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Wo/Men's Alliance for Medical Marijuana (WAMM)
The facts about: the County of Santa Cruz et. al. vs. Gonzales et. al


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Important Documents
The Complaint
  WAMM Order (.pdf)
  Motion for Preliminary Injunction

  Judicial Notice Request
  WAMM Protocols and Guidelines

Meet the Plaintiffs

  More about the Plaintiffs

  Their Declarations

  1.   Valerie Corral

  2.   RIP Eladio V. Acosta (of cancer)

  3.   Jennifer Lee Hentz

  4.   Harold F. Margolin

  5.   Levi Castro - Quadriplegic &  business
      owner More soon...

  6.   RIP Dorothy Gibbs
      (of Post-polio complications)

  7.   RIP James Daniel Baehr

  8.   RIP Michael Cheslosky
      (of AIDS/Bone Cancer)


Supportive Pleadings

  Arnold S. Leff M.D.

  Earnest H. Rosenbaum M.D.

  Harvey L. Rose, M.D.

  Neil Flynn, M.D.

  Robert Brody, M.D.


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Dorothy Gibbs -
RIP from post-Polio complications


Frank Kennamer (SBN 157844)

neha nissen (SBN 190848)


Three Embarcadero Center

San Francisco, California  94111-4067

Telephone:  415.393.2000

Facsimile:  415.393.2286

Attorneys for WAMM Plaintiffs


Gerald Uelmen (SBN 39909)

Santa Clara University School of Law

500 El Camino Real
Santa Clara, California 95053

Telephone:  408.554.5729

Facsimile:  408.554.4426

Attorney for County of Santa Cruz
and WAMM Plaintiffs



county of santa cruz, California; City of santa cruz, california; Valerie Corral; Eladio V. acosta; james daniel baehr; Michael cheslosky; jennifer LEE hentz; dorothy gibbs; harold F. margolin; and Wo/men’s alliance for medical marijuana,



Alberto Gonzales, Attorney General of the United States; JOHN BROWN, III, Acting Administrator of the Drug Enforcement Administration; John P. Walters, Director of the Office of National Drug Control Policy; and 30 UNKNOWN Drug Enforcement Administration AGENTS,


Case No.:_________________






I, Dorothy Gibbs, declare as follows:

1.         I was born on February 18th, 1910 in Chicago, Illinois.  I am currently 93 years old.  I reside in Santa Cruz, California, where I have lived for approximately 40 years.  I have two children, aged 72 and 64, two grandchildren, four great grandchildren and four great- great- grandchildren.

2.         In 1911, at the age of one, I contracted the polio virus.  Perhaps because the virus had been so recently identified, the doctors were at first unable to accurately diagnose my illness.  When I was four or five years old, I was properly diagnosed with polio and sent to Chicago’s Children’s Hospital, where I lived with other children who had polio and other disabilities.  I stayed there until I was 13 years old, when my grandmother brought me to California to join my mother and siblings. 

3.         When I was a baby, I was paralyzed from the waist down.  By the time I left Children’s Hospital, after years of exercise and massage, I was able to walk with crutches and braces.  When I moved to California, I began to attend public school with my sisters and brothers.  I graduated from school and went on to marry and have children.  I lived most of my adult life with my sister Helen, and her husband, and I was responsible for maintaining our home and caring for the children.  Despite my disability, I was able to live a healthy and productive life well into my sixties.

4.         The early onset of polio caused permanent damage in my legs, spine, and back, resulting in significant weakness and atrophy in my legs.  As a result, I have never been able to walk without the assistance of crutches and braces or a wheelchair.  Approximately 30 years ago, my condition began to deteriorate.  I began to suffer from increasing levels of pain and weakness in my legs and back as well as severe osteoarthritis in my hands, arms, and joints.  Over time, my deteriorating medical condition has been exacerbated by my pain, leaving me increasingly immobilized.

5.         I suffer from muscle spasms in my upper shoulders, back and neck.  I have also been diagnosed as having post-polio syndrome, a medical condition that affects polio survivors several decades after the initial onset of the virus. This syndrome causes muscle weakening and chronic pain.  Over the years I have suffered from a variety of illnesses, receiving several diagnoses including osteoarthritis, tendonitis, fibromylgia, subcapular bricitis, myofacial muscle spasm, disc disease and bladder spasms.  My polio (or post-polio syndrome) causes further pain, as well as complicating each of these other diseases and disorders.

6.         The result is that I have been in nearly constant pain for decades.  At some point in the mid 1980’s, I began experiencing painful spasms in my left shoulder.  In approximately 1991, I began to experience severe thoracic pain, which felt like a rope twisting in my back and grew progressively worse with time.  The pain is often so severe that it literally grabs at me while I am sleeping and pulsates throughout my neck and back, waking me up to excruciating pain. 

7.         For periods of time since the mid 1980’s I have been homebound, because moving my body is simply too painful.  During these periods, I spend upwards of twenty hours in bed, trying to avoid moving to lessen the incessant pain.  My condition has become progressively worse and I am now permanently homebound. I leave the house only to see my doctor. 

8.         Beginning sometime in the 1970’s, I could no longer take care of my basic needs and required the assistance of in-home health care services.  Over the years many people have helped me with my cooking, cleaning, hygiene needs, transportation to the doctors, paying my bills and almost everything else that I need to survive.  I have become completely dependent on these caregivers. 

9.         In 1974 I hired Pat Dare Ramey to come work for me as an in-home care person through Visiting Nurses of Santa Cruz.  Pat helped me with activities that I was no longer able to take care of for myself such as laundry, housekeeping, and shopping.  Even after she was no longer employed by Visiting Nurses Pat continued to visit me frequently and she even cut, permed, and fixed my hair.  Over the years Pat has become a dear friend and is part of the family.  Pat has managed my care, working with me and coordinating the other in-home support caregivers who have helped with my care.  Pat has also helped me verify the contents of this declaration.

10.       Since 1988 Dr. Arnold Leff, M.D. has been my primary care physician.  Over the years, he has prescribed many different medications and treatments to combat my pain.  For example, in the late 1980’s, I used an electrical shock therapy system called a TENS (Transcutaneous Electrical Nerve Stimulation) unit as a form of pain therapy.  This provided me with some relief, but lost its effectiveness as my condition worsened. By the mid-1990’s it was not of much use.  It was also problematic in that it burned my skin.  Dr. Leff eventually told me to discontinue using the TENS unit.  By the mid 1990s, I had also tried several kinds of oral pain medication, including Tegrtol, Daypro, Vicodin, Lodine, and Dolibid, but none of them worked and many of them made me nauseous and often made me very dizzy.  Because of these complications, my physician discontinued all of these medications.  Also, in 1995, I tried multiple local anesthetic infiltrations in my left scapula area.  I consulted Dr. William H. Hess, M.D., at the Pain Management Clinic at Dominican Hospital in Santa Cruz, California.  Dr. Hess performed thoracic epidural steroid injections of Depomedrol.  I had high hopes for this treatment, but this was again ineffective in relieving my pain.  Nothing seemed to help, and the pain continued to get worse.

11.       In September 1995 my health took a marked turn for the worse when I fell out of my wheelchair while trying to get into bed.  I lay on the ground for several hours before help arrived.  After this fall the muscle spasms in my shoulder, back and legs became even more extreme.  I was no longer able to control my body well enough to transfer myself to or from my bed. 

12.       After the fall, I began to experience an increased amount of pain. As a form of relief, Dr. Leff prescribed a Duragesic patch that contains the opiod Fentanyl.  The Duragesic patch is an adhesive pad that I place on my skin.  Fentanyl is released slowly from the patch into my skin over a three day period, after which time the patch needs to be changed.  Although Fentanyl made me nauseous and dizzy, the patch did provide a respite from the pain. But as I continued to use the patch the nausea and dizziness got much worse – so much so that I was basically bed-ridden.  Nothing I tried could eliminate these awful side-effects.  After consultation with my physician I ultimately had to discontinue using the patch in 1996, and the pain in my neck, back and legs persisted.

13.       By May, 1996, my physician had tried various prescription medications to relieve my pain, including:  Tylenol #3, Ultram, Daypro, Tegretol, Soma, Valium, steroid injections into the trigger point, Dilantin, Duragesic, Zofran and Comapazine for the nausea caused by the opioid pain relievers, and Doloboid and Lodine as nonsteroids.  Nothing seemed to work, and the pain persisted.  I was growing increasingly depressed by the inability of anything to relieve my pain.

14.       In January 1997 I fell out of bed again, this time injuring my neck.  By now, I was in pain 24 hours a day.  I was referred to Dr. Cathleen Miller, M.D. at the Neurology Medical Group of Santa Cruz.  I went to see Dr. Miller several times, and was then referred to Dr. Robert Quinn, M.D., the Medical Director of Rehabilitation Services at Dominican Hospital in Santa Cruz.  Dr. Quinn suggested that a new wheelchair might help relieve some of the pressure on my back, so I purchased a higher quality wheelchair and went through a series of sessions with an occupational therapist in my home.  Unfortunately, nothing really helped.  I fell again in July, 1997 and injured my neck and arm.  I was unable to take any pain pills or Motrin because they caused me to vomit, even with the help of Compazine.  The pain was so comprehensive that it was too painful to even roll over to use a bedpan, soI had to be catheterized to urinate.  Since neither my caregivers nor I could effectively move my body in and out of bed, I began using a Hoyer lift.

15.       In late 1997, Dr. Leff again prescribed a Duragesic 25 MCG transdermal patch.  After an initial period of extreme nausea upon starting the patch, I was able to withstand the side-effects and was happy with it for awhile.  Even though it caused me some nausea and dizziness, it did provide some relief, and I continued to use the Duragesic patch, together with Halprin, for some time.  Unfortunately, my success with the patch did not last.  With the dose that I needed to relieve my pain, the side effects worsened.  I became increasingly ill and lethargic, to the point that I felt like a ‘zombie.’ I was so sleepy that I could not stay awake long enough to take a drink, and I became dehydrated.  I again used Compazine for my nausea, but I had a hard time swallowing the pills.  Eventually, with all of the negative side-effects, I had to stop using the Duragesic patch to treat my neck, back and leg pain.

16.       During this period it was clear to me, my caretaker and my physician that nothing was working to combat my pain.  My caretaker, Pat, had heard of the success some people experience with the medicinal use of marijuana for pain management.  Sometime during the end of 1997, she obtained a sample for me. Although I had never used marijuana in my previous eighty-seven years of life, I was willing to try anything that could alleviate even part of the pain.

17.       The relief I experienced from medical marijuana was almost immediate.  I was so pleased with the result that I wrote to Dr. Leff about my use of medical marijuana and we talked about the benefits of the medicine.  Dr. Leff examined me and noted that medical marijuana  helped me experience less chronic pain and nausea,  leading him to recommended medical marijuana as part of my daily pain care regimen.  In addition, in November 1997 Dr. Leff signed a letter at my request affirming the benefits of medical marijuana for my care.

18.       I strongly feel that I should have the right to use anything that may  relieve  any or some of my pain, and my last  days should not be spent suffering.  In 1998, around the time that I had to stop using the Duragesic patch, Dr. Leff prescribed 5 milligram tablets of Marinol, to be taken as needed, for pain management.  He explained that Marinol was like marijuana, which I was already using on occasion.  Although Marinol provided me with some minor relief from muscle spasms and bodily pains, its effect was slow and unpredictable.  I found that I had to ingest up to six pills to achieve even a small amount of relief, and it often took over two hours for the pain to subside.  I was sometimes left in excruciating acute pain while waiting for the Marinol to work.  While Marinol seemed to help with some of my pain, its  slow and unpredictable nature meant that I had to continue to use my other medications.  However, by combining Marinol and medical marijuana I am able to combat my pain  and nausea without  the lethargy and incapacitation  I experienced with the patch.  Marinol addresses normal levels of chronic pain, as long as I am not experiencing an episode of acute pain.  At times, however, I am  stricken with severe spasms of pain, and medical marijuana is the only medication  that  provides  quick and effective relief.  During these periods of extreme pain, I have to call a caregiver to immediately administer the medicine.  After these dosages, it only takes about fifteen minutes  to experience  substantial relief. The Marinol is neither fast enough nor strong enough to relieve such pain, even when I ingest as many as six capsules at time.  Medical marijuana also combats the nausea that accompanies many of the oral medications I am prescribed, including anti-inflammatory medications such as Motrin.

19.       Ever since trying medical marijuana , my life has drastically improved.  Although chronic pain, related to my post-polio syndrome will always be a part of my life, medical marijuana had helped me manage this pain.  by providing  fast and effective relief for my muscle spasms, acute pains, and arthritis.

20.       In 1999, Pat heard about the Wo/Men’s Alliance for Medical Marijuana (WAMM) through one of my neighbors.  Since medical marijuana had significantly improved my health, Pat called WAMM to see if they could help me.  I joined WAMM on July 26, 1999.

21.       Since I began  using medical marijuana, my pain is no longer persistent or debilitating. When I do suffer from pain, I am usually able to “get ahead of it” by using medical marijuana and make it manageable.  I still suffer from a series of health problems that accompany both my post-polio syndrome and my advancing age, including recurring persistent rashes, difficulties with my sight, and occasional urinary tract infections.

22.       WAMM and its members have given me incredible support and love.  I abide by all of the rules of WAMM.  I use all of my medicine myself in my home.  I never take any medical marijuana out of the State of California.  I do not have very much money, so I am grateful that I do not have to pay for my medicine through WAMM.  WAMM has helped me add years to my life and has given me happiness.

23.       Medical marijuana is extremely important to my continued health.  I firmly believe that I should have the right to alleviate my suffering and to die without being in constant pain.  As a 93 year old suffering from a terrible disease, life without medical marijuana would relegate me to a position similar to a wounded animal – helpless, easily broken, and vulnerable.  I believe now, as I did six years ago, that the federal government should not be


allowed to interfere with my ability to obtain and use medical marijuana to relieve me of my chronic pain and to make my last days as comfortable as possible. 

24.       Since the WAMM gardens were raided by the Drug Enforcement Administration on September 5, 2002, I have been in constant fear that I will lose the one safe and legal source of medical marijuana available to me.  Since September, my dosage of medicine from WAMM has decreased from 7 grams per week to 5 grams per week.  I have started to receive gel tabs from WAMM which I am using as a substitute for smoked marijuana at night.

25.       I am 93 years old and restricted to my bed.  I am both too frightened and too disabled to consider buying medical marijuana on the streets or any place other than WAMM.  I understand that medical marijuana is legal in California, and that WAMM has been recognized by the City of Santa Cruz as an official medical marijuana provider.  If I did not get my medical marijuana from WAMM, I have no idea where I would get my medicine.

I declare under penalty of perjury under the laws of the United States of America and the State of California that the foregoing is true and correct to the best of my knowledge, and that this declaration was executed on this Twenty First day of April, 2003, in Santa Cruz, California.




Dorothy Gibbs

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