Declaration of Angela Clemente

I, Angela Clemente, declare and state the following:

1. On December 17, 2013 I was made aware of Jahi McMath delicate medical situation and the treating hospital’s position. On that same day I contacted Chris Dolan the attorney representing her interests and offered my assistance and explained to Mr. Dolan that I can pull a team of specialized experts on this type of subject matter both legally and medically to assist him with his client’s needs.

2. I then immediately began to notify each party whose expertise handles the life flight transportation needs, forensic, legal, medical and death experts, housing needs for the family, fundraising, media relations and both acute care and sub-acute care facilities that are open to accepting Jahi McMath into their facility for placing a PEG and Tracheostomy and for long-term care.

3. As an experienced expert in the subject matter of legal, medical, congressional and judicial issues surrounding patients in these similar situations I understand that courts, hospitals, and attorneys are not always aware that there are teams of skilled and specialized experts who specifically step in as a team effort to address the needs of medically vulnerable patients who face the same obstacles as Jahi McMath is facing now. This declaration serves as a formal notice to the court that Jahi McMath does indeed now have a full team of experts supporting all her needs identified in paragraph 2. I will outline within this declaration for the court the expertise and organization[s] and/or individuals who are now working on her behalf.

4. The medically appropriate life flight transportation needs for Jahi McMath from California to New York will be fully covered through our teams efforts.

5. We currently have one confirmed long term care facility that has offered to care for Jahi McMath and we have an additional potential long term care facility. The accepting facility’s formal written acceptance letter will be provided to the court with this declaration as an additional exhibit identified as exhibit A.

6. The housing needs for the family of Jahi McMath has also been provided by our team. The address for their residence in New York is as follows: [address redacted].

7. Our team will continue to follow through with other unanticipated needs that may arise for Jahi McMath and her family.

Hereafter is a summary of our team of specialized experts:

—David Hammons MD is a retired Emergency Medicine specialist, previously board certified. He has more than 20 years’ experience on his hospital’s ethics committee and took the National Catholic Bioethics Center’s one year certification course in Catholic Bioethics. He taught for 9 years on the faculty of the Kaiser-Stanford University Emergency Medicine residency program. He has given talks on end of life care from a medical, legal, and ethical perspective.

—Steve Sanborn has extensive experience with life flight transportation needs, emergent fundraising, and media relations. Mr. Sanborn and I handled in full one of the most significant and successful cases in the United States related to out-of-state transfers and acceptance of a critical patient receiving blood and respirator dependent who was declared medically futile. Prior to the patients release and move from the hospital whose care the patient was under we successfully launched a federal investigation into the county hospital’s substandard care and fraudulent Medicare practices resulting in Medicare forcing the hospital to return $284,106.20 back into the patients Medicare account and escalating the federal violation against the hospital under Part A Tier 2 as “severe” and sending a federal investigator in to the hospital to initiate and force “provider education” without which the hospital’s doors would be closed.

—Angela Clemente is a Forensic Intelligence Analyst, Congressional Consultant and Paralegal. I have worked with the executive, judicial, and legislative branches of the government on many high-profile cases on criminal violations related to federal crimes in both medical and criminal cases. I have twenty years’ experience in the field of pathology, clinical laboratory, and emergency medicine. Additionally, I have extensive experience working with the Department of Justice Office of Inspector General, the U.S. House of Representatives and U.S. Senate on legislative needs, congressional investigations pertaining to systemic criminal and medical problems and advising on and launching state and federal prosecutions against official misconduct. In the year 2008 to the present date I launch and lead the team efforts with uniquely qualified experts in the fields identified in paragraph 2 for assisting vulnerable patients in identical and similar medical states as Jahi McMath. Additionally, I assess, review, identify and advise on medical negligence cases also aiding in the launch of forensic criminal investigations on these same subject matters.

—Bobby Schindler and The Terri Schiavo Life & Hope Network is a national enetwork of resources and support for the medically-dependent, persons with disabilities and the incapacitated who are in or potentially facing life-threatening situations. It has communicated with and supported more than 1,000 families, and has been involved in hundreds of cases since Terri’s March 2005 death.

—Dana Cody—Life Legal Defense Foundation is a public interest law firm that provides resources to defend the lives of vulnerable human beings who are under threat of death because life-sustaining care is not being provided. LLDF provides continuing legal education on the issue of forced death. Notably, LLDF helped support the defense of Terri Schindler Schiavo’s life. LLDF has been a part of the effort to defend Jahi McMath’s life and continues to support efforts to see Jahi moved to a facility that will treat her with the dignity she deserves.

—The Wrongful Death and Injury Institute is multifaceted organization that specializes in the unethical and unprincipled practices of the healthcare industry and unregulated death investigation system nationwide within hospitals, prisons, jails, nursing homes, and assisted living residences.

—Dr. Paul A. Byrne is a neonatologist and a Clinical Professor of Pediatrics. He is past President of the Catholic Medical Association. He is the producer of the film Continuum of Life and the author of Life, Life Support and Death, Beyond Brain Death, and Brain Death is Not Death. Dr. Byrne has presented testimony on life-death issues to nine state legislatures beginning in 1967. He opposed Dr. Jack Kevorkian on Cross-Fire, and has appeared on Good Morning America, the British Broadcasting Corporation (BBC) documentary, “Are the donors really dead?”, and public Television in Japan. He is the author of many articles in medical and law journals and the lay press.

I declare under penalty of perjury that the foregoing information is true and correct.

Executed this 29th day of December 2013.

/s/ Angela Clemente


[This document was prepared in extreme haste when Jahi’s life was literally on the line. It is here reproduced as submitted to the Alameda County Superior Court on Jahi’s behalf December 29, 2013.—Ed.]

Courts, hospitals, and attorneys are not always aware that there are teams of skilled and specialized experts who specifically step in . . . to address the needs of medically vulnerable patients

Author: Life Legal

The Life Legal Defense Foundation is a non-profit law firm that specializes in the defense of vulnerable human life, especially life in the womb.