FIRST SET OF FACTS
 
 
 
While held in Los Angeles County Sherriffs’ custody in the summer of 2010 (the exact date of this incident is uncertain and must be pinpointed in the discovery phase), after I had already been strip searched upon entry of the Los Angeles County Lynwood Jail, days later I was transported under close officer supervision to the Sherriff Department’s own lockdown section of the downtown medical emergency room.  Once there, the supervising officers took me behind the metal bars, which only open electronically, into their high security emergency room, and they kept me handcuffed to medical gurneys the entire time period.  When exiting the sherriffs’ emergency room section, I was kept in handcuffs all the way to the transporting bus, the whole time on the bus back to Lynwood, and all the way back to inside the Lynwood facility.  
 
During the trip back, the officers that were transporting me and a few other women from the sherriffs’ emergency room rolled the front windows othe transport bus considerably down when going full speed down highways back to Lynwood causing strong, whipping winds to continually blow harshly into the faces of us women in the back seat.  The wind was blowing my hair, and my hair was getting stuck in my eyes.  I complained to the transporting officers a couple of times about how my eyes were hurting from the whipping wind blowing my hair into my eyes, but these complaints were completely ignored.  I complained again about the problem, this time a little louder.  A “female Doe” officer responded by abusively yelling “SHUT UP!”  Shortly thereafter, I informed the abusive officer that I felt her yelling was misconduct and that I intended to report it as soon as I had a chance.
 
When we all arrived back at the Lynwood facility, the “female Does” took us inside a room and then we were all loudly ordered to take off all of our clothing, including our bras, underwear and tampons.  We then were ordered completely to bend over with our legs spread apart for an uncomfortably extended period of time and to fully expose our private areas.  While we were kept bent over with legs spread apart stark naked, Officer “female Doe” who was directly behind me made lewd, unnecessary, offensive comments such as “Look how clean her pussy is.”   The officers abusively yelled at us throughout the majority of this unnecessary full cavity strip search.  I along with the other ladies were publicly humiliated, degraded and traumatized from that unconstitutional search.  
 
Other inmates informed me that usually when they returned back to the Lynwood facility after an officers’ fully supervised visit to the sherriffs’ lockdown section of the emergency room, they usually were not subjected to unnecessary full-cavity strip searches upon reentering Lynwood, but on rare occasions they were.  I have also read in the Los Angeles Times that inmates in the mens’ sherriffs’ jail downtown are publicly complaining that they also are being unconstitutionally victimized by needless, sporadic full-cavity strip searches.  During the other occasions they returned me to the Lynwood facility after an officers’ fully supervised visit to the sheriffs; lockdown section of the emergency room, I normally was not subjected to a strip search upon reentering Lynwood.  Therefore the specific full-cavity strip search that I went through as described above was part of an unconstitutional pattern of the Los Angeles Sherriffs’ subjecting inmates of both genders to unnecessary full-cavity strip searches that are degrading, humiliating, embarrassing, distressing and traumatizing.   When inmates are subjected inhumanely to full-cavity strip searches after they have already had one and were under full supervision the whole time until the second, unnecessary strip search, that constitutes a violation of American citizens’ constitutional rights to regulated searches.  When Los Angeles County Sherriffs’ officers arbitrarily choose to subject inmates to these unnecessary strip searches while under color of law, they are violating the American Constitution.  There was no excuse for the officers to have put me through such an unconstitutional full-cavity strip search, nor is there any excuse for the officers to be continually subjecting other inmates to these unconstitutional strip searches in their Los Angeles lockup facilities.  This must be stopped.  I demand justice for that specific unnecessary strip search and the unfair, unconstitutional pattern the Los Angeles County Sherriffs have of sporadically and unnecessarily subjecting me and other people held in their custody, who were already strip searched upon initial entry to their lockup facilities, to additional unnecessary, degrading full-cavity strip searches.