DoD’s Breach of Trust

Because the Department of Defense (DoD) has not acknowledged (concealed) the true nature and extent of the environmental contamination at the former George AFB and its Completed Exposure Pathways (CEP):

• Doctors cannot treat the toxic exposures of base personnel and family members.
• Military personnel are being defrauded of their Medical Discharge, Military Pension, and medical care (TRICARE).
• Military personnel’s family members are being defrauded from their medical care (TRICARE).
• Veterans are being defrauded of their VA Service Connected Pension and VA medical care.
• Veterans’ family members are being defrauded from their VA medical care (CHAMPVA).
• Parents were never given the choice of whether or not to have children because these parents were not provided information about their toxic exposure and the possible effect that it may have on their pregnancy and unborn children.
• The two schools on George AFB remained open for 15 years after the base was closed, potentially exposing the children and staff to environmental contamination.

Fraud or Deception

A. Prima facie elements of fraud/deception by act or commission:

1. 1. A written or verbal statement of fact (not opinion or humor…) that the author or speaker knows (intent) or should know (negligence) is false
   2. Which statement is communicated to one or more third-party/person, i.e., the plaintiff(s)
   3. The plaintiff(s) relied on the statement(s) to their detriment
   4. The reliance was reasonable under the circumstances,  and
   5. The plaintiff(s) was injured as a direct result of the false or deceptive statement(s)

B. Prima facie elements of fraud/deception by omission:

1. 1. The intentional failure to disclose, whether in writing or  verbally, a fact or facts AND/OR the negligent failure to disclose, whether in writing or  verbally, a fact or facts which a person has a duty to disclose to others under the circumstances
   2. The fact or facts that were not disclosed were material and relevant to the transaction(s) between the parties
   3. There is/was no legally recognized excuse or  justification for failing to disclose the material fact(s)
   4. The plaintiff(s) was injured as a direct result of the intentional or negligent failure to disclose the material fact(s)
   5. The failure to disclose was the proximate cause of the plaintiff(s)’ injury

Negligent homicide

In California, Negligent homicide is a criminal offense in which a person commits some act of criminal negligence, and it results in the taking of human life. Criminal negligence refers to conduct in which a person ignores a known or obvious risk or disregards the life and safety of others. Under California law, negligent homicide cases are charged as involuntary manslaughter, per Penal Code 192b PC.

Completed Exposure Pathways (CEP)

“A completed exposure pathway (CEP) links a contaminant source to a receptor population, and people are likely to have been exposed to the substance.”
Source accessed on: 30 May 2013:  http://www.atsdr.cdc.gov/cep/