Caregiver Packet — Case 5:24-cr-00292-PCP, Document118-1

Summary

This is a caregiver need and active search evidence packet filed with Document 118-1. A cover statement signed with the name Cassie Will Darnall says the packet shows her mother medically requires a caregiver, does not currently have one, and that she is searching through licensed agencies and private caregivers. The packet includes a functional needs assessment summary listing assistance with dressing, bathing, medication reminders, technology use and scheduling, and an incident log starting October 2025 with dated entries. A declaration dated 12/12/2025 in the name of Cassie Will Darnall says her mother, Sandra Will, has no caregiver and that the caregiver left Dec 9th 2025. A declaration of Sandra Will dated 12/12/2025 says no agency or individual is providing daily assistance.

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Full text

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Case 5:24-cr-00292-PCP Document118-1 Filed 01/06/26 Page 2of8

This packet demonstrates the following:

1. My mother medically requires a caregiver.

2. She does not currently have one.

3. I am proactively searching for one through licensed agencies
and private caregivers.

4, She needs daily assistance for safety, technology, and
legal/medical tasks.

5. This documentation reflects legitimate, good-faith efforts to
secure proper care.

Respectfully submitted,
Cassie Will Darnall
Case 5:24-cr-00292-PCP Document116- Filed 12/29/25 Page5of 10

Caregiver Need & Active Search Evidence Packet

1. Functional Needs Assessment Summary

Completed by Former Caregiver Agency :

This functional assessment reflects the typical findings from a
licensed Home Health Agency or Geriatric Care Manager:

ADLs she needs assistance with:
¢ Dressing

¢ Bathing

¢ Supervision for safety

¢ Medication reminders

IADLs she needs assistance with:

* Technology use (email, online systems, documents)
* Managing legal paperwork

¢ Scheduling and understanding appointments

¢ Financial or complex decision making
Case 5:24-cr-00292-PCP Document118-1 Filed 01/06/26 Page4of8

Case 5:24-cr-00292-PCP Document116 Filed 12/29/25 Page 6of10

Recommendation:
Client requires daily support and a consistent caregiver to ensure
safety and proper handling of legal/medical matters.

3. Incident Log (Starting October 2025)

¢ 10/03/2025 — Difficulty understanding voicemail from attorney;
needed step-by-step explanation.

* 10/08/2025 — Became confused while paying a bill online; unable
to navigate website without full guidance.

* 10/14/2025 — Misplaced important legal documents; later found
them in the kitchen with food items.

* 10/19/2025 — Forgot how to use television remote; unable to
change input or find news channel.

* 10/23/2025 — Repeatedly asked the same question about lawsuit
deadlines within one hour.

¢ 10/27/2025 — Attempted to call attorney but dialed random
contacts instead; became frustrated and upset.

¢ 10/30/2025 — Mistook scam email for official court notice;
required intervention to prevent response.

¢ 11/01/2025 — Forgot scheduled medical appointment despite
reminders; needed escort and re-explanation.

° 11/03/2025 — Confused by text message from Medicare; believed
benefits were being cut.

¢ 11/07/2025 — Unable to locate medications; required help
organizing daily pillbox.

° 11/09/2025 — Became anxious after misinterpreting a routine
notice from insurance as a termination letter.

¢ 11/13/2025 — Could not recall passwords for banking; locked
herself out of online account.

¢ 11/16/2025 — Forgot whether she ate breakfast; attempted to take
medication twice.
Case 5:24-cr-00292-PCP Document118-1 Filed 01/06/26 Page5of8

Case 5:24-cr-00292-PCP Document116 Filed 12/29/25 Page 7 of 10

¢ 11/19/2025 — Needed help understanding a court date reminder
letter; believed it was a demand notice.

¢ 11/22/2025 — Confused when attempting to print documents;
printer jam escalated her anxiety.

¢ 11/25/2025 — Misidentified phone scam caller as a government
agency; nearly shared personal information.

¢ 11/28/2025 — Forgot how to check voicemail; required full
guidance and emotional reassurance.

¢ 11/30/2025 — Could not understand difference between attorney
retainer letter and invoice; became distressed.

¢ 12/03/2025 — Forgot to attend scheduled lab appointment;
appointment had to be rescheduled and transportation arranged.
¢ 12/07/2025 — Became confused by prescription refill notice;
believed medication had been discontinued.

e 12/11/2025 — Could not turn on the microwave; required
supervision to ensure safety.
Case 5:24-cr-00292-PCP Document116 Filed 12/29/25 Page 8of10

Section B — Evidence that She Has No Current Caregiver
DECLARATION OF CASSIE WILL DARNALL

I, Cassie Will Darnall, declare under penalty of perjury:

1. My mother, Sandra Will, does not currently have a caregiver.
Her caregiver left Dec 9th 2025.

2. She is not receiving any in-home support services.

3. There is no caregiver under contract, no agency providing care,
and she receives no daily care aside from my assistance.

4, Due to her needs, I am the only person helping her manage
technology, legal tasks, and daily responsibilities.

5. I am actively seeking a caregiver on her behalf and have
contacted multiple agencies.

I declare under penalty of perjury that the foregoing is true and
correct.

Date: 12/12/2025

Signature a
Case 5:24-cr-00292-PCP Documenti1i8-1 Filed 01/06/26 Page7of8

DECLARATION OF SANDRA WILL

1 SANDRA WILL, declare that I do not have a caregiver at this
time. No agency or individual is providing daily assistance to me.
Cassie is reaching out to agencies and referrals to find a helper for

me.

I understand that my daughter is helping me search for an
appropriate caregiver, and currently is my caregiver.

Date: 12/12/2025


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gov.uscourts.cand.430212.118.1.pdf

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gov.uscourts.cand.430212.118.1.pdf

Original

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