Free Motion for Miscellaneous Relief - District Court of Arizona - Arizona

Case 2:O4—cv—OO534-NVW D0cument41—3 Filed O9/19/2005 Page10f3

Declaration of Ruth Garcia
I, Ruth Garcia, declare under penalty of perjury the following to be mie to
the best of my information and belief:
€T.\$\`i\`<&Q_.r\ l
l. I was sewenteen years old when l became pregnant with my son, Bobby
Poyson. At the time, I lived in Colorado with Richard Sandoval. Richard
and I had been together for about three years then and we already had one
child, Bobby’s brother, Raymond. Richard was a camival worker, but he
also sometimes work in the fields with me picking onions or apples.
2. Richard and I used a lot of drugs (LSD and marijuana) and alcohol when we
were together. I drank a lot of fortified wine. I continued to drink fortified
wine at least through the first three months of my pregnancy with Bobby. I
smoked marijuana throughout the whole pregnancy and also smoked a pack
of cigarettes every day while I was pregnant.
3. Richard and l broke up before Bobby was born.
4. l remember that Bobby was very slow to learn to crawl and walk and speak.
He didn’t start crawling until he was 18 months old. Even after he learned
to walk, he would drag his left foot behind him.
5. Bobby didn’t start talking until he was three years old. Once he leamed to
1 Initials` [

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talk, he had a lisp and a stutter.
6. Bobby had fainting spells when he was young. He also had problems with
ear infections.
7. Bobby had to go the emergency room when he was I3 because he hurt
himself by jumping off the roof of a shed.
8. My husband, Sabas Garcia, killed himself when Bobby was ll years old.
Bobby was very close to Sabas and his death had a terrible effect on Bobby.
Not long after Sabas died, Bobby began staying away from home a lot. I-Ie
was distant from the family, he began having more trouble in school, and he
even started causing trouble. I remember that around this time Bobby stole
a bike and destroyed it.
9. After Bobby was released from St. Anthony’s Correctional Center when he
tumed 18, he came to live with me in Laughlin, Nevada.
I declare under penalty of perjury under the laws of the United States of
America and the State of Arizona that the foregoing is true and correct.
Signed this day of r`T€5Q_g""?>\· , 2005, at Laughlin, Nevada.
C`;T> '
B A if jCQTa-\Q Ll Lg
Ruth Garcia
s 2 i¤iaa1QQ_;QQ____
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