ESQ; BAYNARD CHANG,
( ( ( M.D.; AGRAQUEST, INC.; DANIEL N. REICH, ESQ.; LYNNE RENDON, LIBERTY ( MUTUAL
(37) ANSWER TO PETITION FOR RECONSIDERATION - BY DANIEL N. REICH, ESQ. FOR AGRAQUEST INC. AND LIBERTY
$ $ MUTUAL INSURANCE COMPANY
(38) REPORT AND RECOMMENDATION ON PETITION FOR RECONSIDERATION - BY WORKERS’ COMPENSATION
$ $ $ $ ADMINISTRATIVE LAW JUDGE SUZANNE F. $ DUGAN
(39) WCAB OPINION & ORDER DENYING PETITION FOR RECONSIDERATION
(40) 2ND MOTION/PETITION FOR RECONSIDERATION
(41) WCAB OPINION & ORDER DISMISSING PETITION FOR RECONSIDERATION