Petition for Independent Audit
and Records Reconciliation

I was employed as a sworn peace officer with the UCLA Police Department, having previously served with the San Gabriel Police Department (1983–1985), Culver City Police Department (1985–1988), and graduated from Rio Hondo Police Academy in 1983. My pre-UCLA medical record —

five separate examinations across three employers from December 29, 1980 through December 1, 1989 — uniformly documented a normal heart with no cardiac abnormalities of any kind.

During a Regents' meeting on the UCLA campus, I wrote a parking citation to a vehicle operated by a UC Regent. I was immediately ordered by Assistant Chief Allen Cueba and Lt. James Vandenberg to cancel the citation. I was told the cancellation was directed by UCLA Chancellor Charles Young and UC Regent Dean Watkins. I complied with the direct order of my supervisory chain.

I was not a secondhand reporter of this event — I was the officer who wrote the ticket and was directly ordered to participate in its cancellation.

This event is documented in my contemporaneous records (SCOTT_WC.docx, entry dated 7/90). Cueba and Vandenberg — the same two officers who ordered the cancellation — subsequently became central figures in the retaliatory campaign documented below.

At department elections for the newly formed Police Officers' Association (POA), I was nominated for president. Lt. Vandenberg and others informed me it would not be a good idea to accept the nomination because management was looking at releasing me from probation due to my "outspoken attitude." I declined in fear of termination.

Threatening an employee with termination for accepting a union nomination constitutes a per se unfair practice under the Higher Education Employer-Employee Relations Act (HEERA, Government Code § 3571(a)).

I founded the Federated University Police Officers' Association (FUPOA), the first National Labor Relations Board-recognized statewide law enforcement bargaining unit in the history of the University of California police system. I named it FUPOA rather than "University Police Officers Association" specifically to comply with California Education Code § 92000, which restricts use of the word "University" — demonstrating my knowledge of and compliance with applicable law from the outset.

I personally initiated and conducted a criminal investigation (Offense Report #01-90-004164) documenting systematic criminal activity inside the UCLA Center for Health Sciences, including: systematic theft of $10,000–$15,000 in hospital supplies by housekeeping supervisor Issac Thompson; an extortion and job-selling scheme ($600–$2,000 per hire); prostitution on duty; and narcotics in the facility. I recorded eight conversations with a confidential informant and placed the recordings into evidence (Property Report #0190000204). Detective Longo conducted follow-up investigation.

I began experiencing stomach problems every night before work, increasing when working, not occurring on days off.

I believed I was having a heart attack. I experienced chest pains, shortness of breath, left arm pain, nausea, and dizziness. My wife drove me to St. John's Hospital Emergency Room.

Under the direct order of supervisor Lt. Michael Shain, I filed my first workers' compensation claim for my heart and stomach conditions.

Heart tests at St. John's Hospital under Dr. Joyce Herrold's direction. Nuclear medicine report by Dr. Julian R. Karelitz documented "right ventricular enlargement" — thallium dye showed "non uniform" distribution with "minimal reperfusion in the inferoapical region" — with recommendation for evaluation for cardiomyopathy. Stress treadmill by Dr. Harry Rockoff showed occasional PVCs with exercise and recovery.

This is the first documented cardiac damage in my medical record, occurring sixteen months after I started at UCLA. Every pre-UCLA examination had documented a normal heart.

Under California Labor Code § 3212.5, heart trouble developing or manifesting during a period in which a peace officer is in active service is presumed to arise out of and in the course of employment.

Applied Risk Management Claims Administrator John Hodson interviewed me about job stressors. At the conclusion of the interview, Hodson stated that my filing of a workers' compensation claim "would not help the grievances" I had filed. Hodson's interview notes subsequently disappeared — Michael Lehman told me the notes "don't exist." I later personally observed a letter from Hodson at Dr. Reynolds' office that referenced that very conversation, proving the notes existed and had been withheld. The notes were never produced.

At a meeting with Chief John Barber, Assistant Chief Karl Ross, and Assistant Chief Allen Cueba, I was offered a transfer away from Lt. Vandenberg's supervision on the express condition that I drop my workers' compensation claim and grievances. I agreed and was transferred. From June 1991 to January 1992, my stomach and heart problems improved and I was asymptomatic.

Against my numerous and documented protests to Chief Barber, Karl Ross, and Allen Cueba, I was transferred back to Lt. Vandenberg's supervision. My medical and personnel problems immediately resumed.

Three command officers had conditioned relief from documented harassment on my surrender of statutory workers' compensation and grievance rights, and the University broke its own agreement upon my compliance.

The resolution and resumption of symptoms upon transfer-in and transfer-back respectively establishes that the University's own chain of command knew Vandenberg's supervision was the cause.

I was placed on paid administrative leave by the UCLA Police Department. I was told by Kit Espinosa that I could return to work as soon as an investigation on Lt. Vandenberg was completed and that this would take approximately three to four weeks. I remained on paid administrative leave for two years and two months.

On July 21, 1992, Tina Simmons offered me my motorcycle assignment back if I dropped my claims. I agreed. Simmons cleared it with Chief Barber. On July 22, 1992 — the very next day — Chief Barber canceled the entire motorcycle program so that I could not obtain the position.

This is a documented next-day retaliatory cancellation in direct response to my exercise of protected statutory rights.

Four independent campus newspaper investigations at three separate UC campuses — not coordinated with each other — documented the same categories of institutional misconduct I was reporting internally at UCLA. The California Aggie (UC Davis, October 19, 1992) documented racial profiling, excessive force, and inadequate oversight at the UC Davis Police Department. The Highlander (UC Riverside, May 18, 1993) documented the same patterns at the UC Riverside Police Department. The Corsair (Santa Monica College) published a two-part investigative series directly on the UCLA Police Department on March 16 and March 23, 1994, documenting my whistleblowing activities, the retaliatory campaign against me, and the broader pattern of command staff misconduct I had exposed. The Los Angeles Times published coverage of my case on February 25, 1993 and April 24, 1994.

Without notifying me, claims administrator Michael Lehman subpoenaed my St. John's Hospital medical records.

Lt. Vandenberg attended a mutual aid training session in Orange County and stated to officers in the class — including my friend Paul Christie — that I was "a paranoid schizophrenic, cocaine user," that I had filed workers' compensation claims for stress, and that the department "was definitely going to...force him out...he won't get his job back." Christie called me from the training course. I called Assistant Chief Ross. Christie subsequently produced a tape recording of the entire training session that captured Vandenberg's statements verbatim,

proving that my account was truthful and that the department's initial internal investigation finding — that I was lying — was factually wrong.

Vandenberg was demoted as a result.

Co-plaintiffs and I filed Harold v. The Regents of the University of California, Case No. SC022125, in Santa Monica Superior Court, alleging discrimination, whistleblowing, acts against public policy, sexual harassment, and corruption. Karl T. Ross was named as a personal defendant. The Los Angeles Times published coverage on February 25, 1993, and April 24, 1994.

I filed multiple formal grievances against UCLA PD command staff. All grievances were subsequently decided in my favor. One year after first filing grievances, and one year into my paid administrative leave, I wrote to Chancellor Young: "I am still on leave for no apparent reason or justification, getting paid full salary and benefits of over $42,000.00 a year, to sit at home and do nothing. This does not make any sense to me."

I wrote formally to UC President Jack Peltason documenting the ticket-fixing case "directed by Chancellor Charles Young, U.C. Regent Dean Watkins, and U.C.L.A. police administrators" and the full pattern of institutional misconduct I had documented.

This created a governance paradox: the person to whom I was constitutionally required to report command staff misconduct was himself implicated in the misconduct I was reporting.

While I was on paid administrative leave, UCLA PD assigned Lt. Michael Shain — a named defendant in my active civil rights case SC022125 — to conduct an internal investigation of me. Lt. Shain's investigation report alleged I had displayed my personal firearm and police identification to obtain information from a bank. I obtained the UCPD Property Sheet Log from the UCLA PD Property Division, which documented that Lt. Boyarski had taken possession of my personal weapon, badge, and police identification approximately one year before the date of the alleged bank incident in Shain's report.

The UCLA Police Department had my gun, badge, and police identification in its own property room, per its own official property records, at the time the alleged incident was claimed to have occurred.

Chief Chapman convened a pre-termination due process hearing consistent with Skelly v. State Personnel Board (1975) 15 Cal.3d 194. When I produced the UCPD Property Sheet Log proving Shain's report was fabricated, Chief Chapman stated "This conversation is over" and walked out. I was not terminated. I was reinstated to full active duty. Lt. Michael Shain was terminated from the UCLA Police Department for falsifying the investigation report. The University had assigned an officer who was a named defendant in my pending civil rights lawsuit to build the case for my termination, and he fabricated the evidence.

I filed a formal whistleblower complaint under California Government Code § 8547.10.

No UC response has ever been received. This filing has been on record for 32 years with no institutional response of any kind.

I returned to active patrol duty at UCLA PD following two years and two months of paid administrative leave (from June 17, 1992). I had passed all fitness-for-duty evaluations — including EKG and a five-hour psychiatric evaluation — both of which cleared me as fit for duty.

I filed a federal lawsuit with co-plaintiff officers (University Police Officers v. Regents, Case No. 2:96-cv-00396-WDK-AJW, U.S. District Court, Central District of California) to recover over $1 million in compensatory overtime that the Chief refused to pay officers in violation of the Fair Labor Standards Act. I and the officers prevailed. UC paid over $1,000,000 in back pay to officers system-wide.

I encountered Chief John Chapman in the UCLA PD parking lot on my day off. I described my cardiac condition and told him I was considering leaving police work because of the health effects. Chief Chapman responded that based on what I described, my condition "should be a slam dunk" for a 100% tax-free medical retirement.

UC's own Chief of Police, on this date, acknowledged in my presence that I was entitled to a 100% tax-free medical retirement. That retirement was never processed.

I sustained an on-duty industrial injury at the UCLA Police Department. Workers' Compensation Claim No. 199650445 was filed. Date of Injury: February 16, 1996.

Dr. Timothy Reynolds documented right ventricular hypertrophy (enlarged heart), possible lateral infarct of undetermined age (heart damage), and an abnormal EKG — all in connection with my on-duty injury.

UCLA PD, under Acting Chief Karl T. Ross — a named personal defendant in my active civil rights case SC022125 — classified me as "medically separated." I received no Duty Disability Income payments from UC for approximately 84 months following this date. Ross subsequently entered a "resigned" classification into the UC system. A "resigned" officer is not a disabled member, not entitled to DDI, not "honorably retired" under Penal Code § 16690, and would not qualify for a CCW under Penal Code § 25455.

Ross's "resigned" entry is the documented mechanism by which DDI payments were suppressed for those 84 months — while I was simultaneously classified as disabled by the same University.

This is the first of fifteen mutually contradictory written classifications UC has issued regarding my employment status over thirty years.

For approximately 84 months following my on-duty injury and medical separation, I received zero DDI payments from UC while simultaneously carrying a disability classification. I was forced to file for bankruptcy. I lost my home. No WCAB order authorized the withholding of these payments. The unpaid DDI for this period, at the subsequently established rate of $3,075.98 per month, is estimated at $150,000–$258,000.

During this period of financial hardship caused by UC's refusal to pay disability income, my wife suffered a miscarriage.

Acting Chief Ross had informed me that UC had up to 120 days to determine whether my injury claim was valid before paying me anything. That delay caused the loss of my home refinance loan, extreme financial hardship, a drive-by shooting at my home, and the stress-related loss of my wife's third pregnancy by miscarriage.

UCLA obtained a court order against my website, BruinWatch.org, through Santa Monica Superior Court contempt proceedings, citing California Education Code § 92000 and trademark claims. BruinWatch.org posted publicly available records about a public trust institution funded by California taxpayers. UCLA did not dispute the accuracy of any content on the site. The same institution that suppressed my publication of UC property records in 1998–1999 now publishes the same category of property information through its own public database at ucop.edu.

Octagon Risk Services — UC's own authorized claims administrator — issued a permanent and stationary disability determination: 6¾% permanent disability, $3,075.98 per month DDI, Workers' Compensation Claim No. 199650445.

This determination has never been revoked, modified, or superseded by any medical authority or by the Workers' Compensation Appeals Board. No WCAB modification order has ever issued in this matter.

UCLA PD issued CCW Permit No. 1, signed by Chief Clarence Chapman. The card states "RETIRED." This is the first institutional acknowledgment of my retired status — six years and six months after medical separation, and four years after dismissal of SC022125 in which Ross was a named defendant.

My workers' compensation case settled. Settlement terms included: lifetime paid health insurance for myself and my family; DDI of $3,075.98 per month, tax-free; and the right to carry a concealed weapon as a retired peace officer.

I was represented by Dennis Hargrove of Mastagni Holstedt. Full DDI payments commenced. This settlement was never submitted to the WCAB for modification. It remains in full legal effect under California Labor Code § 5803 (WCAB continuing jurisdiction).

Andrew D. Parker, UCRP Disability Unit, University of California Office of the President, Human Resources and Benefits — Disability Income, P.O. Box 24570, Oakland, CA 94623–1570, sent me a letter on official University of California letterhead at my then-address of 1625 North Frederic Street, Burbank, CA 91505. The letter is signed in original ink by Andrew D. Parker over the printed signature block “ANDREW D. PARKER / UCRP Disability Unit.”

The verbatim operative text reads: “This refers to your pending request for payment of Duty Disability Income under the UC Retirement Plan (UCRP) following your layoff from Disney effective July 8, 2005. I received the Notice to Employee and the current (5/1/05) UCPD pay rate that you faxed. We also need the following: 1. Evidence of your earnings from Disney and other sources (if any) during 2005; 2. The annual rate for UCLA PD Police Officer step 5 as of January 1, 2005. This information is required so that we can make a benefit calculation with reference to your actual income and the prevailing PD salary for the entire calendar year. Please respond to this letter as soon as possible, but no later than November 10, 2005. If we do not hear from you by then we will consider your request for reinstatement to be withdrawn. In that event, you will be notified and given additional time in which to perfect your claim. [If you experience difficulty in obtaining the requested information, please let us know in advance of that date.]”

Parker’s letter treats my Duty Disability Income payment request as a “request for reinstatement” to be processed administratively upon submission of two ordinary income-documentation items. The letter contains no demand for a new disability determination, no request for a new QME finding, no requirement for any WCAB proceeding, no requirement for any independent medical examination, and no reference to any adversarial process. The mechanism Parker describes is purely an affirmative election initiated by me, processed by the UCRP Disability Unit, and completed without external adjudication.

Twelve years later, in May 2017, the same Andrew D. Parker submitted the sworn declaration in Jacobs v. Regents of the University of California, Court of Appeal Case No. B268758, that established UC’s controlling published legal standard for UCRP duty-disability conversion: “Duty Disabled and Retired are mutually exclusive states” and “a person may convert to Retirement only by making an affirmative election to do so.” The Court of Appeal affirmed. The opinion is published. UC won the case on Parker’s standard.

Parker did not invent the affirmative-election standard for Jacobs. Parker was already applying that standard as routine UCRP Disability Unit operating practice — to my own file — twelve years before he testified to it under oath in court. The September 7, 2005 letter is contemporaneous documentary evidence, on UC’s own letterhead and in UC’s own files, that the Jacobs standard was UCRP’s actual operating practice and not a litigation position constructed after the fact. Parker applied that standard to me personally in 2005 and then testified to that same standard under oath in 2017.

The “Voluntary” checkbox did not appear on any University of California UBEN 100 form until October 2021. UC’s purported 2015 conversion of my classification from Duty Disability Income (1099-R Distribution Code 3) to Service Retirement (1099-R Distribution Code 2) was accomplished without any documented signed UBEN form, without any “Voluntary” checkbox (because none then existed), and without any form-based affirmative-consent mechanism of any kind. Parker’s September 7, 2005 letter resolves that contradiction: the voluntary affirmative-election mechanism existed as operational UCRP practice at least sixteen years before UC’s own forms caught up to it. The absence of a “Voluntary” checkbox on any 2015 UBEN form is a form deficiency — not the absence of the underlying mechanism. Parker processed my voluntary affirmative election in 2005 without any “Voluntary” checkbox by applying the same UCRP practice he later testified to under oath in Jacobs.

Exhibit: EX 50 — Andrew D. Parker, UCRP Disability Unit letter to Harold (September 7, 2005)

UCLA PD maintained me on its active retiree CCW qualification list continuously for approximately 18 years, sending range qualification notices in 2011, 2014, 2015, 2016, and 2017.

UC issued annual IRS Forms 1099-R under Distribution Code 3 (Disability), confirming my income was tax-free Duty Disability Income, each filed by UC under penalty of perjury with the Internal Revenue Service: Tax Year 2010: $30,660.80 gross / $2,244.25 taxable (92.7% tax-free); Tax Year 2011: $31,274.01 / $2,289.13; Tax Year 2012: $31,899.49 / $2,334.92; Tax Year 2013: $32,537.50 / $2,381.62; Tax Year 2014: $33,188.26 / $2,429.25.

UCLA PD issued CCW Permit No. 2, signed by Chief James D. Herren. The card states: "RETIRED. Retired in good standing from service as a Peace Officer of the state of California." Badge #341, Rank: Officer, Date Retired: 03/01/96, Service Years: 8. Issued pursuant to California Penal Code §§ 25455, 25460–25465. Expiration: August 29, 2018.

Thomas Herz, a UC Office of the President employee, corresponded with me regarding my disability status across a period of eight months. His departmental title changed three times during this single correspondence thread — "Retiree Insurance" (September 2009), "Health Welfare Administration" (January 2010), and "Retiree Administration Service Center" (March 2010) — all from the identical UCOP telephone number 510-987-0229. This is the same UCOP telephone exchange later used by Erin Morse (510-987-0762) who issued the April 9, 2026 RASC 90-Day Review letter. On March 29, 2010, Herz confirmed my classification in writing: "The requirement does apply to you as it does to all other retirees on disability." I asked Herz twice, in writing, to verify my workers' compensation settlement before taking any action. Herz stated he was "not aware of any settlements" and did not consult UC legal as I requested. On April 6, 2010, Herz threatened that failure to provide an SSA determination "can result in an offset fee being imposed on your check and termination of UC medical coverage." On April 9, 2010, the Social Security Administration confirmed I was ineligible for SSDI because my income exceeded the Substantial Gainful Activity threshold. Herz's attempt to reclassify my status or terminate my medical coverage failed.

His conduct pattern — confirming disability classification, dismissing a written settlement as unknown, steering toward a federal program without verifying the settlement, and threatening coverage termination to create urgency — is documented in five statements that directly parallel the conduct the Department of Justice has alleged in United States ex rel. Shea v. eHealth, Inc., et al., No. 1:21-cv-11777-DJC (D. Mass.).

This was the first of three documented UCOP attempts — across three different employees, three different titles, and sixteen years — to terminate my medical coverage using the same mechanism.

I began receiving letters from a third-party workers' compensation adjusting company representing UC (believed to be Gates or Gallagher). A representative demanded I appear for a medical re-examination to determine whether I still qualified for disability income or UC would stop my monthly disability payments. I explained that my status was governed by a settlement agreement. The representative stated she "knew nothing about a lawsuit or worker's comp settlement agreement." No re-examination occurred. Shortly thereafter, UC's "At Your Service" program called me and informed me I was required to convert from DDI to service retirement status or I would "lose everything." The representative informed me I had 21 years of service credit — combining active-duty time (1989–1996) with disability-time accrual under UCRP § 8.18(e). I made the conversion under this coercive representation. I received no written notice, no pre-deprivation hearing, and no opportunity to respond — as required under POBR and Skelly v. State Personnel Board. No WCAB modification order has ever issued authorizing this conversion.

In Jacobs et al. v. The Regents of the University of California (2017) B268758, UC's own lead disability benefits analyst stated under oath that a person may convert to Retirement "only by making an affirmative election to do so." UC's RASC letter of March 2, 2015 told me the opposite — that Retirement Income was the lifetime benefit and Disability Income was not — to induce a conversion that cost me $727.48 per month in premiums and converted my tax-free income to fully taxable income.

UC issued three conflicting IRS Forms 1099-R for the same tax year, all filed under penalty of perjury: Form A (Code 3, Disability, $15,557.34, $0 taxable — January through approximately May 2015); Form B (Code 2, Early Retirement, $14,614.44, 100% taxable — approximately June through December 2015); Form C (Code 2, $30,171.78, 100% taxable — entire year reclassified). No WCAB order authorized any of these classifications. No notice was provided to me. UC simultaneously began deducting $727.48 per month in health insurance premiums from my retirement payments — premiums that were employer-paid under the terms of the 2003 workers' compensation settlement.

UC issued annual IRS Forms 1099-R under Code 2 (2016–2019) then Code 7 (2020–2025) — 100% taxable — each filed by UC under penalty of perjury. Each filing represents UC's own sworn federal confirmation of a reclassification that was never authorized by the WCAB.

CCW Permit No. 2 expired. UCLA PD sent no renewal notice and no range qualification communications of any kind.

After eighteen months of silence following the expiration of my CCW, I initiated contact myself with UCLA PD. Administrative staff identified that my email address had been dropped from the retiree distribution list and corrected it. Sgt. James Echols confirmed my address and resumed communications, sending range qualification notices confirming my continued status on the retiree list.

Sgt. Echols canceled all range training due to COVID-19 and promised in writing to notify me promptly when training resumed. No such notification was ever sent. My correct, confirmed, operational email address remained in the system. UCLA PD's range training for retirees must have resumed at some point thereafter — it is a functioning law enforcement agency — but I received no notification.

On February 24, 2021, Ida Fong, a UC Benefits employee at the University of California Office of the President, acting within the scope of her employment for The Regents of the University of California, called me.

This call was initiated by UC, not by me.

I had made no prior request, filed no prior complaint, and sent no prior inquiry that prompted this call. Ms. Fong called because UC's own UCRAYS portal had flagged an internal records anomaly: UC's own system had incorrectly identified my son as the disabled person in my account, and had been charging health insurance premiums accordingly. On the recorded line Fong stated my son's full name and date of birth from UC's records; both are omitted here to protect family PII. I informed Fong that my son has never been disabled and has no disability rating of any kind. I further informed her that I — Chuck Harold — hold a documented permanent disability rating of 6¾% established by UC's own contracted claims administrator, Octagon Risk Services, on August 8, 2001, under Workers' Compensation Claim No. 199650445, with a monthly DDI entitlement of $3,075.98 tax-free, reflected in UC's own IRS 1099-R filings under Distribution Code 3 (Disability) for tax years 2010 through mid-2015. Fong's February 24, 2021 call constitutes documented institutional self-discovery: through investigation of the disability coding anomaly for my son in its own UCRAYS portal, UC's own employee confirmed — on a UC-initiated call, acting in her official capacity — that UC's own disability classification records for Chuck Harold, Badge #341, were corrupted, lost, or missing from active systems; that UC had been misidentifying a non-disabled family member as the disabled person in my account; that my son had already passed the ACA age-26 coverage cutoff eleven months and fifteen days before Fong's call — meaning UC had been charging premiums for an ineligible dependent by coding him as disabled without factual basis; and that my own documented, permanent, never-revoked disability rating had been stripped from the system without authorization.

I sent a four-page letter by email to Ida Fong at her confirmed UCOP institutional email address, Ida.Fong@ucop.edu, with BCC to my wife. The email subject was "My UC Health Insurance Payments." The letter contained my complete chronological account of the case, including the 1989 UCLA PD employment, the 1994 whistleblowing activities that led to the termination of the Chief of Police and command staff, the January 1996 on-duty injury, the 1996–2001 period during which UC refused to pay DDI, the August 8, 2001 Octagon permanent disability determination, the March 2003 workers' compensation settlement, and the 2015 coerced conversion. I stated explicitly in writing to Fong: "I wonder if part of the problem with my case is that the new computer program did not properly migrate my data from the old system and marked [my son] as disabled instead of me." The email contained three attachments transmitted directly to Fong's UCOP inbox: Attachment 1 — UCLA Retirement Administration Service Center Letter dated March 2, 2015, in which UCOP's own Retirement Administration Service Center represented that UC would continue paying my medical insurance upon conversion to retirement income; Attachment 2 — UCLA Retirement Estimator dated April 2, 2015, showing an estimated monthly payment of $2,341.04 with no disclosure that health insurance premiums would be deducted; Attachment 3 — UCLA Octagon Risk Services letter dated August 8, 2001, establishing my 6¾% permanent disability rating and $3,075.98/month DDI entitlement under Workers' Compensation Claim No. 199650445. By this transmission, I placed the University of California Office of the President on documented actual notice — with the supporting evidence physically delivered to a UCOP employee's confirmed institutional inbox — of the Octagon permanent disability determination. No written response from Ida Fong or from any other University of California employee to the March 12, 2021 email has ever been received. No correction to my disability status was made.

Fong called me again. She confirmed that UC would issue a refund check for overpayment of health insurance premiums incorrectly charged in connection with my son's erroneous disability coding. UC issued that refund. I asked Fong to simultaneously correct my own record — to re-list me as disabled, which would reinstate UC's employer obligation to pay my health insurance premiums under both the DDI benefit structure and the terms of the 2003 workers' compensation settlement. Fong confirmed that when UC upgraded its computer systems several years prior, old records had been lost and not recovered, and that she was unable to locate any information about my original workers' compensation case and disability status — notwithstanding that I had sent her the Octagon letter, the RASC conversion letter, and the Retirement Estimator six days earlier, on March 12, 2021. Fong stated she was unable to correct my record. She did not refer the matter to any supervisor, any audit officer, any compliance official, or any records recovery process.

On March 18, 2021, the University of California Office of the President's own retirement administration process worked as follows: UC identified an erroneous disability coding for a non-disabled person (my son, then age 27) → corrected the record → issued a refund. Simultaneously, UC was in possession of the Octagon permanent disability determination physically delivered to Fong's inbox six days earlier → took no corrective action → issued no refund → made no referral. UC had the mechanism and used it for my son on that date. UC chose not to apply the same mechanism to me.

I logged into the UC UCRAYS portal and captured a screenshot of the "Manage Contacts" page under my account (CHARLES HAROLD). The screenshot, preserved in my evidence archive, shows four contacts with their enrollment statuses: MEGAN HAROLD — Child/Grandchild — Beneficiary ✓ — Health Enrollee ✗; MAXIMILLIAN HAROLD — Child/Grandchild — Beneficiary ✓ — Health Enrollee ✓; SILVIA HAROLD — Spouse — Beneficiary ✓ — Health Enrollee ✗; SILVIA HAROLD — Spouse (duplicate entry) — Beneficiary ✗ — Health Enrollee ✓.

My son was, on August 7, 2022, 28 years, 4 months, and 29 days old — two years and four months past the ACA age-26 cutoff, and seventeen months after Fong confirmed on March 18, 2021 that the erroneous enrollment would be corrected. The portal was never corrected.

The portal also shows two separate duplicate entries for my spouse my wife — with beneficiary and health enrollment attributes split across two rows — consistent with Fong's statement that UC's computer system upgrades caused records to be lost and not recovered.

The same UCRAYS portal that maintained an erroneous disability classification for a non-disabled 28-year-old simultaneously showed me — a documented permanently disabled peace officer with an unrevoked Octagon determination since August 8, 2001 — as a service retiree with no disability coding whatsoever.

My attorney Edgar A. Saenz, Esq. transmitted a formal four-page audit request on November 9, 2021 by both certified mail and by email to Alexander Bustamante at his confirmed UCOP institutional address, Alexander.bustamante@ucop.edu (transmitted Tuesday, November 9, 2021 at 3:10 PM, subject line "C. A. HAROLD; LTR RE PERSONNEL STATUS REVIEW," with the four-page letter "Ltr to Bustamante UC 2021.11.09.pdf," 423 KB, attached), with CC to Joanna Weber, Law Office of Edgar Saenz, and BCC to me. The letter identified me as "a former UCLA peace officer and whistleblower." It made four specific requests: (1) an audit of my workers' compensation and disability income case; (2) an audit to determine what personally identifiable information belonging to me was breached during UC data breaches; (3) an audit of my internal UC records to determine what records were lost during UC computer system upgrades; and (4) reversal of UC's 2015 action when it "erroneously and improperly changed Mr. Harold's disability income status to a service retirement and stopped paying for his medical insurance." The letter documented that my monthly income dropped from approximately $3,000 per month tax-free to $1,300 per month taxable as a direct result of the 2015 conversion — a reduction of approximately $1,700 per month. On the same date, I accessed the LinkedIn profiles of Bustamante, Matthew Hicks (Systemwide Deputy Audit Officer, UCOP, 510-987-9646), and Erin Pressman (Principal Investigator, UCOP Office of Ethics, Compliance & Audit Services) and sent LinkedIn connection requests to each — a third independent contact channel. Contact was therefore made through three independent channels on November 9, 2021: certified mail, institutional email, and LinkedIn.

No acknowledgment, response, investigation, or referral was ever received through any channel from Bustamante, Hicks, Pressman, or from anyone at the University of California.

Alexander Bustamante served as LAPD Inspector General from November 2011 through August 2017 — with direct responsibility for independent oversight of LAPD operations, peace officer discipline, workers' compensation claims integrity, and retaliation complaints filed by and against sworn law enforcement personnel under POBR — and as an Assistant United States Attorney prosecuting civil rights violations under 42 U.S.C. § 1983 from January 2002 through November 2011. He has served as UC's Senior Vice President and Chief Compliance and Audit Officer since September 2017. The subjects of his prior employment — POBR, workers' compensation retaliation, civil rights claims against government actors — are the precise subjects of my case. His non-response constitutes: (1) a violation of UC Whistleblower Policy 1100171; (2) a violation of UC Regents Policy 7503; (3) a statutory failure under Government Code § 8547.10(b), which mandates that designated officials "shall" investigate upon receipt of a complaint; (4) actual institutional notice imputed to every UC employee who acted adversely against me after November 9, 2021; and (5) institutional liability under California Government Code § 815.2 for the acts and omissions of its officers acting within the scope of their employment.

I logged into the UCOP "At Your Service Online" portal (atyourserviceonline.ucop.edu). UC's own automated system sent two confirmation emails to info@bruinwatch.org from do.not.reply5@ucop.edu: at 9:57 AM, Temporary Password Request (Confirmation Number 0008720384PWDF); at 10:02 AM, Password Change Confirmation (Confirmation Number 0008720385PWDC). At 10:31 AM — twenty-nine minutes after the confirmed login — I emailed myself the complete evidentiary package (Gmail thread ID 184bf4abd88e3ea3) containing eight attachments: the UCRAYS migration statement screenshot, the August 7, 2022 UCRAYS enrollment status screenshot, the March 12, 2021 email to Fong, the UC Retirement Center Letter, the Current Enrollment document, the Octagon letter, the RASC conversion letter, and the Retirement Estimator. UC's own server-generated confirmation emails establish that I was actively monitoring the UCRAYS portal more than twenty months after Fong's February 24, 2021 call and over a year after the Bustamante letter, and that I preserved the complete documentary record under a confirmed Gmail timestamp. UC had still taken no corrective action of any kind.

I corresponded with Captain Jeff Chobanian (Badge #307) of UCLA PD regarding CCW renewal. I identified myself as "THAT Chuck Harold," provided my service history and POST certification, and cited the 1994 Los Angeles Times articles. On August 21, 2023, Chobanian addressed me as an "active retiree." On August 25, 2023, the same Captain Chobanian wrote: "After a comprehensive review of your file, I have determined you are ineligible for a CCW. Your status was designated as medically separated on March 1, 1996." This directly contradicted his August 21 characterization of me as an "active retiree" and contradicted 21 years of CCW issuance, renewal, and range qualification by UCLA PD treating me as a retiree. Chobanian attached to his denial letter the case of Jacobs v. Regents of the University of California — in which FUPOA, the union I founded, was the named plaintiff. The union I created was used to deny my own rights.

PATTERN ATTEMPT #3 — DECEMBER 2025 — FEBRUARY 2026 — HEALTH COVERAGE TERMINATION CAMPAIGN

Background: How the Premium Deduction Worked

Since the 2015 conversion from Duty Disability Income to service retirement, UC has been deducting $727.48 per month from my UC Retirement Annuity pension to pay the monthly premium for my UC High Option Supplement to Medicare PPO, covering both myself and my wife. I never had the ability to pay Anthem directly. The only mechanism available to me for premium payment was the pension deduction executed by UC. I did not control it. I did not see it as a line item in any document sent to me. I knew of it only because my pension was reduced by that amount each month.

December 26, 2025 — UBEN Form Signed; Via Benefits Transfer Pipeline Activated Internally by UC

On December 26, 2025, a UC RASC employee identified to me only as "Robin" called me. Robin informed me that I "live in Arizona," that UC "did not know that," and that this newly-discovered residency required me to enroll in Via Benefits — operated by Willis Towers Watson — in lieu of my existing UC-direct Anthem Blue Cross coverage.

Robin's representation that UC "did not know" I lived in Arizona was false at the time it was made:

UC's own UCRAYS automated ACH system had been wiring monthly federal retirement payments to my Arizona-registered Unify Federal Credit Union account since July 31, 2018 — seven years and five months before Robin's call — and UC had been filing IRS Forms 1099-R and 1095-B bearing my Arizona mailing address under penalty of perjury every January from 2019 forward.

I signed the UBEN 100 form she sent — revision R10/21, the superseded form — under her representation that this transfer was mandatory. I have since established through the current UBEN 100 footnotes that Via Benefits enrollment for out-of-state retirees is elective, not mandatory. The signing of that form on December 26, 2025 appears to have triggered UC's internal processing of the premium deduction removal.

The UBEN 100 form I received and signed was the then-current form bearing revision code R10/21 (revised October 2021). A new version of the UBEN 100 — revision code R1/26 — was published by UC in January 2026. UC RASC did not inform me of the updated form.

The Via Benefits transfer Robin attempted to initiate on December 26, 2025 was the third in a documented series of UCOP attempts — following Thomas Herz in 2009–2010 and the unnamed "At Your Service" representative in approximately 2014–2015 — to remove me from UC-direct medical coverage, each using a different mechanism and a different UCOP employee title.

The Department of Justice has identified Willis Towers Watson — Via Benefits' parent company — as one half of a "two horse race" that controls at least 95% of the private multicarrier retiree exchange market in the United States. United States v. Aon plc, Case No. 1:21-cv-01633 (D.D.C. 2021) (DOJ Complaint ¶ 47).

UC's own systems automatically enrolled me in UC High Option Supplement to Medicare — a federally designated Medigap (Medicare Supplement) plan — confirmed simultaneously by UCRAYS (Medicare Coordination: Yes, $727.48/month, 100% UC contribution), the Anthem Blue Cross portal (active coverage January 1, 2026), and Medicare.gov (Blue Cross of California listed as "Other Insurance" — the federal CMS designation for a Medigap policy). UC High Option Supplement to Medicare is available only to qualifying UC retirees and safety members. UC's own automatic enrollment constitutes an institutional acknowledgment of my qualifying status.

January 2026 — UC Internally Removes the $727.48 Deduction Without Notifying Me

During the month of January 2026, UC internally processed the removal of the $727.48 High Option premium deduction from my pension calculation. I did not know this had occurred. I received no notice of any kind. No letter. No UCRAYS message. No phone call.

I submitted a formal letter to UC Benefits / RASC Team titled "Re: Immediate Hold Request on Retiree Medical Coverage Changes." The letter demanded an "immediate hold on any internal actions, quotes, or procedures" that would "modify, re-rate, terminate, or otherwise change my current Blue Cross Medicare coverage." The letter stated the matter was "medically urgent" and that I was "scheduled for cancer surgery in February" and that any change could jeopardize my scheduled surgery date, continuity and quality of care, and my health and life expectancy. I requested written confirmation that no changes would be made. Attachments: UCRAYS screenshot reflecting pending insurance activity 1-29-2026; MEDICARE screenshot reflecting current coverage 1-29-2026. No written confirmation was received.

My pension deposits arrive on the first of each month to my Unify Financial Credit Union account. On February 1, 2026, my deposit was $2,902.26. My January 2026 deposit had been $2,174.78. The difference was exactly $727.48 — to the penny — the monthly premium for my UC High Option coverage.

My Unify Financial Credit Union bank records document this increase precisely. That $727.48 increase was not income. It was the absence of a deduction that UC had stopped taking without telling me.

I discovered the deduction had been removed only because I noticed the amount was higher than usual. No UC document told me why. UC created the non-payment default it subsequently used to justify the cancellation of my coverage.

Joshua Lewis, Via Benefits / Willis Towers Watson program administrator, called me at 12:11 PM Arizona time (7 minutes, 6 seconds, from incoming number +1 866-322-2824) and confirmed I am ineligible for Via Benefits because of my disability rating. He stated he would notify UC in writing that my application would not be accepted. Upon learning of my then-scheduled February 25, 2026 cancer surgery, Lewis stated:

"We need to fix this before then."

UC's own contracted Via Benefits program administrator confirmed, in real time, that the transfer pathway UC was attempting to use was legally unavailable to me based on my disability classification.

On February 9, 2026, I served Captain Chobanian a written litigation hold and POBR records demand (EX 20) requiring production of eight categories of records by February 18, 2026. On February 10, 2026, Chobanian responded: "Based on your last email, I will no longer communicate with you since you have threatened legal action against me." He refused all further communication. The February 18, 2026 compliance deadline lapsed with no records produced. A notification of potential legal liability under 42 U.S.C. § 1983 is a legal notification of existing law, not a threat. Captain Chobanian used that notification as the stated basis for terminating all communication with me and failing to produce the records I had formally demanded.

Williams-Cook called me at 3:07 PM on February 11, 2026. During that call, she did not disclose that UC had already removed the premium deduction from my pension. She did not tell me that Anthem was not receiving my premium. She did not tell me my coverage was at risk of cancellation for non-payment.

I filed a Crime Report under California Labor Code § 132a against Captain Jeff Chobanian for discrimination against a workers' compensation claimant. Labor Code § 132a designates violations as a criminal misdemeanor. The WCAB has exclusive jurisdiction. My workers' compensation case (Claim #199650445) has never been formally closed.

I filed POST complaints (PUBLIC-26-000212, PUBLIC-26-000213, and PUBLIC-26-000214) against Captain Jeff Chobanian, Chief Craig Valenzuela, and Lt. Richard Davis, respectively. On the same date, Lt. James Echols issued three irreconcilable custody-of-file statements in forty-one minutes: file "located" at 1:24 PM; file "located" again at 2:23 PM; file "archived and being searched for" at 3:04 PM. Captain Chobanian was copied on each. Captain Chobanian had confirmed reviewing the same file in writing on August 25, 2023 and February 10, 2026. These four statements — across two officers, on the same file — cannot all be true on the same set of facts.

I underwent radical prostatectomy surgery for Gleason 4+3=7 prostate cancer with one positive surgical margin (Gleason 4+4=8), extraprostatic extension, and two PSA doubling-time periods in less than two years. Williams-Cook's denial was issued two days after this surgery.

Two days after my surgery, UC RASC Benefits Analyst III Beverly Jeanine Williams-Cook dated a written Administrative Review Determination denying my re-enrollment in UC High Option Supplement to Medicare. Williams-Cook processed my dispute using the superseded UBEN 100 form bearing revision code R10/21 — the same form "Robin" had provided to me on December 26, 2025. The current UBEN 100 form, bearing revision code R1/26, had been published by UC in January 2026 — the same month Williams-Cook was assigned my case. Williams-Cook held my dispute for 28 days and never informed me that a new version of the controlling enrollment form had been published during the period of her review. The R1/26 form contains materially different enrollment criteria relevant to my case. By processing my dispute on the superseded R10/21 form, Williams-Cook ensured a procedurally defective record regardless of the merits.

The determination states my coverage "will be suspended on April 30, 2026, due to non-compliance with UC retiree health policy." The determination records four factual findings: (1) I elected regular retirement in June 2015; (2) I am not receiving UCRP Disability Income; (3) I have Medicare eligibility status; and (4) I currently reside outside of California. The determination directs me exclusively to Via Benefits as the only alternative — without disclosing my Medigap guaranteed issue rights under 42 U.S.C. § 1395ss(q)(2) and (3). Additionally, the denial letter: contained an incomplete phone number (800-888-826, missing the final digit); did not request a single document from me; did not address any of my six prior RASC filings; and was mailed late and received by me on approximately March 28–29, 2026 — 30 days after the date printed on the letter. I retained the envelope.

On February 27, 2026 — two days after my cancer surgery — the University of California issued a written determination that I was ineligible for UC High Option Supplement to Medicare coverage because I resided in Arizona, was not receiving UCRP Disability Income, and had no option other than Via Benefits, and that my coverage would terminate April 30, 2026; then, after I filed the correct current UBEN 100 (R1/26) enrollment form checking the "Involuntary loss of coverage" checkbox, UC re-enrolled me in the identical UC High Option Supplement to Medicare coverage it had just declared him ineligible for, in the identical state it had just declared disqualifying, under the identical disability status it had just declared irrelevant, through the identical insurer it had just directed him away from, while the only alternative UC had offered him — Via Benefits — had already confirmed in writing that I was ineligible for that alternative due to the identical disability status UC had simultaneously declared he did not have — all of this occurring while I was recovering from cancer surgery, undergoing cardiac treatment, and receiving neurological care.

MARCH 25 — APRIL 28, 2026 — REGULATORY FILINGS AND COVERAGE DISPUTE TIMELINE

On March 25, 2026, I sent the first written notice to Anthem Blue Cross regarding the unlawful cancellation of my UC High Option Supplement to Medicare coverage. That letter constitutes the initial notice establishing the notice date in this matter. On March 30, 2026, I transmitted a second, superseding document titled "Controlling Legal Notice & Demand to Maintain Insurance Coverage," which expressly states: "This letter supersedes and replaces in its entirety my correspondence of March 25, 2026, and constitutes the controlling legal notice and demand regarding the above-referenced coverage. My March 25, 2026 letter remains part of the record as the initial notice establishing the notice date." The March 25, 2026 letter is therefore the first documented written notice to Anthem Blue Cross of the unlawful cancellation, predating the DMHC complaint filed March 31, 2026, the CMS filing filed March 31, 2026, and all subsequent correspondence in this matter.

On March 27, 2026 — five days before Anthem terminated my coverage on April 1, 2026 — Tamika Lyons, Health Insurance Specialist, Centers for Medicare & Medicaid Services, Office of Program Operations & Local Engagement (OPOLE), Phone: 212-616-2340, Fax: 443-380-5148, Tamika.Lyons@cms.hhs.gov, sent me an email committing in writing to research my case further. This is documented in my April 8, 2026 letter to Lyons, which opens: "Thank you for your continued attention to Case #7100158 and for your commitment to researching this matter further, as you stated in your March 27, 2026 email."

Lyons's March 27, 2026 written commitment establishes that CMS was actively engaged in Case #7100158 and had made a written commitment to investigate before Anthem terminated my coverage on April 1, 2026. The termination therefore occurred while CMS was in active correspondence with me and had already committed to investigating the same coverage dispute that the termination purported to resolve.

No written notification of the April 1 termination was sent to Lyons by UC or Anthem before or after the termination occurred. I notified Lyons of the termination myself in my April 8, 2026 letter.

I transmitted a 20-page "Controlling Legal Notice & Demand to Maintain Insurance Coverage" dated March 30, 2026 via USPS Express Mail, Facsimile, and Physical Delivery. The letter is addressed to: Anthem Blue Cross Grievances and Appeals Department, P.O. Box 4310, Woodland Hills, CA 91365-4310; AND Anthem Blue Cross Compliance Coordinator, P.O. Box 27401, Richmond, VA 23279. Simultaneous copies transmitted to: California Department of Managed Health Care (DMHC), fax (916) 255-5241; California Department of Insurance (CDI), (800) 927-4357; UC Office of General Counsel, 1111 Franklin Street, 8th Floor, Oakland, CA 94607; CMS Case #7100158, Tamika.Lyons@cms.hhs.gov.

The letter states it supersedes and replaces my correspondence of March 25, 2026, which remains part of the record as the initial notice establishing the notice date. The letter demands acknowledgment in writing by no later than April 4, 2026, with a clear statement of how Anthem will ensure my UC High Option coverage is maintained and that any UC- or Via Benefits-initiated cancellation effective April 30, 2026 is blocked.

On March 31, 2026 at 5:56 PM Pacific, I submitted a formal HIPAA records request to Anthem Blue Cross pursuant to 45 C.F.R. § 164.524 — the HIPAA Right of Access rule. The request covered both of my Member IDs — VUC***87210 (pre-Medicare, UC CARE PPO) and U5X***87210 (post-Medicare, UC High Option Supplement to Medicare) — across my entire coverage history. The request covered ten categories of records including all claims, all Explanation of Benefits statements, all pre-authorization records, all coordination of benefits records, all enrollment and termination records including any instructions received from UC or Via Benefits, all premium payment records, all dependent records, all medical records, and — critically — a complete audit trail of any changes to my enrollment status, plan type, benefit classification, or coverage level, including the date, time, user, and source of each change. Under 45 C.F.R. § 164.524(b)(2), Anthem is required to act on this request no later than 30 days after receipt.

The 30-day statutory deadline is April 30, 2026.

Under 42 U.S.C. § 1395w-22(h), Medicare-contracted organizations must provide enrollees access to records. Under California Insurance Code § 10123.35, insurers must provide complete medical records upon request. These are Anthem's independent obligations and do not depend on UC's instructions. HHS Office for Civil Rights has pursued more than 50 enforcement actions under its HIPAA Right of Access Initiative since 2019. As of the date of this sworn statement, no HIPAA-compliant response has been received from Anthem Blue Cross.

On March 31, 2026, at 5:25 PM Pacific, I filed a formal complaint with the California Department of Managed Health Care (DMHC) against Blue Cross of California, the Knox-Keene licensee operating under the Anthem Blue Cross trade name. DMHC issued Case #1409109. The complaint, as filed, stated the cancellation date as "effective May 1, 2026" — the date I stated based on information available to me at the time of filing.

The DMHC complaint's stated cancellation date of May 1, 2026 is a fourth distinct termination date now documented in the record of this matter, separate from and inconsistent with: Williams-Cook's February 27, 2026 determination stating April 30, 2026; Anthem's actual portal termination occurring April 1, 2026; and Lorena Rivera's April 17, 2026 closure letter also stating May 1, 2026. As of the date of this sworn statement, four separate written instruments in the record assert four different termination dates. Not one of these four dates is consistent with any of the others.

At 6:35 PM, I sent a formal email to Anthem Blue Cross Compliance Coordinator at compliance.coordinator@anthem.com, subject line: "URGENT — CMS Case #7100158 — DMHC Complaint Filed 3/31/26 — Premium Non-Payment by UC — Offer to Pay Directly — Member ID U5X***87210." The email stated in full:

"Tonight I discovered that the University of California has stopped deducting my monthly High Option premium of $727.48 from my UC Retirement Annuity pension. My Unify Financial Credit Union bank records show the following: January 2026 pension deposit: $2,174.78. February 2026 pension deposit: $2,902.26 (increase of exactly $727.48). March 2026 pension deposit: $2,902.26. The $727.48 increase matches — to the penny — the monthly premium for my UC High Option Supplement to Medicare PPO covering both myself and my wife. UC stopped collecting this premium without my knowledge, without my consent, and without any written notification. I did not request this change. I did not authorize this change. I was not informed of this change. If Anthem Blue Cross intends to use non-payment of premium as a basis for cancellation, I am hereby placing you on notice that any such non-payment was manufactured by the University of California, not by me."

In the same March 31 email, I formally offered to pay $727.48 per month directly to Anthem Blue Cross, including all back premiums for February and March 2026 totaling $1,454.96, to ensure continuous coverage. I requested Anthem's payee name, mailing address, and written confirmation of acceptance — or, if Anthem refused direct payment, a written refusal stating the legal basis. No written response accepting or refusing that offer was ever received from Anthem Blue Cross.

My UC High Option Supplement to Medicare coverage is terminated on April 1, 2026 — 29 days before the April 30, 2026 date stated in the Williams-Cook determination as the coverage suspension date. I discover the termination himself upon logging into the Anthem Blue Cross member portal on April 1, 2026. The portal displays a red INACTIVE status badge on my plan. No grace period notice was sent to me prior to termination. No delinquency notice was sent. No advance written notice of any kind was sent.

In the 24-month period ending April 2, 2026, Anthem Blue Cross sent me zero notices of any kind — no premium delinquency notice, no grace period notice, no cancellation warning.

California Insurance Code § 10273.6 and standard Medigap policy provisions require written notice before coverage is cancelled for non-payment of premium, with a grace period to cure.

Who Entered April 1 into Anthem's Enrollment System

The Anthem Blue Cross member portal plan period selector shows my 2026 coverage ending on April 1, 2026. That date did not appear in the Anthem system by accident and it did not appear because I requested it. A plan period end date of April 1, 2026 in Anthem's enrollment system means that someone — a human being with administrative access — entered April 1, 2026 as the coverage termination date into Anthem's group enrollment system. That entry did not occur on its own.

Anthem Blue Cross has represented in correspondence that UC, as the group policyholder, is the contracting party responsible for enrollment and termination decisions under the group plan. UC's own Group Insurance Regulations state that "By authority of the Regents, University of California Human Resources, located in Oakland, administers all benefit plans." Under that structure, the termination entry in Anthem's system on or before April 1, 2026 was directed by UC — not by Anthem acting unilaterally, and not by me.

The factual conflict this creates is documented entirely in UC's and Anthem's own records: Williams-Cook's written determination, dated February 27, 2026, states coverage will be suspended April 30, 2026. Someone then entered April 1, 2026 — not April 30 — into Anthem's enrollment system, causing the plan period to close 29 days before Williams-Cook's own stated date. Allison Cumming at Elevance Health, on April 1, 2026, acknowledged in writing "your policy terminating on April 30th, 2026" — meaning that as of 3:14 PM on April 1, Anthem's own Executive Concierge still had April 30 in her records, while Anthem's own enrollment system had already closed the plan period at April 1.

Three documented facts therefore stand simultaneously: First — Williams-Cook stated April 30 in writing on February 27, 2026. Second — Someone entered April 1 into Anthem's enrollment system, closing the plan period 29 days early, before Cumming sent her email at 3:14 PM on April 1. Third — Cumming's email at 3:14 PM on April 1 still referenced April 30 — meaning the right hand of Anthem/Elevance did not know what the left hand had already done in the enrollment system that same morning.

The identity of the person who entered April 1, 2026 as the plan period end date in Anthem's enrollment system has not been disclosed to me in writing by UC or Anthem as of the date of this sworn statement. That question — who made that entry, on whose authority, and on what date — has been directed to DMHC Case #1409109, CMS Case #7100158, and to Allison Cumming at Elevance Health. No written answer has been received.

April 1, 2026 — Allison Cumming / Elevance Health Contacts Me at 3:14 PM

On April 1, 2026 — the same day I logged into the Anthem portal and discovered my plan showing as INACTIVE — I received the following email:

FROM: allison.cumming@elevancehealth.com TO: info@bruinwatch.org DATE: Wednesday, April 1, 2026 at 3:14 PM SUBJECT: FAX ESCALATION / CSHD (CA) / ack follow up

"Good morning, Mr. Harold. I tried to reach you by phone at 818-652-6400 a short time ago. Our Executive Concierge team has received your fax regarding your policy terminating on April 30th, 2026. We have assigned an analyst from our team who will investigate this on your behalf. We will provide you with an update as soon as new information becomes available. Thank you, Allison. Allison Cumming, Resolution Lead, Consumer Experience Office, Elevance Health Executive Concierge, 615-306-9712."

Allison Cumming is a Resolution Lead in the Consumer Experience Office of Elevance Health — the corporate parent of Anthem Blue Cross. She contacted me proactively on April 1, 2026 after Anthem Blue Cross received my fax asking to stop all termination of my coverage. She wrote this email on the same day and at the same time Anthem's own portal was displaying my plan as INACTIVE. She did not dispute the April 30 date. She did not correct it. She did not state that my coverage had already been terminated on April 1. She assigned an analyst to investigate.

April 1, 2026 at 10:10 AM — Lt. James Echols / UCLA PD Contacts Me

Lt. James Echols, jechols@ucpd.ucla.edu, emailed me at 10:10 AM, CC: "Chobanian, Jeff" <Chobanian@ucpd.ucla.edu>, stating: "Hello Chuck, I did receive a box that should have had your files in it, but it was not the correct box. I am now in the process of tracking down the correct box. It has been quite some time since you worked here so locating your files, if they still exist, is a bit challenging. I appreciate your patience as I try to assist you with your request." — signed Lieutenant James Echols, UCLA Police Department, 601 Westwood Plaza, Los Angeles, CA 90095, Office: (310) 794-7218, Cell: (213) 604-1851, jechols@ucpd.ucla.edu, 310-825-1491 (24 hr).

On April 1, 2026, I forwarded all DMHC Case #1409109 and CMS Case #7100158 regulatory filings directly to Allison Cumming, Executive Concierge at Elevance Health — Anthem Blue Cross's parent company — at allison.cumming@elevancehealth.com, with copies to Kelly Tursany and Petina Jones. I subsequently transmitted the 4th Supplemental DMHC filing directly to Cumming on April 7, 2026, at 7:47 PM (email: "Good evening Allison, Attached is my 4th Supplemental report filed tonight with DMHC. After my insurance was canceled on April 1, it appears to have been reinstated, without notification, sometime after I submitted my UCBEN form April 3, 2026."), and the 5th Supplemental DMHC filing directly to Cumming on April 8, 2026 at 9:07 PM (email: "Hello Allison, Attached is my 5th Supplemental report filed tonight with DMHC. This report contains an exhibit index that may help you navigate the facts.").

Anthem Blue Cross, in receipt of all five DMHC supplemental filings and the CMS complaint, took no corrective action to restore my coverage, produce my missing medical records, or resolve the guaranteed issue obligation.

I capture screenshots of the Anthem member portal the day following the termination. The screenshots, preserved as Exhibit EX_32 in the evidentiary record, show: (1) my plan displaying a red INACTIVE status badge; (2) three plan periods accessible — 2024, 2025, and 2026 through April 1; and (3) $14,094.36 in documented paid claims visible in the portal. Anthem Blue Cross generates the Certificate of Creditable Coverage dated April 2, 2026, documenting:

Date of This Notice: April 1, 2026. Issued by: Anthem Blue Cross, PO Box 60007, Los Angeles, CA 90060. Subscriber Name: CHARLES HAROLD. Group Health Plan Name: UC HIGH OPTION SUPPLEMENT. Member ID: U5X***87210. CHARLES HAROLD: Date Benefits Began January 1, 2026, Date Benefits End April 1, 2026. SILVIA HAROLD: Date Benefits Began January 1, 2026, Date Benefits End April 1, 2026.

Under 42 U.S.C. § 1395ss(q)(2) and (3) and corresponding CMS regulations, this Certificate constitutes the federal trigger document for my guaranteed issue rights — the 63-day window during which Anthem Blue Cross, as the issuer, is federally obligated to offer me an individual Medicare Supplement (Medigap) policy without medical underwriting, without pre-existing condition exclusions, and without denial. Calculated from April 1, 2026, the 63-day guaranteed issue window runs through approximately June 3, 2026.

On April 3, 2026 — two days after the premature April 1 termination and in compliance with the federally required procedure for involuntary loss of Medicare Supplement coverage under 42 U.S.C. § 1395ss(q)(2) and (3) — I filed the current UBEN 100 (R1/26) — the January 2026 revision that Williams-Cook did not disclose — directly with UC RASC. On the form, under Section 2 — Action Requested, I checked the enrollment checkbox and checked the specific sub-checkbox that reads: "Involuntary loss of coverage — attach proof (loss of coverage date: 04-01-2026)." I attached the Anthem Blue Cross Certificate of Creditable Coverage dated April 2, 2026 as the required proof document — the same document that constitutes the federal trigger under 42 U.S.C. § 1395ss(q)(2) and (3). The Comments section of the filing states: "Re-enrollment follows UC's unilateral cancellation of coverage without notice or consent. See attached cover letter. CALIFORNIA DEPT. MANAGED HEALTH CARE — DMHC Case No. 1409109 — CMS CASE NO. 7100158."

I simultaneously transmitted an email to Allison Cumming stating: "Today, I re-enrolled in UC High Option Medicare Supplement. I think Medicare calls it Part G. I doubt UC will honor it. My question to your team is: What number at Blue Cross or other Elevance Health companies should I call to enroll in a Medigap Part G plan? Our attempt to do so a few days ago with Blue Cross was not successful. The representative did not know which plan we were referring to. This is a mandatory right I have under federal statutes; however, I have a small time window in which to enroll. I would appreciate any referrals you can provide."

The re-enrollment package was faxed to UC RASC (800) 792-5178, UC OGC (510) 355-9002, Secretary to Regents (510) 987-9224, Systemwide Senior Counsel (510) 987-9757), CMS, and DMHC. Enclosures: Exhibit A — Anthem Blue Cross Certificate of Creditable Coverage, dated April 2, 2026; Exhibit B — Signed UBEN 100 (R1/26), dated April 3, 2026; Exhibit C — Octagon Risk Services "Notice Regarding Start & End of Permanent Disability Benefits," dated August 8, 2001.

This filing formally invoked my 63-day guaranteed issue rights under federal law. The "Involuntary loss of coverage" checkbox, combined with the attached termination certificate, forecloses any UC argument that I chose to leave the plan or failed to re-enroll.

The Williams-Cook denial had been processed on the superseded R10/21 form; the April 3 re-enrollment on the correct R1/26 form constitutes a correction of a procedurally defective prior determination, made on the controlling form, within the federally protected window, with the correct supporting documentation attached. Via Benefits — UC's intended transfer pathway — cannot satisfy Anthem's obligation under § 1395ss(q)(2)–(3) as it offers no Medigap equivalent.

My coverage is reinstated in the Anthem Blue Cross member portal on April 7, 2026 at 3:25 PM — only after intervention by DMHC (Case #1409109) and CMS (Case #7100158). I video-recorded the entire session. The portal displays coverage for both Charles A. Harold and my wife Z. Harold with a retroactive effective date of January 1, 2026 — not from April 1, 2026, the date the termination occurred. A Proof of Insurance was generated from that session confirming the same — coverage active from January 1, 2026, no end date displayed.

I received no advance written notice that reinstatement was occurring. I received no written confirmation from UC RASC, Anthem Blue Cross, DMHC, or CMS that reinstatement had occurred or was being processed. I discovered it by logging in.

The reinstatement creates the following documented contradiction internal to the Anthem Blue Cross system: the Anthem Certificate of Creditable Coverage, dated April 2, 2026, states that coverage terminated April 1, 2026. The reinstated portal record, as of April 7, 2026, shows continuous coverage from January 1, 2026 with no termination date. Both documents are generated by Anthem Blue Cross. Both are in the evidentiary record.

They cannot simultaneously be true. Anthem has not provided a written explanation of which document reflects the operative state of my coverage, who directed the April 1 termination entry into the enrollment system, or who directed the April 7 reinstatement.

I transmitted a formal letter to Tamika Lyons, Health Insurance Specialist, Centers for Medicare & Medicaid Services, OPOLE, Phone: 212-616-2340, Fax: 443-380-5148, Tamika.Lyons@cms.hhs.gov, dated April 8, 2026. Subject: CMS Case #7100158 — Reference 03262026Q010 — Request for CMS Coordination of Benefits Database Audit. Member: Chuck Harold, Medicare ID: 9AU6-***-DD46. Dependent: my wife, Medicare ID: 2KJ0-***-YM15. The letter references Lyons's March 27, 2026 email in which she committed to researching the matter further.

The letter identifies four COB database anomalies: Anomaly 1 — A pre-65 enrollment/cancellation entry that should not exist (discovered approximately December 24, 2025, disappeared between two calls with CMS representatives); Anomaly 2 — A crossover record anomaly; Anomaly 3 — COB configuration errors causing retroactive claim denials; Anomaly 4 — Member ID retroactively changed in Anthem's portal from pre-Medicare VUC***87210 to post-Medicare U5X***87210 for 2024 and 2025 plan years, corresponding temporally with the disappearance of the December 2023 Valley Fever hospitalization (approximately $230,000 in claims).

The letter documents five developments since March 30, 2026: April 1 termination 29 days early; April 1–2 DMHC 1st through 3rd supplemental complaints; April 7 portal restored ACTIVE with retroactive January 1, 2026 effective date, zero notice; April 8 DMHC 5th supplemental filing documenting Chiari I malformation discovered during December 2023 covered hospitalization whose records are completely absent from Anthem's portal. All six DMHC filings (original plus five supplementals) were transmitted to Lyons.

I transmitted an expanded version of the CMS COB audit request letter, dated April 9, 2026, to Tamika Lyons. The letter requests verification of five specific items in the CMS COB system for Medicare IDs 9AU6-***-DD46 and 2KJ0-***-YM15: (a) whether COB records correctly show Blue Cross of California as sole secondary insurer; (b) whether a crossover record exists; (c) whether enrollment/cancellation/modification entries exist before January 3, 2026; (d) whether retroactive Member ID changes were submitted; (e) whether any retroactive changes were submitted by Anthem or UC between April 1, 2026 and April 7, 2026 specifically. The letter states: "The improper COB Coordination of Benefits in my case, could mean the difference between living a normal lifespan or my lifespan being cut short due to lack of High Option medical treatment choices."

Eight days after Anthem had already shown my plan as INACTIVE and two days after the portal had been restored to ACTIVE, I received an email from DoNot.Reply@ucop.edu at 5:08 PM, subject line "TIMELY LEGAL NOTICE TO STOP ALL MEDICAL COVERAGE TRANSFER ACTIONS (CRMCASEID1871390)," signed by Erin Morse, Benefits/Insurance Supervisor, Retirement Administration Service Center, Erin.morse@ucop.edu, 510-987-0762. The letter's operative language states:

"Pending the Plan Administrator's review of your Complaint, the University will preserve the status quo, and you and your spouse will continue to be enrolled in the UC High Option Supplement plan until a final decision has been made regarding your and your spouse's continued eligibility to remain in the UC High Option Supplement plan. The RASC will inform you of the Plan Administrator's decision within the next 90 days."

The Morse letter does not acknowledge that Anthem had already terminated my coverage on April 1, 2026. It does not acknowledge that Anthem had already generated a Certificate of Creditable Coverage documenting that termination. It does not disclose that my federal 63-day guaranteed issue window was already running.

The 90-day window stated in the Morse letter, calculated from April 9, 2026, runs through approximately July 8, 2026. The 63-day federally protected guaranteed issue window, calculated from the April 1, 2026 termination date on the Anthem Certificate of Creditable Coverage, runs through approximately June 3, 2026. The Morse 90-day review window therefore extends approximately 35 days past the expiration of my federal guaranteed issue rights.

A final determination issued by the Plan Administrator at the outer limit of the Morse review period — July 8, 2026 — would be issued after my guaranteed issue window has closed, leaving me without any underwriting-free Medigap enrollment pathway if that determination is adverse.

I have been in this position before. In 1996, Acting Chief Karl T. Ross told me that UC had up to 120 days to determine whether his workers' compensation claim was valid before paying me anything. I waited. The result was loss of my home refinance loan, bankruptcy, a drive-by shooting at his home, and the loss of my wife's third pregnancy. In 2015, UC's "At Your Service" representative told me I would "lose everything" if I did not immediately convert from Duty Disability Income to service retirement. I converted. I lost $1,700 per month in income and began paying $727.48 per month in premiums that had previously been paid by UC under the terms of my workers' compensation settlement.

The Morse letter presents the identical structure for the third time: a UC administrative window that, if relied upon, causes the expiration of a federal right before UC is required to give me an answer. A Medicare beneficiary who read the Morse letter on April 9, 2026 and relied on its plain language — "you will continue to be enrolled until a final decision has been made" — would have had no written basis from any UC source to know that the federal clock for guaranteed issue enrollment without medical underwriting was simultaneously running and would expire 35 days before UC was required to respond.

I did not wait. I went to State Farm on April 20, 2026. The State Farm policies are the documented result of that decision.

Exhibit: EX 41 — Erin Morse 90-Day Review email (April 9, 2026)

On March 30, 2026, I filed a formal records request with UCLA Information Practices under both the California Public Records Act (CPRA) and the California Information Practices Act (IPA). UCLA received the request on March 31, 2026. UCLA Information Practices assigned the matter Public Records Request number PRR #26-6921. On April 10, 2026, Rachel Pounds, Senior Public Records Analyst, Information Practices, UCLA, 10920 Wilshire Boulevard, Suite 107, Los Angeles, CA 90024-6543, (310) 794-8741, rpounds@iprecords.ucla.edu, transmitted a letter via email acknowledging receipt and requesting additional time pursuant to Cal. Gov't Code Section 7922.535. The stated basis for the extension: "The need to search for and collect the requested records from field facilities or other establishments that are separate from the office processing the request."

The Pounds letter states: "IP will respond to your request no later than the close of business on April 24, 2026 with an estimated date that responsive documents will be made available." The April 24, 2026 deadline is for an estimated date of production — not for the documents themselves. As of the date of this sworn statement, the documents responsive to PRR #26-6921 have not been produced.

I contacted Blue Cross Blue Shield of Arizona to obtain a Medigap quote for himself and his wife my wife. The call was handled by agent Sandra Lopez, who identified herself by name on the recorded line. The call was recorded by both BCBS Arizona (per Ms. Lopez's opening disclosure) and by me. The following exchange occurred verbatim on the recorded line:

Ms. Lopez: "So if you have a letter saying that you're gonna be terminated, yes, you have a guaranteed acceptance."

Mr. Harold: "Yeah."

Ms. Lopez: "However, if you don't have a letter saying that you're gonna be terminated, then you have to go through medical underwriting."

Mr. Harold: "Yeah. I have a letter..."

Despite this exchange, Ms. Lopez continued to insist I would require medical underwriting, stated "Sir, you're not in your guaranteed acceptance any longer" and "Arizona has different rules and regulations than California." She never asked to see my termination letter, never transferred me to enrollment, and never provided a quote. I asked for a supervisor; was told the supervisor was in a meeting and would call back. No callback was received.

I transmitted a five-page formal demand letter via fax to Blue Cross Blue Shield of Arizona at (602) 864-5340 AND (602) 544-5601. Addressed to: Chief Compliance Officer Anne Schrock, Appeals and Grievances Department, Mailstop A116, P.O. Box 13466, Phoenix, AZ 85002-3466. CC: Arizona Department of Insurance and Financial Institutions (DIFI), 2910 N. 44th Street, Ste. 210, Phoenix, AZ 85018, Fax: (602) 364-2505. Subject: "Constructive Denial of Guaranteed Issue Medigap Enrollment — Formal Demand."

The letter documents the April 16, 2026 recorded call with Sandra Lopez in full detail, identifies four federal and state law violations, and notes that BCBS Arizona's parent company Elevance Health, Inc. is a named defendant in Shea v. eHealth, Case No. 1:21-cv-11777-DJC (D. Mass.), where the motion to dismiss was denied March 25, 2026 — 22 days prior. The letter demands: (1) immediate enrollment processing for both Charles and my wife under guaranteed issue without medical underwriting, effective no later than May 1, 2026; (2) written acknowledgment of guaranteed issue qualification; (3) written explanation of corrective action regarding Sandra Lopez's statements; (4) preservation of the April 16, 2026 call recording. If demands are not met within five business days, complaints will be filed with DIFI, CMS Case #7100158, and DMHC Case #1409109. Enclosed: Williams-Cook Administrative Review Determination dated February 27, 2026; Anthem Blue Cross Proof of Insurance dated April 16, 2026; recording of April 16, 2026 call with Sandra Lopez (available upon request).

On April 16, 2026, I called Anthem Blue Cross and spoke with a customer service agent who identified himself as Roger. The call was recorded. Agent Roger confirmed on the recorded line that my coverage remained active as of that date. I offered to pay all outstanding back premiums directly to Anthem Blue Cross to ensure continuous coverage. Agent Roger's response was:

"We don't handle that."

No explanation of the legal or contractual basis for that refusal was provided. No alternative payment mechanism was offered. No supervisor was offered. Anthem Blue Cross, on April 16, 2026, through its own customer service agent on a recorded line, simultaneously confirmed my coverage was active and refused to accept direct premium payment from me. This is the first documented rejection of my direct payment offer at the agent level. My offer to pay all outstanding back premiums — totaling approximately $2,909.92 as of April 17, 2026 — has been renewed in writing multiple times and has never been accepted or formally refused in writing by either UC or Anthem Blue Cross as of the date of this sworn statement.

At 6:31 AM Pacific on April 17, 2026, Allison Cumming, Resolution Lead, Consumer Experience Office, Elevance Health Executive Concierge, transmitted to info@bruinwatch.org a brief email forwarding the Lorena Rivera case-closure letter as an attachment. Subject line: "FAX ESCALATION/CSHD (CA)/closure." Cumming's verbatim message text:

"Good morning, Mr. Harold. I hope you’re doing well. Thank you so much for your patience and understanding while we reviewed your concerns. I’ve attached the case closure letter for your records. Thank you, Allison."

The transmittal closed the Anthem-side case track of my coverage termination dispute. The attached Rivera letter, dated April 17, 2026, on Anthem letterhead, bearing Reference Number INQ-COMM-197295, is the institutional instrument catalogued in FACT 81 below. The Cumming transmittal email and the Rivera attachment together constitute the Anthem case-closure record of April 17, 2026.

Exhibit: EX 42 — Allison Cumming transmittal email (April 17, 2026, 6:31 AM Pacific)

On April 17, 2026, via Allison Cumming, Lorena Rivera, CX Resolution Risk Analyst, Anthem Blue Cross Executive Concierge, transmitted a case closure letter bearing Reference Number INQ-COMM-197295. Rivera's letter contains the following verbatim statement:

"Please note that we enroll and terminate members as instructed by the University of California (UC), and UC communicates eligibility and enrollment to its members."

This statement, made by Anthem Blue Cross's own Executive Concierge division in writing on April 17, 2026, constitutes Anthem Blue Cross's documented institutional admission that the termination of my coverage was directed by the University of California — not by Anthem acting independently. This admission is consistent with and corroborates the documentary evidence established by the Anthem portal plan period selector, which shows my 2026 coverage ending on April 1, 2026 — a date that required a human entry into Anthem's enrollment system.

Rivera's letter also contains a material error: it states my fax sought review "regarding the cancellation of your Medicare Supplement coverage, effective May 1, 2026." The actual termination date on the Certificate of Creditable Coverage issued by Anthem Blue Cross is April 1, 2026 — not May 1. Anthem's own CX Resolution Risk Analyst, in Anthem's own closure letter, stated a termination date that is incorrect by 30 days and is inconsistent with Anthem's own Certificate of Creditable Coverage already in the regulatory record. Rivera directed me to contact UC RASC at 1-800-888-8267.

Exhibit: EX 43 — Lorena Rivera / Anthem case-closure letter, Reference INQ-COMM-197295 (April 17, 2026)

At 1:23 PM Pacific on April 17, 2026, the UCLA Compliance Office transmitted the CMP373 closure email to info@bruinwatch.org from the institutional address compliance@compliance.ucla.edu. Subject line: "PERSONAL & CONFIDENTAL//CMP373 Your Complaints related to UCLA PD." The full body of the email, in verbatim institutional language:

"CONFIDENTIAL — Dear Mr. Harold: The UCLA Compliance Office is responsible for investigating complaints filed against UCLA PD Sworn Officers. Our office received the three complaints you filed on February 25, 2026 with the California Commission on Peace Officer Standards & Training. After reviewing your complaints and documentation we received from UCLA PD, we did not substantiate that UCLA PD Officers violated University policy when they denied your Carry & Conceal Weapons permit (CCW). We now consider this matter closed. The UCLA Compliance Office, UCLA Wilshire Center, Suite 700, Los Angeles, CA 90024."

The email is the institutional instrument that closes Compliance Case CMP373. By the Compliance Office's own admission within the email, the determination rested on "complaints you filed" and "documentation we received from UCLA PD" — the agency whose officers (Captain Jeff Chobanian, Badge #307; Chief Craig Valenzuela; Lieutenant Richard Davis, Badge #305) were the subjects of the complaint. The email contains no reference to the February 19, 2026 California Labor Code § 132(a) crime report; no reference to the documented contradictions in classification status; no reference to the four mutually irreconcilable custody-of-file statements; and no statement that I was interviewed prior to the determination. The Compliance Office adjudicated complaints filed under California Penal Code § 13510.8 by reference to UC internal policy alone.

Exhibit: EX 44 — UCLA Compliance CMP373 closure email from compliance@compliance.ucla.edu (April 17, 2026, 1:23 PM Pacific)

UCLA Compliance closed Case CMP373 finding that Captain Chobanian and Chief Valenzuela committed no policy violation in denying my CCW. The denial was premised expressly on my "medically separated" status and current receipt of Duty Disability Income under UC Gold Book GO 21-02 § 1700.1(b)(1). By upholding that denial, UCLA Compliance — the highest UC compliance authority at the campus level — rendered an institutional determination that I am a DDI recipient who has not retired or separated from the University of California. If I was a regular retiree as UC RASC simultaneously classified him since 2015, the CCW denial would have been wrongful and CMP373 would have been sustained in my favor. It was not. UCLA Compliance affirmed the DDI classification. That determination is UC's own.

Under either of UC's two simultaneous classifications of my status — DDI recipient or service retiree — the Via Benefits transfer and health coverage termination are prohibited. There is no Scenario C.

At 2:00 PM, I transmitted a formal rejection email from info@bruinwatch.org to allison.cumming@elevancehealth.com, CC: kelly.tursany@elevancehealth.com, petina.jones@elevancehealth.com, BCC: my daughter, my son (two addresses), my wife. Subject: "Re: FAX ESCALATION/CSHD (CA)/closure." The letter opens: "Thank you for your prompt attention to my case. We may disagree but I do appreciate your professionalism. Respectfully, I must reject the case closure communicated in Lorena Rivera's letter dated April 17, 2026 (Reference: INQ-COMM-197295) in its entirety and demand immediate escalation to Elevance Health Corporate Compliance."

Section I — Federal False Claims Act litigation disclosure: Shea v. eHealth, Case No. 1:21-cv-11777-DJC (D. Mass.), March 25, 2026 motion to dismiss denied, all seven FCA counts proceeding into discovery, Elevance Health named defendant, $230 million in alleged illegal kickbacks in violation of the Anti-Kickback Statute (42 U.S.C. § 1320a-7b) and the False Claims Act (31 U.S.C. §§ 3729–3733).

Section II — United States v. Aon plc, Case No. 1:21-cv-01633 (D.D.C. 2021), DOJ Complaint ¶ 47, Via Benefits' parent controls 95% of private multicarrier retiree exchange market.

Section III — Temple v. Hartford Ins. Co. of Midwest, No. CV-12-2357 (D. Ariz. Aug. 26, 2014) — duty of good faith non-delegable; Anthem cannot escape liability by directing me to call UC.

Section IV — Rivera's letter contains material error: termination date stated as May 1, 2026; actual date on Certificate is April 1, 2026.

Section V — Three-stage disappearance of Anthem portal records documented.

Section VI — April 16, 2026 call with Anthem agent Roger on recorded line confirming coverage active; offer to pay $2,909.92 in back premiums rejected with statement "We don't handle that."

Section VII — HIPAA records request: 30-day deadline is April 30, 2026.

Section VIII — Spoliation demand.

Section IX — Five specific demands: (1) immediate escalation to Elevance Health Corporate Compliance; (2) full HIPAA compliance by April 30; (3) complete independent audit of Anthem's records for both Member IDs; (4) written explanation of how $14,094.36 in paid claims were removed from the portal and what happened to the December 2023 Valley Fever hospitalization records; (5) formal reopening of Reference INQ-COMM-197295.

The letter renews the offer to pay all outstanding back premiums of approximately $2,909.92 directly to Anthem. Neither UC nor Anthem has responded to that offer.

At 3:03 PM Pacific on April 17, 2026 — one hour and forty minutes after receipt of the UCLA Compliance Office CMP373 closure email — I transmitted a formal written rejection from info@bruinwatch.org to compliance@compliance.ucla.edu, with BCC to my wife, my daughter, and my son (family email addresses redacted for public release). Subject: "Re: PERSONAL & CONFIDENTAL//CMP373 Your Complaints related to UCLA PD."

The letter opens: "This matter is not closed," and sets forth the factual, procedural, and legal deficiencies in the CMP373 determination across multiple sections.

Section 1 establishes the documentary record: the February 19, 2026 California Labor Code § 132(a) crime report naming Captain Chobanian (57 days of UCLA PD silence as of the date of the letter); the three POST complaints (PUBLIC-26-000212, PUBLIC-26-000213, PUBLIC-26-000214) acknowledged by POST on February 25, 2026; and the March 30, 2026 spoliation warning whose April 14, 2026 response deadline had passed without a written response from any recipient.

Section 2 identifies the wrong legal standard applied: the UCLA Compliance Office determined no "University policy" violation, but POST's own acknowledgment letters identify California Penal Code § 13510.8 — not University policy — as the applicable statutory standard for the complaints filed.

The rejection cites by section the statutes that the CMP373 determination did not address, including California Government Code §§ 3304(a), 3305, 3306, and 3306.5(b) (POBR), and the four mutually irreconcilable custody-of-file statements catalogued elsewhere in this Sworn Statement. The rejection demands referral to the UCOP Systemwide LDO under Policy 1100563 § D.1.e or to an independent outside agency under UC Whistleblower Policy 1100171 § II.C.2 on the ground that the UCLA Compliance Office cannot lawfully adjudicate the CMP373 matter under the foundational principle of natural justice — nemo iudex in causa sua — because UCLA Compliance is itself the institutional actor of the very Adverse Personnel Action it purports to adjudicate.

The rejection preserves all rights, renews the February 9, 2026 litigation hold, and constitutes a Protected Disclosure under California Government Code § 8547.10 and UC Whistleblower Protection Policy 1100563.

Exhibit: EX 45 — Harold's formal rejection of CMP373 closure (April 17, 2026, 3:03 PM Pacific)

The disappearance of records from my Anthem Blue Cross member portal has occurred in three documented stages, each corresponding to a regulatory contact or filing milestone.

Stage 1 — Approximately December 24, 2025

I called Medicare at 1-800-MEDICARE approximately December 24, 2025. The Medicare representative told me on a recorded line that his Blue Cross of California coverage had been canceled approximately two years prior and that an enrollment/cancellation entry existed in the system predating his 65th birthday of January 3, 2026. A Medicare Supplement enrollment entry before my Medicare eligibility date is a factual impossibility. On December 31, 2025, I called back. Medicare representative Monica Soria searched for that same entry and stated on the recorded line: "I don't know where she looked at that because I'm not able to find it." A record visible to one CMS representative had become invisible to another within days. Stage 1 documents the first disappearance: a pre-65 enrollment/cancellation ghost entry that existed and then did not.

Stage 2 — April 16, 2026 — Post-BCBS Arizona Call

On April 16, 2026, at approximately 5:02 PM MST, I contacted Blue Cross Blue Shield of Arizona to obtain a Medigap quote. This call is documented in my formal demand letter to BCBS Arizona Chief Compliance Officer Anne Schrock transmitted April 16, 2026. This call and the events immediately following it correspond to the second documented stage of portal record changes. My April 17, 2026 rejection letter to Allison Cumming documents that records disappeared from my portal following this regulatory contact.

Stage 3 — Documented in April 17, 2026 Rejection Letter to Cumming

My April 17, 2026 nine-section rejection letter to Allison Cumming at Elevance Health documents a third stage of portal record disappearance following regulatory contacts. The third stage corresponds to contacts with regulatory bodies in the period following the April 8, 2026 DMHC 5th Supplemental filing.

The three-stage pattern establishes the following: records visible in the portal at one point in time became invisible following specific regulatory contacts, across three separate documented instances, in a sequence that begins in December 2025 and continues through April 2026. The approximately $230,000 in Valley Fever hospitalization claims that were processed by Anthem during December 2023 and January 2024 and are now completely absent from the portal constitute the most significant single disappearance within this three-stage pattern. The audit trail of those changes — including the date, time, user, and source of each modification — is the subject of Item 10 of my March 31, 2026 HIPAA records request, which remains unanswered as of the date of this sworn statement.

On April 20, 2026, my wife and I sat down with State Farm agent Juston Lisk at his office in Gold Canyon, Arizona — ten minutes from my home. They left in under an hour with signed Medigap supplemental insurance policies underwritten by State Farm, effective May 1, 2026 — the day after UC's stated cancellation date of April 30, 2026. My monthly premium: $203.23. My wife's monthly premium: $184.11. Combined State Farm monthly premium: $387.34.

UC Anthem's monthly premium had been $727.48 — $340.14 more per month, $4,081.68 more per year, for the same two people.

Based on the Williams-Cook determination's written statement of April 30, 2026 as the coverage suspension date — the only written UC coverage-end communication I possessed on April 3, 2026 — I presented that determination to State Farm as the qualifying event documentation for involuntary loss of group Medigap coverage. State Farm accepted the enrollment.

In ten months of RASC correspondence, Via Benefits phone calls, and formal administrative review, no UC representative informed me that he retained the right to decline the Via Benefits pathway entirely and purchase a Medigap policy on the open market. The option that resolved my coverage problem was never presented by any party whose job description included informing Medicare-eligible retirees of their coverage options.

At 5:56 PM Mountain Time, I logged into the UC UCRAYS portal and captured a screenshot of the Address page under his account. The portal displays both my Arizona addresses — mailing address at [address withheld], Gold Canyon, AZ 85118, and home address at [address withheld], Apache Junction, AZ 85119 — each bearing a Start Date of 10/20/2025, as if UCOP first received my Arizona address on October 20, 2025.

That assertion is contradicted by the documentary record.

UC's own automated ACH payment system transmitted 95 consecutive monthly retirement payments to my Arizona-registered Unify Federal Credit Union account between July 31, 2018 and March 31, 2026, totaling $167,581.83. The originating ACH metadata for those payments reads, verbatim: Description: "Deposit ACH UCOP UCRS ANNUIT / TYPE: UCRS PAYMT / ID: 1942557406 / CO: UCOP UCRS ANNUIT"; Entry Class Code: PPDACH; Trace Number: 043000262165091. Under the NACHA Operating Rules governing PPD-class ACH credits, the federal payment system requires the receiver's name, account number, and routing number on file before any ACH credit can be transmitted.

UCOP's 95 consecutive monthly transmissions to my Arizona account establish that UCOP's master records have continuously held my Arizona banking and contact information since at least July 31, 2018 — seven years, two months, and twenty days before the October 20, 2025 "start date" the UCRAYS portal now claims. Additionally, from tax year 2018 through tax year 2025, UCOP filed eight successive years of IRS Forms 1099-R and 1095-B with the federal government, each bearing my Arizona mailing address, each filed under penalty of perjury.

One of two assertions is false: either the federal ACH payment record and the eight years of sworn IRS filings are false, or the UCRAYS portal record is false. The bank ledger and the federal tax-filing record independently corroborate one another. The portal record stands alone.

77 Missing Pay Stubs and the Phantom Clawback

The same UCRAYS Benefit Payment Statements page displayed only 18 pay stubs, the earliest dated November 29, 2024, truncating approximately 77 monthly pay-stub records — more than six years — from my view. Among the 18 visible stubs, one entry reads as follows: Date — April 1, 2026. Gross — $0.00. Deductions — $0.00. Reimbursements — $0.00. Net — negative $727.48.

A document showing $0.00 gross, $0.00 deductions, and $0.00 reimbursements cannot mathematically reconcile to a net of negative $727.48.

No advance written notice of this entry was provided to me. No statutory citation accompanies it. No explanation through any channel has been given. No corresponding withdrawal appears in my Unify Federal Credit Union bank ledger for that date.

On April 26, 2026, I also confirmed through LinkedIn that Erin Pressman — Principal Investigator, UCOP Office of Ethics, Compliance & Audit Services, one of the three UCOP officials to whom I directed contact attempts on November 9, 2021 — has departed the University of California and is now employed as an Employment Investigator at OpenAI. Her departure from UC removes her from UC's institutional control for purposes of witness cooperation obligations under Policy 1100563 § D.4.c and the litigation hold renewed herein.

I check my PO Box at [address withheld], Suite 104, PMB 350, Gold Canyon, AZ 85118. The UC Medicare Supplement PPO plan welcome mailer was not present in the box on April 20, 2026. It is present on April 28, 2026. The PRSRT STD bulk mail class carries a processing and delivery lag of multiple days to multiple weeks between the date of generation in the sender's system and the date of physical delivery. The mailer bears the following identifying information: return address University of California, Office of the President, 1111 Franklin Street, Oakland, CA 94607; postage indicia PRSRT STD, US POSTAGE PAID, SAN FRANCISCO CA, PERMIT 5231; addressee CHARLES A HAROLD, [address withheld], GOLD CANYON AZ 85118. The mailer's headline reads: "Get to know the UC Medicare Supplement PPO plan." The mailer bears co-branding logos for Anthem and NAVITUS. The mailer instructs me to register with Anthem by calling (844) 437-0486 and with Navitus by calling (833) 637-4309. The mailer describes the coverage as including: $0 Medicare Part A and B deductibles; Anthem Health Guide access; Benefits Beyond Medicare; prescription drug coverage through Navitus; global coverage; and access to UC Health providers.

On the same date, I log into the Anthem Blue Cross member portal and video-record the portal session. The portal shows both Charles A. Harold and my wife Z. Harold enrolled and covered from January 1, 2026. The portal additionally displays dozens of claims from 2024 now appearing in the processing queue — claims that were not accessible or visible in the portal at the time of the April 2, 2026 screenshot session documented in Exhibit EX_32. My video recording of the April 28, 2026 portal session, capturing the current enrollment status and the 2024 claims now appearing in the processing queue, is preserved in my evidentiary record and is available for production.

April 30, 2026 at 5:51 PM Pacific. I transmitted by email from info@bruinwatch.org to compliance@compliance.ucla.edu a written Petition for Independent Audit and Records Reconciliation under California Government Code § 8547.10. The Petition expressly posed a binary that UC’s April 17, 2026 disposition of CMP373 could not escape: either (A) the CCW denial was correct and I am a current Duty Disability Income recipient entitled to reinstatement and retroactive payments since 2015, or (B) the CCW denial was incorrect and the Compliance Office’s ratification of it rests on a basis the personnel file does not support. The Petition identified concurrent obligations under Labor Code § 5803 and § 5410, Penal Code § 832.5(b), § 135, § 135.5, and § 13510.9, and demanded written confirmation that no records under the February 9, 2026 preservation hold had been destroyed, altered, or archived.

May 1, 2026 at 1:02 PM Pacific. The UCLA Compliance Office at compliance@compliance.ucla.edu transmitted by email a two-sentence response, in full:

“We have reviewed your April 30, 2026 email and do not plan to take any further action in this matter. We realize you continue to have concerns, and you are always welcome to report them to any federal or state entity with oversight responsibility in such matters.”

The disposition contains no findings of fact, no legal conclusions, no reference to UC Whistleblower Policy 1100171, no reference to UC Whistleblower Protection Policy 1100563, no reference to the § 8547.10 procedural framework, no determination under any required disposition category, no investigator name, no scope, no records-review reference, no appeal rights, and is signed by an office rather than a person with title and authority. The disposition does not address the binary expressly posed in the Petition.

May 1, 2026 at 4:25 PM Pacific. I transmitted to the UCLA Compliance Office a written reply to the May 1, 2026 1:02 PM disposition. The reply: (i) acknowledged receipt of the disposition; (ii) accepted UC’s April 17, 2026 ratification of the CCW denial as UC’s own institutional determination that I am a current Duty Disability Income recipient under UC Gold Book GO 21-02 § 1700.1(b)(1); (iii) catalogued the entitlements that flow from that determination — reinstatement of DDI tax status, retroactive payments since the 2015 conversion, employer-paid medical premiums under the 2003 WCAB-approved settlement, removal from the Via Benefits transfer pathway, and re-enrollment in UC High Option Supplement to Medicare as a DDI recipient with no geographic restriction; (iv) renewed the records-preservation demand under California Labor Code §§ 5803 and 5410, Penal Code § 832.5(b), Penal Code §§ 135 and 135.5, and the common-law spoliation duty triggered by the February 9, 2026 written hold; (v) requested that the Compliance Office locate my peace-officer personnel file during the pendency of external-agency referral, given the irreconcilable written statements of Lieutenant Echols (April 1, 2026) and Captain Chobanian (August 25, 2023 and February 10, 2026); and (vi) confirmed, consistent with the disposition’s express invitation, that referral to federal and state entities with oversight responsibility has been made.

Exhibits.

• EX 47 — May 1, 2026 1:02 PM Pacific UCLA Compliance Office two-sentence email response to the § 8547.10 Petition (PDF).
• EX 49 — May 1, 2026 4:25 PM Pacific reply email from Chuck Harold to the UCLA Compliance Office in response to the May 1, 2026 1:02 PM disposition (PDF).

Legal Impact Analysis.

Under Miklosy v. Regents of the University of California (2008) 44 Cal.4th 876, UC’s internal whistleblower process must provide a meaningful, non-perfunctory mechanism that satisfies due process. A two-sentence disposition, issued without findings, without legal conclusions, without policy citations, without an investigator name, without a records-review reference, and without addressing the binary expressly posed in the Petition, is on its face the perfunctory disposition Miklosy identifies as the procedural failure that opens the § 8547.10 civil damages route. The disposition’s opening assertion that the matter has been “reviewed” is preserved separately in the documentary forensic record outside of this Sworn Statement.

The disposition itself, by its own terms, expressly invites referral to “any federal or state entity with oversight responsibility,” which I treat as UC’s written authorization for external referral.

April 20, 2026. My wife my wife and I each enrolled in State Farm Medicare Supplement (Medigap) policies. Combined monthly premium for both policies: $387.34. The previous monthly premium for my single UC High Option Supplement to Medicare PPO coverage through UC RASC was $727.48.

April 22, 2026. Navitus MedicareRx (PDP), P.O. Box 1039, Appleton, WI 54912-1039, generated a letter to my wife at our home address ([address withheld]) bearing reference number V00200155603. The letter states in pertinent part: “This is to confirm your disenrollment from Navitus MedicareRx (PDP). Beginning 05/01/2026, Navitus MedicareRx (PDP) won’t cover your prescription drugs.” The letter is signed only with a form number (S9701_2026_ALL_DEN10A_V01_C). Neither my wife nor I requested or initiated this disenrollment.

April 30, 2026. I executed and transmitted to UC RASC a UBEN 100 (R4/26) Retiree Continuation, Enrollment or Change form. On the form I checked the CANCEL/DE-ENROLL boxes for UC Medicare PPO — UC High Option Supplement to Medicare with effective date 4/30/26, and the Voluntary checkbox under CANCEL/DE-ENROLL. In the Comments field I wrote: “I have a letter from Beverly Jeanine Williams-Cooke of RASC that states, ‘If you do not complete the enrollment through Via Benefits, your UC High Option Supplemental coverage will be suspended April 30, 2026.’” The signed form was preserved as a documentary record on UC’s own current-revision letterhead.

May 1, 2026. The federal Medicare beneficiary portal at medicare.gov/my/home, accessed today under my logged-in account “Charles,” displays in the “Your plans” module the following three plans:

• Original Medicare — Hospital Insurance (Part A) coverage start 1/1/2026; Medical Insurance (Part B) coverage start 1/1/2026.
• Drug Insurance (Part D) — Wellcare Value Script (PDP), coverage start 5/1/2026.
• Other Insurance — BLUE CROSS OF CALIFORNIA, coverage start 1/1/2026.

Wellcare Value Script (PDP) is shown today, May 1, 2026, with a coverage start date of today. Navitus MedicareRx (PDP) is no longer present in the federal Medicare.gov record. The Anthem Blue Cross of California entry remains present in the federal Medicare.gov “Other Insurance” field with an unchanged coverage-start date of January 1, 2026.

I did not file any cancellation or change form to terminate Navitus coverage. The transition from Navitus to Wellcare Value Script appears in the federal record as having occurred automatically following the April 20, 2026 State Farm enrollment, with the Navitus disenrollment letter generated April 22, 2026 (two days after enrollment), and the Wellcare effective date set to May 1, 2026 (federal standard effective date for Special Enrollment Period changes).

Concurrent Anthem record. The Anthem Blue Cross of California “Other Insurance” entry that remains visible on Medicare.gov as of May 1, 2026 exists in parallel with the following separately documented facts established elsewhere in this Sworn Statement: (i) my UBEN 100 (R4/26) cancellation of UC High Option Supplement to Medicare effective April 30, 2026, signed yesterday; (ii) the April 1, 2026 Anthem portal termination of UC High Option PPO coverage twenty-nine days before Williams-Cook’s stated April 30 suspension date; (iii) the April 7, 2026 reinstatement of coverage in the Anthem portal with a backdated January 1 effective date, which occurred during a period in which DMHC Case #1409109 and CMS Case #7100158 were active investigations; (iv) the Cumming/Rivera April 17, 2026 Anthem closure letter stating an April 30, 2026 termination date; (v) UCRAYS’ April 1, 2026 phantom pay-stub entry of negative $727.48; and (vi) the non-payment condition that arose after UC stopped collecting the premium in January 2026 without notice. As of the date of this entry, the federal Medicare.gov record reflects none of those events.

The Two Household Transitions, Compared on the Federal Record.

Step	My wife (Navitus → Wellcare)	Charles Harold (Anthem / UC High Option)
Outside enrollment	Apr 20, 2026 (State Farm)	Apr 20, 2026 (State Farm)
Disenrollment from prior plan	Apr 22, 2026 disenrollment letter generated by Navitus (two days after enrollment, no member action required)	Apr 1, 2026 termination by Anthem (29 days before stated date); Apr 7 reinstatement during active DMHC and CMS investigations; Apr 30, 2026 UBEN 100 (R4/26) signed by Charles under a written threat from UC RASC
Effective date of transition	May 1, 2026 (federal standard SEP effective date)	Variously stated as Apr 1, Apr 30, May 1, and an undisclosed internal-system date
Federal Medicare.gov record on May 1, 2026	Wellcare Value Script (PDP), coverage start 5/1/2026; Navitus no longer present	BLUE CROSS OF CALIFORNIA, coverage start 1/1/2026, still present
Number of intermediating institutions	Two (CMS, Navitus). UC not in the loop.	UC RASC, UC Compliance, Anthem Blue Cross, Elevance Health, Via Benefits, DMHC, CMS.

Exhibits.

• EX 48 — April 22, 2026 Navitus MedicareRx (PDP) disenrollment letter to my wife, reference V00200155603, form S9701_2026_ALL_DEN10A_V01_C, confirming disenrollment effective May 1, 2026 (PDF).
• EX 48a — April 30, 2026 UBEN 100 (R4/26) signed by Chuck Harold cancelling UC Medicare PPO — UC High Option Supplement to Medicare effective April 30, 2026, with Comments-field rebuttal documenting the written threat from UC RASC Benefits Analyst III Beverly Jeanine Williams-Cooke (PDF, three pages).
• EX 48b — May 1, 2026 screenshot of medicare.gov/my/home logged in as Charles, showing Wellcare Value Script (PDP) coverage start 5/1/2026 and BLUE CROSS OF CALIFORNIA coverage start 1/1/2026 (image, captured 2:30 PM Pacific).
• EX 48c — May 1, 2026 screenshot of medicare.gov/my/home logged in as Charles, captured at 2:39 PM Pacific (confirms persistence of the Wellcare and Blue Cross of California records nine minutes after EX 48b).

Legal Impact Analysis.

Federal record as the controlling source. The medicare.gov beneficiary portal is the federal authoritative source maintained by the Centers for Medicare & Medicaid Services. Where the federal Medicare.gov record on May 1, 2026 reflects an unchanged Anthem Blue Cross of California coverage-start date of January 1, 2026, that record cannot be reconciled with UC’s and Anthem’s contemporaneous written assertions of an April 1, April 30, or May 1 termination date for the same coverage.

Procedural compliance of UBEN 100 (R4/26). The UBEN 100 (R4/26) signed April 30, 2026 is the only document in the entire UC-related record that procedurally aligns with the date Williams-Cook stated in writing on February 27, 2026 (“suspended on April 30, 2026”). The Voluntary checkbox under CANCEL/DE-ENROLL is selected because UC’s current-revision form provides only the Voluntary and Involuntary checkboxes; the Comments field accompanies the Voluntary selection with a verbatim quotation of the written threat that compelled the cancellation.

Parallel transition under federal Medicare rules. The Navitus → Wellcare transition for my wife, occurring with no member-initiated cancellation form and no employer-group intermediation, completed on the federal standard Special Enrollment Period schedule: outside enrollment April 20, 2026; carrier-generated disenrollment letter April 22, 2026; effective date May 1, 2026. The transition is reflected on the federal Medicare.gov record as of May 1, 2026.

Anthem → State Farm transition under UC intermediation. The same outside enrollment date (April 20, 2026), for the same household, did not produce the same federal-record outcome on the same May 1, 2026 effective date. The Anthem Blue Cross of California entry remains visible on Medicare.gov on May 1, 2026 with an unchanged January 1, 2026 coverage-start date.

Records-reconciliation obligation. Reconciliation of the federal Medicare.gov record with UC’s and Anthem’s contemporaneous written records, and identification of the institutional actor responsible for the discrepancy, falls within the scope of the April 30, 2026 § 8547.10 Petition for Independent Audit and Records Reconciliation transmitted to the UCLA Compliance Office and disposed of in two sentences on May 1, 2026 at 1:02 PM Pacific.