WHAT I LEARNED TO WRITE AND FILE A COMPLAINT AGAINST MARION COUNTY IN THE UNITED STATES DISTRICT COURT, DISTRICT OF OREGON, PORTLAND AND EUGENE DIVISION, RESULTING IN A MOTION FOR APPOINTMENT OF PRO BONO COUNSEL

Individualized treatment: “Individuals with disabilities must be treated on a case-by-case basis consistent with facts and objective evidence” (Ref. 20 - See, e.g., 28 C.F.R. ~ 35.130(b); see also 28 C.F.R. pt. 35, App. B (explaining in 1991 Section-by-Section guidance to the Title II regulation, “ that, taken together, the provisions ((in 28 C.F.R. ~ 35.130(b)) are intended to prohibit exclusion . . . of individuals with disabilities and denial of equal opportunities enjoyed by others, based on, among other things, presumptions, patronizing attitudes, fears, and stereotypes about individuals with disabilities.” Consistent with these standards, public entities are required to ensure that their actions are based on facts applicable to individuals and not presumptions as to what a class of individuals with disabilities can or cannot do. (Ref. School Bd. of Nasssan County v. Arline, 480 U.S. 273, 285 (1987) of U. S. Department of Health And Human Services, U. S. Department of Justice, and Civil Rights Section).