Case: Dominguez v. Schwarzenegger

4:09-cv-02306 | U.S. District Court for the Northern District of California

Filed Date: May 26, 2009

Closed Date: 2014

Clearinghouse coding complete

Case Summary

On May 26, 2009, recipients of In-Home Service Support (IHSS) care filed a lawsuit under the Supremacy Clause against Arnold Schwarzenegger and other government officials in the Northern District Court of California. The Plaintiffs, represented by private counsel, asked the court for injunctive and declaratory relief, claiming that in enacting Section 12306. 1 (d)(6), the California Legislature failed to consider the required factors of efficiency, economy, quality of care, and access to servic…

On May 26, 2009, recipients of In-Home Service Support (IHSS) care filed a lawsuit under the Supremacy Clause against Arnold Schwarzenegger and other government officials in the Northern District Court of California. The Plaintiffs, represented by private counsel, asked the court for injunctive and declaratory relief, claiming that in enacting Section 12306. 1 (d)(6), the California Legislature failed to consider the required factors of efficiency, economy, quality of care, and access to services prior to its enactment.

The IHSS program provides crucial medical assistance to low-income elderly people and disabled people as part of California's Medicaid program (also called "Medi-Cal"). The types of assistance that IHSS providers give are bathing, feeding, dressing, and providing the medications IHSS recipients require. The IHSS program allows recipients to reside safely in their homes and costs less than institutionalized care.

At the time of this case, there were over 360,000 IHSS providers giving assistance to 440,000 individuals in California. Providers are often relatives, such as a parent, that leave a full-time job in order to care for a child or other person. The wages began at $8.10 per hour to $12.10, but with the state's reductions decreased to at most $10.10 per hour. Under the Title XIX of the Social Security Act, 42 U.S.C. § 1396 et seq., such modifications must be approved by the Department of Health and Human Services Centers for Medicare and Medicaid Services (CMS) prior to being implemented. In September and December 2008, California submitted amendment proposals to CMS that incorporated most of the rate reductions the Legislature had already included in these statutes. Before CMS had completed its review the amendments, this suit and several others seeking injunctions to prevent the rate reductions were filed.

In the case at hand, Plaintiffs motioned for a preliminary injunction on June 4th, 2009. Defendants repeatedly challenged Plaintiffs' motion for a preliminary injunction, objecting to the declarations of Plaintiffs' witnesses and evidence filed by the Plaintiff. After a series of back and forth objections, the Northern District Court for California (Judge Claudia Wilken) ruled in favor of the Plaintiffs and granted Plaintiffs' motion for a preliminary injunction. Judge Wilken granted Plaintiffs' motion for preliminary injunction on June 26th, 2009, just a few days before IHSS cuts were set to take effect on July 1st, 2009.

In the Court's order, Judge Claudia Wilken concluded that the Plaintiffs established the necessary criterion for being granted a preliminary injunction. The Plaintiffs, according to Judge Wilken, established both a strong likelihood of success and that they would suffer irreparable injury if IHSS cuts were implemented. Judge Wilken found that State Defendants had violated the procedural requirements of the Medicaid Act, including the consideration of how IHSS cuts would affect efficiency, economy, and quality of care given by IHSS providers to elderly and disabled recipients (42 U. S. C. §1396a(a)(30)(A)). State Defendants did not consider factors laid in the federal statute when they decided to implement California Welfare and Institutions Code § 12301(d)(6).

The Defendants appealed the preliminary injunction to the Ninth Circuit Court of Appeals, which issued a decision on March 3, 2010. Judge Milan D. Smith reasoned that the factors of efficiency, economy, and quality of care applied to the statute in dispute, the California Welfare and Institutions Code Section 12306.1(d)(6). The Ninth Circuit Court of Appeals also wrote in the opinion that the legislative report Defendants had submitted regarding the quality and access in the IHSS system was inadequate under the Medicaid provision. Other important parts of the opinion included the Court's finding that Plaintiffs did show irreparable harm in showing that IHSS providers would be harmed by reduction in their hourly wages and benefits, in addition to IHSS recipients. The Court of Appeals found that the balance of hardships and the public interest also weighed in favor of implementing the preliminary injunction. In deciding to grant or deny a preliminary injunction, the Court of Appeals needed to review the District Court's finding for abuse of discretion. The Court of Appeals found no abuse of discretion and agreed with the District Court's first decision. Dominguez et al v. Schwarzenegger, 596 F.3d 1087 (N.D. Cal. 2009).

On March 24, 2010, the Defendants petitioned the United States Supreme Court to review the decision of the Ninth Circuit holding that the Supremacy Clause of the U.S. Constitution could serve as a basis for a cause of action in this case. During the period between the Appellate Court decision and the Supreme Court's grant of review, the case remained active at the District Court level. On June 8, 2010, prior to the Supreme Court's grant of certiorari, the District Court granted class certification, and on July 2, 2010, it ordered a temporary restraining order prohibiting the Defendants from lowering hourly wages and benefit contributions of IHSS workers in the County of Fresno. The Supreme Court granted certiorari review on January 18, 2011, consolidating this case with four others that raised the same issue. These four cases were Independent Living Center of Southern California, Inc. v. Shewry (Clearinghouse case code PB-CA-0016), Managed Pharmacy Care v. Maxwell-Jolly (PB-CA-0019), California Pharmacists Association v. Maxwell-Jolly (PB-CA-0020), and Santa Rosa Memorial Hospital v. Shewry (Docket #: 3:08-cv-05173-SC).

Oral argument before the Supreme Court took place on October 3, 2011. After oral argument and while the cases were pending before the Supreme Court, CMS approved California's amendments to its Medicaid plan. In light of this, the Supreme Court declined to issue a ruling on whether the Supremacy Clause could serve as a basis for a private suit to enforce Title XIX against a state. Instead, the Supreme Court vacated the Ninth Circuit Court's decision and remanded the case to the Ninth Circuit for reconsideration, with instructions to take into account CMS's approval of the amendments. Douglas v. Independent Living Center of Southern California, 132 S. Ct. 1204 (U.S. 2012).

After the Supreme Court decision was issued, the parties entered settlement mediation. On March 26, 2013, the parties were granted a joint motion to stay proceedings at the Ninth Circuit Court of Appeals pending the approval of the class-action settlement agreement at the District Court level. On April 4, 2013, the District Court granted preliminary approval of a settlement. Final approval of the settlement was granted on May 23, 2013.

The Settlement also resolved Oster v. Lightbourne (In the Clearinghouse as DR-CA-0027: V.L. v. Wagner, see related cases), a suit that raised similar issues. For the purpose of the settlement, the plaintiff classes from these two suits were combined and expanded to include all IHSS recipients who resided in Alameda, Calaveras, Contra Costa, Fresno, Los Angeles, Madera, Marin, Mariposa, Mendocino, Monterey, Napa, Placer, Riverside, Sacramento, San Benito, San Francisco, San Joaquin, San Luis Obispo, San Mateo, Santa Barbara, Santa Clara, Santa Cruz, Solano, Sonoma, Yolo, and Yuba counties. The settlement would prevent the IHSS wage cuts from coming into effect, keeping them at the statutory rates that were in place prior to the 2009 amendments contested in Dominguez. The terms also included an eight-percent cut in IHSS employee service hours for twelve months, which would then be replaced by a seven-percent cut in service hours, contingent on the passing of the legislation described below. These cuts in service hours would be inclusive of and not in addition to an already existing 3.4 percent cut in hours.

The attached legislation would repeal an earlier bill that cut authorized IHSS service hours by twenty percent across the board, implementation of which was delayed pending the outcome of these suits and related litigation. 12306.1(d)(6), the amendment which lowered IHSS wages, would also be repealed. If this legislation was not passed by the California Legislature and delivered to the Governor by November 1, 2013, then the Parties were to meet and confer to determine whether they could agree upon a mutually acceptable solution. If the Parties did not reach a new agreement, then any Party would be able to declare the settlement agreement void.

No attorneys' fees or costs were awarded.

On Sept. 3, 2014, the court approved amendments to the settlement to which the parties stipulated. The State was given a deadline to submit proposed legislation authorizing an assessment on home care services by Feb. 1, 2015.

There has been no further docket activity, and the case appears to be closed.

Summary Authors

Julianne Nowicki (5/27/2010)

Alex Colbert-Taylor (7/18/2013)

Virginia Weeks (11/12/2017)

Related Cases

Independent Living Center of Southern California v. Maxwell-Jolly, Central District of California (2008)

Independent Living Center v. Maxwell-Jolly, Central District of California (2009)

California Pharmacists Association v. Maxwell-Jolly, Central District of California (2009)

Gray Panthers v. Schwarzenegger, Northern District of California (2009)

Oster v. Wagner, Northern District of California (2009)

People

For PACER's information on parties and their attrorneys, see: https://www.courtlistener.com/docket/5861805/parties/dominguez-v-schwarzenegger/


Judge(s)

Breyer, Stephen Gerald (District of Columbia)

Canby, William Cameron Jr. (Arizona)

Corley, Jacqueline Scott (California)

Fletcher, William A. (California)

Larson, James L. (California)

Reinhardt, Stephen Roy (California)

Roberts, John Glover Jr. (District of Columbia)

Smith, Milan Dale Jr. (California)

Thomas, Sidney Runyan (Montana)

Wilken, Claudia Ann (California)

Judge(s)

Breyer, Stephen Gerald (District of Columbia)

Canby, William Cameron Jr. (Arizona)

Corley, Jacqueline Scott (California)

Fletcher, William A. (California)

Larson, James L. (California)

Reinhardt, Stephen Roy (California)

Roberts, John Glover Jr. (District of Columbia)

Smith, Milan Dale Jr. (California)

Thomas, Sidney Runyan (Montana)

Wilken, Claudia Ann (California)

Attorneys(s) for Plaintiff

Arkush, Anne Nelson (California)

Berzon, Stephen P. (California)

Cannizo, Craig J. (California)

Cannizzo, Craig J. (California)

Carman, Lynn S. (California)

Cincotta, Caroline (California)

Kronland, Scott A. (California)

Leyton, Stacey M. (California)

Maynard, Deanne (District of Columbia)

Phillips, Carter G (District of Columbia)

Reagan, Mark E. (California)

Thoreen, Peder J. (California)

White, Emily Butler (California)

Attorneys(s) for Defendant

Brown, Gregory David (California)

Buchanan, Timothy John (California)

Bunshoft, Jennifer A. (California)

Carson, Susan (California)

Humes, James M. (California)

Jeffcoach, Mandy L. (California)

Schwartz, Karin S. (California)

Sherman, Greg B. (California)

Silberman, David Abraham (California)

Woods, Michael Gary (California)

Zwibelman, Michael A. (District of Columbia)

Other Attorney(s)

Ball, Frederick R. (Illinois)

Bullock, Louis Werner (Oklahoma)

Bursch, John J. (Michigan)

Hallward-Driemeier, Douglas Harry (District of Columbia)

Joseph, Lawrence J (District of Columbia)

Kneedler, Edwin S. (District of Columbia)

McConnell, Michael W (District of Columbia)

Untereiner, Alan (District of Columbia)

Verrilli, Donald B. Jr. (District of Columbia)

Vladeck, Stephen I (District of Columbia)

Wolfson, Paul R. Q. (Illinois)

Documents in the Clearinghouse

Document

09-01158

SCOTUS Docket (PACER)

Douglas v. California Pharmacists Association

Supreme Court of the United States

March 26, 2012

March 26, 2012

Docket

09-16359

USCA Ninth Circuit Docket (PACER)

U. S. Court of Appeals for the Ninth Circuit

July 8, 2013

July 8, 2013

Docket

4:09-cv-02306

Docket [PACER]

Sept. 3, 2014

Sept. 3, 2014

Docket
1

4:09-cv-02306

Complaint

May 26, 2009

May 26, 2009

Complaint
55

4:09-cv-02306

PLAINTIFFS' EX PARTE MOTION TO SHORTEN TIME FOR MOTION FOR A PRELIMINARY INJUNCTION SO THAT RELIEF CAN BE GRANTED BEFORE JULY 1, 2009, OR, IN THE ALTERNATIVE, FOR A TEMPORARY RESTRAINING ORDER FINDING A RULING ON PRELIMINARY INJUNCTION

June 4, 2009

June 4, 2009

Pleading / Motion / Brief
5

4:09-cv-02306

PLAINTIFFS' NOTICE OF MOTION AND MOTION FOR A PRELIMINARY INJUNCTION; MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT

June 4, 2009

June 4, 2009

Pleading / Motion / Brief
73

4:09-cv-02306

OBJECTIONS TO THE DECLARATION OF JOHN F. SCHNELLE

June 11, 2009

June 11, 2009

Pleading / Motion / Brief
75

4:09-cv-02306

OBJECTIONS TO DECLARATION OF CANDACE HOWES

June 11, 2009

June 11, 2009

Pleading / Motion / Brief
74

4:09-cv-02306

OBJECTIONS TO DECLARATION OF JUSZTINA TRAUM

June 11, 2009

June 11, 2009

Pleading / Motion / Brief
99

4:09-cv-02306

STATE DEFENDANTS’ OBJECTIONS TO EVIDENCE FILED BY PLAINTIFFS IN SUPPORT OF MOTION FOR PRELIMINARY INJUNCTION

June 15, 2009

June 15, 2009

Pleading / Motion / Brief

Resources

Docket

See docket on RECAP: https://www.courtlistener.com/docket/5861805/dominguez-v-schwarzenegger/

Last updated Aug. 4, 2022, 3:14 a.m.

ECF Number Description Date Link Date / Link
1

COMPLAINT against Arnold Schwarzenegger, John A. Wagner, David Maxwell-Jolly, John Chiang, Fresno County, Fresno County In-Home Supportive Services Public Authority ( Filing fee $ 350, receipt number 34611032471.). Filed byAlex Brown, Donna Brown, Mikesha Martinez, Chloe Lipton, Herbert M. Meyer, Leslie Gordon, Charlene Ayers, Willie Beatrice Sheppard, Andy Martinez, Service Employees International Union United Health Care Workers West, Service Employees International Union United Long-Term Care Workers, Service Employees International Union Local 521, Service Employees International Union California State Council, Lydia Dominguez. (Attachments: # 1 Civil Cover Sheet)(cp, COURT STAFF) (Filed on 5/26/2009) (Entered: 05/27/2009)

1 Civil Cover Sheet

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May 26, 2009

May 26, 2009

PACER
2

Certificate of Interested Entities by Alex Brown, Donna Brown, Mikesha Martinez, Chloe Lipton, Herbert M. Meyer, Leslie Gordon, Charlene Ayers, Willie Beatrice Sheppard, Andy Martinez, Service Employees International Union United Health Care Workers West, Service Employees International Union United Long-Term Care Workers, Service Employees International Union Local 521, Service Employees International Union California State Council, Lydia Dominguez (cp, COURT STAFF) (Filed on 5/26/2009) (cp, COURT STAFF). (Entered: 05/27/2009)

May 26, 2009

May 26, 2009

PACER
3

Summons Issued as to Arnold Schwarzenegger, John A. Wagner, David Maxwell-Jolly, John Chiang, Fresno County, Fresno County In-Home Supportive Services Public Authority. (cp, COURT STAFF) (Filed on 5/26/2009) (Entered: 05/27/2009)

May 26, 2009

May 26, 2009

PACER
4

ADR SCHEDULING ORDER: Case Management Statement due by 8/25/2009. Case Management Conference set for 9/1/2009 02:00 PM. (Attachments: # 1 Standing Order)(cp, COURT STAFF) (Filed on 5/26/2009) (Entered: 05/27/2009)

1 Standing Order

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May 26, 2009

May 26, 2009

PACER

CASE DESIGNATED for Electronic Filing. (cp, COURT STAFF) (Filed on 5/26/2009)

May 26, 2009

May 26, 2009

PACER
5

MOTION for Preliminary Injunction ; MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT filed by Mikesha Martinez,, Charlene Ayers, Alex Brown, Donna Brown, Lydia Dominguez, Leslie Gordon, Chloe Lipton, Andy Martinez, Herbert M. Meyer, Service Employees International Union California State Council, Service Employees International Union Local 521, Service Employees International Union United Health Care Workers West, Service Employees International Union United Long-Term Care Workers, Willie Beatrice Sheppard(Leyton, Stacey) (Filed on 6/4/2009) Modified on 6/5/2009 (cp, COURT STAFF). (Entered: 06/04/2009)

June 4, 2009

June 4, 2009

PACER
6

Declaration of David F. Altman filed byMikesha Martinez, Charlene Ayers, Alex Brown, Donna Brown, Lydia Dominguez, Leslie Gordon, Chloe Lipton, Andy Martinez, Herbert M. Meyer, Service Employees International Union California State Council, Service Employees International Union Local 521, Service Employees International Union United Health Care Workers West, Service Employees International Union United Long-Term Care Workers, Willie Beatrice Sheppard. (Related document(s) 5 ) (Leyton, Stacey) (Filed on 6/4/2009) Modified on 6/5/2009 (cp, COURT STAFF). (Entered: 06/04/2009)

June 4, 2009

June 4, 2009

PACER
7

Declaration of Teresa Armas filed byMikesha Martinez,, Charlene Ayers, Alex Brown, Donna Brown, Lydia Dominguez, Leslie Gordon, Chloe Lipton, Andy Martinez, Herbert M. Meyer, Service Employees International Union California State Council, Service Employees International Union Local 521, Service Employees International Union United Health Care Workers West, Service Employees International Union United Long-Term Care Workers, Willie Beatrice Sheppard. (Leyton, Stacey) (Filed on 6/4/2009) Modified on 6/5/2009 (cp, COURT STAFF). (Entered: 06/04/2009)

June 4, 2009

June 4, 2009

PACER
8

Declaration of Charlene Ayers filed byMikesha Martinez, Charlene Ayers, Alex Brown, Donna Brown, Lydia Dominguez, Leslie Gordon, Chloe Lipton, Andy Martinez, Herbert M. Meyer, Service Employees International Union California State Council, Service Employees International Union Local 521, Service Employees International Union United Health Care Workers West, Service Employees International Union United Long-Term Care Workers, Willie Beatrice Sheppard. (Related document(s) 5 ) (Leyton, Stacey) (Filed on 6/4/2009) Modified on 6/5/2009 (cp, COURT STAFF). (Entered: 06/04/2009)

June 4, 2009

June 4, 2009

PACER
9

Declaration of Willie Billops filed byMikesha Martinez, Charlene Ayers, Alex Brown, Donna Brown, Lydia Dominguez, Leslie Gordon, Chloe Lipton, Andy Martinez, Herbert M. Meyer, Service Employees International Union California State Council, Service Employees International Union Local 521, Service Employees International Union United Health Care Workers West, Service Employees International Union United Long-Term Care Workers, Willie Beatrice Sheppard. (Leyton, Stacey) (Filed on 6/4/2009) Modified on 6/5/2009 (cp, COURT STAFF). (Entered: 06/04/2009)

June 4, 2009

June 4, 2009

PACER
10

Declaration of Brenda Blannon filed byMikesha Martinez, Charlene Ayers, Alex Brown, Donna Brown, Lydia Dominguez, Leslie Gordon, Chloe Lipton, Andy Martinez, Herbert M. Meyer, Service Employees International Union California State Council, Service Employees International Union Local 521, Service Employees International Union United Health Care Workers West, Service Employees International Union United Long-Term Care Workers, Willie Beatrice Sheppard. (Leyton, Stacey) (Filed on 6/4/2009) Modified on 6/5/2009 (cp, COURT STAFF). (Entered: 06/04/2009)

June 4, 2009

June 4, 2009

PACER
11

Declaration of Donna Brown filed byMikesha Martinez, Charlene Ayers, Alex Brown, Donna Brown, Lydia Dominguez, Leslie Gordon, Chloe Lipton, Andy Martinez, Herbert M. Meyer, Service Employees International Union California State Council, Service Employees International Union Local 521, Service Employees International Union United Health Care Workers West, Service Employees International Union United Long-Term Care Workers, Willie Beatrice Sheppard. (Leyton, Stacey) (Filed on 6/4/2009) Modified on 6/5/2009 (cp, COURT STAFF). (Entered: 06/04/2009)

June 4, 2009

June 4, 2009

PACER
12

Declaration of Hui Chuen Chen filed byMikesha Martinez, Charlene Ayers, Alex Brown, Donna Brown, Lydia Dominguez, Leslie Gordon, Chloe Lipton, Andy Martinez, Herbert M. Meyer, Service Employees International Union California State Council, Service Employees International Union Local 521, Service Employees International Union United Health Care Workers West, Service Employees International Union United Long-Term Care Workers, Willie Beatrice Sheppard. (Related document(s) 5 ) (Leyton, Stacey) (Filed on 6/4/2009) Modified on 6/5/2009 (cp, COURT STAFF). (Entered: 06/04/2009)

June 4, 2009

June 4, 2009

PACER
13

Declaration of Lisa Brown filed byMikesha Martinez, Charlene Ayers, Alex Brown, Donna Brown, Lydia Dominguez, Leslie Gordon, Chloe Lipton, Andy Martinez, Herbert M. Meyer, Service Employees International Union California State Council, Service Employees International Union Local 521, Service Employees International Union United Health Care Workers West, Service Employees International Union United Long-Term Care Workers, Willie Beatrice Sheppard. (Leyton, Stacey) (Filed on 6/4/2009) Modified on 6/5/2009 (cp, COURT STAFF). (Entered: 06/04/2009)

June 4, 2009

June 4, 2009

PACER
14

Declaration of Brittany Calhoun filed byMikesha Martinez, Charlene Ayers, Alex Brown, Donna Brown, Lydia Dominguez, Leslie Gordon, Chloe Lipton, Andy Martinez, Herbert M. Meyer, Service Employees International Union California State Council, Service Employees International Union Local 521, Service Employees International Union United Health Care Workers West, Service Employees International Union United Long-Term Care Workers, Willie Beatrice Sheppard (Leyton, Stacey) (Filed on 6/4/2009) Modified on 6/5/2009 (cp, COURT STAFF). (Entered: 06/04/2009)

June 4, 2009

June 4, 2009

PACER
15

Declaration of Ebe Cerqua filed byMikesha Martinez, Charlene Ayers, Alex Brown, Donna Brown, Lydia Dominguez, Leslie Gordon, Chloe Lipton, Andy Martinez, Herbert M. Meyer, Service Employees International Union California State Council, Service Employees International Union Local 521, Service Employees International Union United Health Care Workers West, Service Employees International Union United Long-Term Care Workers, Willie Beatrice Sheppard (Leyton, Stacey) (Filed on 6/4/2009) Modified on 6/5/2009 (cp, COURT STAFF). (Entered: 06/04/2009)

June 4, 2009

June 4, 2009

PACER
16

Declaration of LYDIA DOMINGUEZ filed byMikesha Martinez, Charlene Ayers, Alex Brown, Donna Brown, Lydia Dominguez, Leslie Gordon, Chloe Lipton, Andy Martinez, Herbert M. Meyer, Service Employees International Union California State Council, Service Employees International Union Local 521, Service Employees International Union United Health Care Workers West, Service Employees International Union United Long-Term Care Workers, Willie Beatrice Sheppard. (Leyton, Stacey) (Filed on 6/4/2009) Modified on 6/5/2009 (cp, COURT STAFF). (Entered: 06/04/2009)

June 4, 2009

June 4, 2009

PACER
17

Declaration of PENNY DURHAM filed byMikesha Martinez, Charlene Ayers, Alex Brown, Donna Brown, Lydia Dominguez, Leslie Gordon, Chloe Lipton, Andy Martinez, Herbert M. Meyer, Service Employees International Union California State Council, Service Employees International Union Local 521, Service Employees International Union United Health Care Workers West, Service Employees International Union United Long-Term Care Workers, Willie Beatrice Sheppard. (Leyton, Stacey) (Filed on 6/4/2009) Modified on 6/5/2009 (cp, COURT STAFF). (Entered: 06/04/2009)

June 4, 2009

June 4, 2009

PACER
18

Declaration of MARIA LUISA FIGUEROA filed byMikesha Martinez, Charlene Ayers, Alex Brown, Donna Brown, Lydia Dominguez, Leslie Gordon, Chloe Lipton, Andy Martinez, Herbert M. Meyer, Service Employees International Union California State Council, Service Employees International Union Local 521, Service Employees International Union United Health Care Workers West, Service Employees International Union United Long-Term Care Workers, Willie Beatrice Sheppard. (Leyton, Stacey) (Filed on 6/4/2009) Modified on 6/5/2009 (cp, COURT STAFF). (Entered: 06/04/2009)

June 4, 2009

June 4, 2009

PACER
19

Declaration of CAROL GOLUBOCK filed byMikesha Martinez, Charlene Ayers, Alex Brown, Donna Brown, Lydia Dominguez, Leslie Gordon, Chloe Lipton, Andy Martinez, Herbert M. Meyer, Service Employees International Union California State Council, Service Employees International Union Local 521, Service Employees International Union United Health Care Workers West, Service Employees International Union United Long-Term Care Workers, Willie Beatrice Sheppard. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E) (Leyton, Stacey) (Filed on 6/4/2009) Modified on 6/5/2009 (cp, COURT STAFF). (Entered: 06/04/2009)

1 Exhibit A

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2 Exhibit B

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3 Exhibit C

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4 Exhibit D

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5 Exhibit E

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June 4, 2009

June 4, 2009

PACER
20

Declaration of Leslie Gordon filed byMikesha Martinez, Charlene Ayers, Alex Brown, Donna Brown, Lydia Dominguez, Leslie Gordon, Chloe Lipton, Andy Martinez, Herbert M. Meyer, Service Employees International Union California State Council, Service Employees International Union Local 521, Service Employees International Union United Health Care Workers West, Service Employees International Union United Long-Term Care Workers, Willie Beatrice Sheppard. (Leyton, Stacey) (Filed on 6/4/2009) Modified on 6/5/2009 (cp, COURT STAFF). (Entered: 06/04/2009)

June 4, 2009

June 4, 2009

PACER
21

Declaration of Sara Hamry filed byMikesha Martinez, Charlene Ayers, Alex Brown, Donna Brown, Lydia Dominguez, Leslie Gordon, Chloe Lipton, Andy Martinez, Herbert M. Meyer, Service Employees International Union California State Council, Service Employees International Union Local 521, Service Employees International Union United Health Care Workers West, Service Employees International Union United Long-Term Care Workers, Willie Beatrice Sheppard. ((Leyton, Stacey) (Filed on 6/4/2009) Modified on 6/5/2009 (cp, COURT STAFF). (Entered: 06/04/2009)

June 4, 2009

June 4, 2009

PACER
22

Declaration of CANDACE HOWES filed byMikesha Martinez, Charlene Ayers, Alex Brown, Donna Brown, Lydia Dominguez, Leslie Gordon, Chloe Lipton, Andy Martinez, Herbert M. Meyer, Service Employees International Union California State Council, Service Employees International Union Local 521, Service Employees International Union United Health Care Workers West, Service Employees International Union United Long-Term Care Workers, Willie Beatrice Sheppard. (Attachments: # 1 Exhibit A, # 2 Exhibit B) (Leyton, Stacey) (Filed on 6/4/2009) Modified on 6/5/2009 (cp, COURT STAFF). (Entered: 06/04/2009)

1 Exhibit A

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2 Exhibit B

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June 4, 2009

June 4, 2009

PACER
23

Declaration of ANA HUAMANI filed byMikesha Martinez, Charlene Ayers, Alex Brown, Donna Brown, Lydia Dominguez, Leslie Gordon, Chloe Lipton, Andy Martinez, Herbert M. Meyer, Service Employees International Union California State Council, Service Employees International Union Local 521, Service Employees International Union United Health Care Workers West, Service Employees International Union United Long-Term Care Workers, Willie Beatrice Sheppard (Leyton, Stacey) (Filed on 6/4/2009) Modified on 6/5/2009 (cp, COURT STAFF). (Entered: 06/04/2009)

June 4, 2009

June 4, 2009

PACER
24

Declaration of NATALIE HUNTER filed byMikesha Martinez, Charlene Ayers, Alex Brown, Donna Brown, Lydia Dominguez, Leslie Gordon, Chloe Lipton, Andy Martinez, Herbert M. Meyer, Service Employees International Union California State Council, Service Employees International Union Local 521, Service Employees International Union United Health Care Workers West, Service Employees International Union United Long-Term Care Workers, Willie Beatrice Sheppard. (Leyton, Stacey) (Filed on 6/4/2009) Modified on 6/5/2009 (cp, COURT STAFF). (Entered: 06/04/2009)

June 4, 2009

June 4, 2009

PACER
25

Declaration of DIONNE JIMENEZ filed byMikesha Martinez, Charlene Ayers, Alex Brown, Donna Brown, Lydia Dominguez, Leslie Gordon, Chloe Lipton, Andy Martinez, Herbert M. Meyer, Service Employees International Union California State Council, Service Employees International Union Local 521, Service Employees International Union United Health Care Workers West, Service Employees International Union United Long-Term Care Workers, Willie Beatrice Sheppard. (Attachments: # 1 Exhibit A1, # 2 Exhibit A2, # 3 Exhibit B, # 4 Exhibit C, # 5 Exhibit D1, # 6 Exhibit D2, # 7 Exhibit E1, # 8 Exhibit E2, # 9 Exhibit E3) (Leyton, Stacey) (Filed on 6/4/2009) Modified on 6/5/2009 (cp, COURT STAFF). (Entered: 06/04/2009)

1 Exhibit A1

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2 Exhibit A2

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3 Exhibit B

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4 Exhibit C

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5 Exhibit D1

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6 Exhibit D2

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7 Exhibit E1

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8 Exhibit E2

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9 Exhibit E3

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June 4, 2009

June 4, 2009

PACER
26

Declaration of PUI LAM filed byMikesha Martinez, Charlene Ayers, Alex Brown, Donna Brown, Lydia Dominguez, Leslie Gordon, Chloe Lipton, Andy Martinez, Herbert M. Meyer, Service Employees International Union California State Council, Service Employees International Union Local 521, Service Employees International Union United Health Care Workers West, Service Employees International Union United Long-Term Care Workers, Willie Beatrice Sheppard. (Leyton, Stacey) (Filed on 6/4/2009) Modified on 6/5/2009 (cp, COURT STAFF). (Entered: 06/04/2009)

June 4, 2009

June 4, 2009

PACER
27

Declaration of SUSAN L' AMIE filed byMikesha Martinez, Charlene Ayers, Alex Brown, Donna Brown, Lydia Dominguez, Leslie Gordon, Chloe Lipton, Andy Martinez, Herbert M. Meyer, Service Employees International Union California State Council, Service Employees International Union Local 521, Service Employees International Union United Health Care Workers West, Service Employees International Union United Long-Term Care Workers, Willie Beatrice Sheppard (Leyton, Stacey) (Filed on 6/4/2009) Modified on 6/5/2009 (cp, COURT STAFF). (Entered: 06/04/2009)

June 4, 2009

June 4, 2009

PACER
28

Declaration of MITCHELL LAPLANTE filed byMikesha Martinez, Charlene Ayers, Alex Brown, Donna Brown, Lydia Dominguez, Leslie Gordon, Chloe Lipton, Andy Martinez, Herbert M. Meyer, Service Employees International Union California State Council, Service Employees International Union Local 521, Service Employees International Union United Health Care Workers West, Service Employees International Union United Long-Term Care Workers, Willie Beatrice Sheppard. (Attachments: # 1 Exhibit A) (Leyton, Stacey) (Filed on 6/4/2009) Modified on 6/5/2009 (cp, COURT STAFF). (Entered: 06/04/2009)

1 Exhibit A

View on PACER

June 4, 2009

June 4, 2009

PACER
29

Declaration of JEFFREY LEE filed byMikesha Martinez, Charlene Ayers, Alex Brown, Donna Brown, Lydia Dominguez, Leslie Gordon, Chloe Lipton, Andy Martinez, Herbert M. Meyer, Service Employees International Union California State Council, Service Employees International Union Local 521, Service Employees International Union United Health Care Workers West, Service Employees International Union United Long-Term Care Workers, Willie Beatrice Sheppard. (Leyton, Stacey) (Filed on 6/4/2009) Modified on 6/5/2009 (cp, COURT STAFF). (Entered: 06/04/2009)

June 4, 2009

June 4, 2009

PACER
30

Declaration of YOUNG EUN LEE filed byMikesha Martinez, Charlene Ayers, Alex Brown, Donna Brown, Lydia Dominguez, Leslie Gordon, Chloe Lipton, Andy Martinez, Herbert M. Meyer, Service Employees International Union California State Council, Service Employees International Union Local 521, Service Employees International Union United Health Care Workers West, Service Employees International Union United Long-Term Care Workers, Willie Beatrice Sheppard. (Leyton, Stacey) (Filed on 6/4/2009) Modified on 6/5/2009 (cp, COURT STAFF). (Entered: 06/04/2009)

June 4, 2009

June 4, 2009

PACER
31

Declaration of EMILY MADANAT filed byMikesha Martinez, Charlene Ayers, Alex Brown, Donna Brown, Lydia Dominguez, Leslie Gordon, Chloe Lipton, Andy Martinez, Herbert M. Meyer, Service Employees International Union California State Council, Service Employees International Union Local 521, Service Employees International Union United Health Care Workers West, Service Employees International Union United Long-Term Care Workers, Willie Beatrice Sheppard. (Leyton, Stacey) (Filed on 6/4/2009) Modified on 6/5/2009 (cp, COURT STAFF). (Entered: 06/04/2009)

June 4, 2009

June 4, 2009

PACER
32

Declaration of ANDY MARTINEZ filed byMikesha Martinez, Charlene Ayers, Alex Brown, Donna Brown, Lydia Dominguez, Leslie Gordon, Chloe Lipton, Andy Martinez, Herbert M. Meyer, Service Employees International Union California State Council, Service Employees International Union Local 521, Service Employee International Union United Health Care Workers West, Service Employees International Union United Long-Term Care Workers, Willie Beatrice Sheppard (Leyton, Stacey) (Filed on 6/4/2009) Modified on 6/5/2009 (cp, COURT STAFF). (Entered: 06/04/2009)

June 4, 2009

June 4, 2009

PACER
33

Declaration of CARLOS MARTINEZ filed byMikesha Martinez, Charlene Ayers, Alex Brown, Donna Brown, Lydia Dominguez, Leslie Gordon, Chloe Lipton, Andy Martinez, Herbert M. Meyer, Service Employees International Union California State Council, Service Employees International Union Local 521, Service Employee International Union United Health Care Workers West, Service Employees International Union United Long-Term Care Workers, Willie Beatrice Sheppard. (Leyton, Stacey) (Filed on 6/4/2009) Modified on 6/5/2009 (cp, COURT STAFF). (Entered: 06/04/2009)

June 4, 2009

June 4, 2009

PACER
34

Declaration of SHAWNA MARZETTE filed byMikesha Martinez, Charlene Ayers, Alex Brown, Donna Brown, Lydia Dominguez, Leslie Gordon, Chloe Lipton, Andy Martinez, Herbert M. Meyer, Service Employees International Union California State Council, Service Employees International Union Local 521, Service Employee International Union United Health Care Workers West, Service Employees International Union United Long-Term Care Workers, Willie Beatrice Sheppard (Leyton, Stacey) (Filed on 6/4/2009) Modified on 6/5/2009 (cp, COURT STAFF). (Entered: 06/04/2009)

June 4, 2009

June 4, 2009

PACER
35

Declaration of HERBERT M. MEYER filed byMikesha Martinez, Charlene Ayers, Alex Brown, Donna Brown, Lydia Dominguez, Leslie Gordon, Chloe Lipton, Andy Martinez, Herbert M. Meyer, Service Employees International Union California State Council, Service Employees International Union Local 521, Service Employees International Union United Health Care Workers West, Service Employees International Union United Long-Term Care Workers, Willie Beatrice Sheppard (Leyton, Stacey) (Filed on 6/4/2009) Modified on 6/5/2009 (cp, COURT STAFF). (Entered: 06/04/2009)

June 4, 2009

June 4, 2009

PACER
36

Declaration of SUSANNAH MCDEVITT filed byMikesha Martinez, Charlene Ayers, Alex Brown, Donna Brown, Lydia Dominguez, Leslie Gordon, Chloe Lipton, Andy Martinez, Herbert M. Meyer, Service Employees International Union California State Council, Service Employees International Union Local 521, Service Employees International Union United Health Care Workers West, Service Employees International Union United Long-Term Care Workers, Willie Beatrice Sheppard. (Attachments: # 1 Exhibit A) (Leyton, Stacey) (Filed on 6/4/2009) Modified on 6/5/2009 (cp, COURT STAFF). (Entered: 06/04/2009)

1 Exhibit A

View on PACER

June 4, 2009

June 4, 2009

PACER
37

Declaration of HYUN NAM filed byMikesha Martinez, Charlene Ayers, Alex Brown, Donna Brown, Lydia Dominguez, Leslie Gordon, Chloe Lipton, Andy Martinez, Herbert M. Meyer, Service Employees International Union California State Council, Service Employees International Union Local 521, Service Employees International Union United Health Care Workers West, Service Employees International Union United Long-Term Care Workers, Willie Beatrice Sheppard. (Attachments: # 1 Exhibit A, # 2 Exhibit B)(Related document(s) 5 ) (Leyton, Stacey) (Filed on 6/4/2009) Modified on 6/5/2009 (cp, COURT STAFF). (Entered: 06/04/2009)

1 Exhibit A

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2 Exhibit B

View on PACER

June 4, 2009

June 4, 2009

PACER
38

Declaration of JACKIE PEPPARS filed byMikesha Martinez, Charlene Ayers, Alex Brown, Donna Brown, Lydia Dominguez, Leslie Gordon, Chloe Lipton, Andy Martinez, Herbert M. Meyer, Service Employees International Union California State Council, Service Employees International Union Local 521, Service Employees International Union United Health Care Workers West, Service Employees International Union United Long-Term Care Workers, Willie Beatrice Sheppard. (Leyton, Stacey) (Filed on 6/4/2009) Modified on 6/5/2009 (cp, COURT STAFF). (Entered: 06/04/2009)

June 4, 2009

June 4, 2009

PACER
39

Declaration of VIRGINIA RAE filed byMikesha Martinez, Charlene Ayers, Alex Brown, Donna Brown, Lydia Dominguez, Leslie Gordon, Chloe Lipton, Andy Martinez, Herbert M. Meyer, Service Employees International Union California State Council, Service Employees International Union Local 521, Service Employees International Union United Health Care Workers West, Service Employees International Union United Long-Term Care Workers, Willie Beatrice Sheppard. (Leyton, Stacey) (Filed on 6/4/2009) Modified on 6/5/2009 (cp, COURT STAFF). (Entered: 06/04/2009)

June 4, 2009

June 4, 2009

PACER
40

Declaration of TAMARA RASBERRY filed byMikesha Martinez, Charlene Ayers, Alex Brown, Donna Brown, Lydia Dominguez, Leslie Gordon, Chloe Lipton, Andy Martinez, Herbert M. Meyer, Service Employees International Union California State Council, Service Employees International Union Local 521, Service Employees International Union United Health Care Workers West, Service Employees International Union United Long-Term Care Workers, Willie Beatrice Sheppard. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E, # 6 Exhibit F, # 7 Exhibit G, # 8 Exhibit H) (Leyton, Stacey) (Filed on 6/4/2009) Modified on 6/5/2009 (cp, COURT STAFF). (Entered: 06/04/2009)

1 Exhibit A

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2 Exhibit B

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3 Exhibit C

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4 Exhibit D

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5 Exhibit E

View on PACER

6 Exhibit F

View on PACER

7 Exhibit G

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8 Exhibit H

View on PACER

June 4, 2009

June 4, 2009

PACER
41

Declaration of DIANA ROBINSON filed byMikesha Martinez, Charlene Ayers, Alex Brown, Donna Brown, Lydia Dominguez, Leslie Gordon, Chloe Lipton, Andy Martinez, Herbert M. Meyer, Service Employees International Union California State Council, Service Employees International Union Local 521, Service Employees International Union United Health Care Workers West, Service Employees International Union United Long-Term Care Workers, Willie Beatrice Sheppard. (Leyton, Stacey) (Filed on 6/4/2009) Modified on 6/5/2009 (cp, COURT STAFF). (Entered: 06/04/2009)

June 4, 2009

June 4, 2009

PACER
42

Declaration of SOCORRO ROMERO filed byMikesha Martinez, Charlene Ayers, Alex Brown, Donna Brown, Lydia Dominguez, Leslie Gordon, Chloe Lipton, Andy Martinez, Herbert M. Meyer, Service Employees International Union California State Council, Service Employees International Union Local 521, Service Employees International Union United Health Care Workers West, Service Employees International Union United Long-Term Care Workers, Willie Beatrice Sheppard. (Leyton, Stacey) (Filed on 6/4/2009) Modified on 6/5/2009 (cp, COURT STAFF). (Entered: 06/04/2009)

June 4, 2009

June 4, 2009

PACER
43

Declaration of DEBRA ROTH filed byMikesha Martinez, Charlene Ayers, Alex Brown, Donna Brown, Lydia Dominguez, Leslie Gordon, Chloe Lipton, Andy Martinez, Herbert M. Meyer, Service Employees International Union California State Council, Service Employees International Union Local 521, Service Employees International Union United Health Care Workers West, Service Employees International Union United Long-Term Care Workers, Willie Beatrice Sheppard. (Leyton, Stacey) (Filed on 6/4/2009) Modified on 6/5/2009 (cp, COURT STAFF). (Entered: 06/04/2009)

June 4, 2009

June 4, 2009

PACER
44

Declaration of ARMINDA SANCHEZ filed byMikesha Martinez, Charlene Ayers, Alex Brown, Donna Brown, Lydia Dominguez, Leslie Gordon, Chloe Lipton, Andy Martinez, Herbert M. Meyer, Service Employees International Union California State Council, Service Employees International Union Local 521, Service Employees International Union United Health Care Workers West, Service Employees International Union United Long-Term Care Workers, Willie Beatrice Sheppard. (Leyton, Stacey) (Filed on 6/4/2009) Modified on 6/5/2009 (cp, COURT STAFF). (Entered: 06/04/2009)

June 4, 2009

June 4, 2009

PACER
45

Declaration of JOHN F. SCHNELLE filed byMikesha Martinez, Charlene Ayers, Alex Brown, Donna Brown, Lydia Dominguez, Leslie Gordon, Chloe Lipton, Andy Martinez, Herbert M. Meyer, Service Employees International Union California State Council, Service Employees International Union Local 521, Service Employees International Union United Health Care Workers West, Service Employees International Union United Long-Term Care Workers, Willie Beatrice Sheppard. (Attachments: # 1 Exhibit A) (Leyton, Stacey) (Filed on 6/4/2009) Modified on 6/5/2009 (cp, COURT STAFF). (Entered: 06/04/2009)

1 Exhibit A

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June 4, 2009

June 4, 2009

PACER
46

Declaration of CHRISTINE SCHWARTZ filed byMikesha Martinez, Charlene Ayers, Alex Brown, Donna Brown, Lydia Dominguez, Leslie Gordon, Chloe Lipton, Andy Martinez, Herbert M. Meyer, Service Employees International Union California State Council, Service Employees International Union Local 521, Service Employees International Union United Health Care Workers West, Service Employees International Union United Long-Term Care Workers, Willie Beatrice Sheppard. (Leyton, Stacey) (Filed on 6/4/2009) Modified on 6/5/2009 (cp, COURT STAFF). (Entered: 06/04/2009)

June 4, 2009

June 4, 2009

PACER
47

Declaration of WILLIE BEATRICE SHEPPARD filed byMikesha Martinez, Charlene Ayers, Alex Brown, Donna Brown, Lydia Dominguez, Leslie Gordon, Chloe Lipton, Andy Martinez, Herbert M. Meyer, Service Employees International Union California State Council, Service Employees International Union Local 521, Service Employees International Union United Health Care Workers West, Service Employees International Union United Long-Term Care Workers, Willie Beatrice Sheppard. (Leyton, Stacey) (Filed on 6/4/2009) Modified on 6/5/2009 (cp, COURT STAFF). (Entered: 06/04/2009)

June 4, 2009

June 4, 2009

PACER
48

Declaration of PAMELA TIEDT filed byMikesha Martinez, Charlene Ayers, Alex Brown, Donna Brown, Lydia Dominguez, Leslie Gordon, Chloe Lipton, Andy Martinez, Herbert M. Meyer, Service Employees International Union California State Council, Service Employees International Union Local 521, Service Employees International Union United Health Care Workers West, Service Employees International Union United Long-Term Care Workers, Willie Beatrice Sheppard. (Leyton, Stacey) (Filed on 6/4/2009) Modified on 6/5/2009 (cp, COURT STAFF). (Entered: 06/04/2009)

June 4, 2009

June 4, 2009

PACER
49

Translator Certification of Curtis Draves filed byMikesha Martinez, Charlene Ayers, Alex Brown, Donna Brown, Lydia Dominguez, Leslie Gordon, Chloe Lipton, Andy Martinez, Herbert M. Meyer, Service Employees International Union California State Council, Service Employees International Union Local 521, Service Employees International Union United Health Care Workers West, Service Employees International Union United Long-Term Care Workers, Willie Beatrice Sheppard. (Leyton, Stacey) (Filed on 6/4/2009) Modified on 6/5/2009 (cp, COURT STAFF). (Entered: 06/04/2009)

June 4, 2009

June 4, 2009

PACER
50

Declaration of JUSZTINA TRAUM filed byMikesha Martinez, Charlene Ayers, Alex Brown, Donna Brown, Lydia Dominguez, Leslie Gordon, Chloe Lipton, Andy Martinez, Herbert M. Meyer, Service Employees International Union California State Council, Service Employees International Union Local 521, Service Employees International Union United Health Care Workers West, Service Employees International Union United Long-Term Care Workers, Willie Beatrice Sheppard. (Leyton, Stacey) (Filed on 6/4/2009) Modified on 6/5/2009 (cp, COURT STAFF). (Entered: 06/04/2009)

June 4, 2009

June 4, 2009

PACER
51

Declaration of JULIE WEISSMAN-STEINBAUGH filed byMikesha Martinez, Charlene Ayers, Alex Brown, Donna Brown, Lydia Dominguez, Leslie Gordon, Chloe Lipton, Andy Martinez, Herbert M. Meyer, Service Employees International Union California State Council, Service Employees International Union Local 521, Service Employees International Union United Health Care Workers West, Service Employees International Union United Long-Term Care Workers, Willie Beatrice Sheppard. (Leyton, Stacey) (Filed on 6/4/2009) Modified on 6/5/2009 (cp, COURT STAFF). (Entered: 06/04/2009)

June 4, 2009

June 4, 2009

PACER
52

Declaration of SADIE WILSON filed byMikesha Martinez, Charlene Ayers, Alex Brown, Donna Brown, Lydia Dominguez, Leslie Gordon, Chloe Lipton, Andy Martinez, Herbert M. Meyer, Service Employees International Union California State Council, Service Employees International Union Local 521, Service Employees International Union United Health Care Workers West, Service Employees International Union United Long-Term Care Workers, Willie Beatrice Sheppard. (Leyton, Stacey) (Filed on 6/4/2009) Modified on 6/5/2009 (cp, COURT STAFF). (Entered: 06/04/2009)

June 4, 2009

June 4, 2009

PACER
53

Request for Judicial Notice re 5 MOTION for Preliminary Injunction filed byMikesha Martinez, Charlene Ayers, Alex Brown, Donna Brown, Lydia Dominguez, Leslie Gordon, Chloe Lipton, Andy Martinez, Herbert M. Meyer, Service Employees International Union California State Council, Service Employees International Union Local 521, Service Employees International Union United Health Care Workers West, Service Employees International Union United Long-Term Care Workers, Willie Beatrice Sheppard. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E, # 6 Exhibit F, # 7 Exhibit G, # 8 Exhibit H, # 9 Exhibit I, # 10 Exhibit J, # 11 Exhibit K, # 12 Exhibit L, # 13 Exhibit M, # 14 Exhibit N, # 15 Exhibit O, # 16 Exhibit P, # 17 Exhibit Q, # 18 Exhibit R, # 19 Exhibit S, # 20 Exhibit T, # 21 Exhibit U, # 22 Exhibit V, # 23 Exhibit W, # 24 Exhibit X)(Related document(s) 5 ) (Leyton, Stacey) (Filed on 6/4/2009) Modified on 6/5/2009 (cp, COURT STAFF). (Entered: 06/04/2009)

1 Exhibit A

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2 Exhibit B

View on PACER

3 Exhibit C

View on PACER

4 Exhibit D

View on PACER

5 Exhibit E

View on PACER

6 Exhibit F

View on PACER

7 Exhibit G

View on PACER

8 Exhibit H

View on PACER

9 Exhibit I

View on PACER

10 Exhibit J

View on PACER

11 Exhibit K

View on PACER

12 Exhibit L

View on PACER

13 Exhibit M

View on PACER

14 Exhibit N

View on PACER

15 Exhibit O

View on PACER

16 Exhibit P

View on PACER

17 Exhibit Q

View on PACER

18 Exhibit R

View on PACER

19 Exhibit S

View on PACER

20 Exhibit T

View on PACER

21 Exhibit U

View on PACER

22 Exhibit V

View on PACER

23 Exhibit W

View on PACER

24 Exhibit X

View on PACER

June 4, 2009

June 4, 2009

PACER
54

Proposed Order re 5 MOTION for Preliminary Injunction by Mikesha Martinez, Charlene Ayers, Alex Brown, Donna Brown, Lydia Dominguez, Leslie Gordon, Chloe Lipton, Andy Martinez, Herbert M. Meyer, Service Employees International Union California State Council, Service Employees International Union Local 521, Service Employees International Union United Health Care Workers West, Service Employees International Union United Long-Term Care Workers, Willie Beatrice Sheppard. (Leyton, Stacey) (Filed on 6/4/2009) Modified on 6/5/2009 (cp, COURT STAFF). (Entered: 06/04/2009)

June 4, 2009

June 4, 2009

PACER
55

EX PARTE MOTION TO SHORTEN TIME FOR MOTION FOR A PRELIMINARY INJUNCTION SO THAT RELIEF CAN BE GRANTED BEFORE JULY 1, 2009, OR, IN THE ALTERNATIVE, FOR A TEMPORARY RESTRAINING ORDER PENDING A RULING ON PRELIMINARY INJUNCTION filed by Mikesha Martinez, Charlene Ayers, Alex Brown, Donna Brown, Lydia Dominguez, Leslie Gordon, Chloe Lipton, Andy Martinez, Herbert M. Meyer, Service Employees International Union California State Council, Service Employees International Union Local 521, Service Employees International Union United Health Care Workers West, Service Employees International Union United Long-Term Care Workers, Willie Beatrice Sheppard. (Leyton, Stacey) (Filed on 6/4/2009) Modified on 6/5/2009 (cp, COURT STAFF). (Entered: 06/04/2009)

June 4, 2009

June 4, 2009

PACER
56

Declaration of Stacey Leyton in Support of 55 PLAINTIFFS EX PARTE MOTION TO SHORTEN TIME FOR MOTION FOR A PRELIMINARY INJUNCTION SO THAT RELIEF CAN BE GRANTED BEFORE JULY 1, 2009, OR, IN THE ALTERNATIVE, FOR A TEMPORARY RESTRAINING ORDER PENDING A RULING ON PRELIMINARY I filed byMikesha Martinez, Charlene Ayers, Alex Brown, Donna Brown, Lydia Dominguez, Leslie Gordon, Chloe Lipton, Andy Martinez, Herbert M. Meyer, Service Employees International Union California State Council, Service Employees International Union Local 521, Service Employees International Union United Health Care Workers West, Service Employees International Union United Long-Term Care Workers, Willie Beatrice Sheppard. (Related document(s) 55 ) (Leyton, Stacey) (Filed on 6/4/2009) Modified on 6/5/2009 (cp, COURT STAFF). (Entered: 06/04/2009)

June 4, 2009

June 4, 2009

PACER
57

Proposed Order re 55 EX PARTE MOTION TO SHORTEN TIME FOR MOTION FOR A PRELIMINARY INJUNCTION SO THAT RELIEF CAN BE GRANTED BEFORE JULY 1, 2009, OR, IN THE ALTERNATIVE, FOR A TEMPORARY RESTRAINING ORDER PENDING A RULING ON PRELIMINARY I by Mikesha Martinez, Charlene Ayers, Alex Brown, Donna Brown, Lydia Dominguez, Leslie Gordon, Chloe Lipton, Andy Martinez, Herbert M. Meyer, Service Employees International Union California State Council, Service Employees International Union Local 521, Service Employees International Union United Health Care Workers West, Service Employees International Union United Long-Term Care Workers, Willie Beatrice Sheppard. (Leyton, Stacey) (Filed on 6/4/2009) Modified on 6/5/2009 (cp, COURT STAFF). (Entered: 06/04/2009)

June 4, 2009

June 4, 2009

PACER
58

CERTIFICATE OF SERVICE by Mikesha Martinez (Leyton, Stacey) (Filed on 6/5/2009) (Entered: 06/05/2009)

June 5, 2009

June 5, 2009

PACER
59

ORDER by Judge Claudia Wilken granting 55 Motion to Shorten Time (cwlc3, COURT STAFF) (Filed on 6/5/2009) (Entered: 06/05/2009)

June 5, 2009

June 5, 2009

PACER

Set/Reset Hearings: Motion Hearing set for 6/25/2009 02:00 PM. (scc, COURT STAFF) (Filed on 6/5/2009)

June 5, 2009

June 5, 2009

PACER
60

EXHIBIT A (CD) re 40 Declaration in Support of Tamara Rasberry filed byCharlene Ayers, Alex Brown, Donna Brown, Lydia Dominguez, Leslie Gordon, Chloe Lipton, Andy Martinez, Mikesha Martinez, Herbert M. Meyer, Service Employees International Union California State Council, Service Employees International Union Local 521, Service Employees International Union United Health Care Workers West, Service Employees International Union United Long-Term Care Workers, Willie Beatrice Sheppard. (Related document(s) 40 ) (cp, COURT STAFF) (Filed on 6/5/2009) (Entered: 06/08/2009)

June 5, 2009

June 5, 2009

PACER
61

Ex Parte Application re 5 MOTION for Preliminary Injunction filed by David Maxwell-Jolly, Arnold Schwarzenegger, John A. Wagner. (Attachments: # 1 Proposed Order)(Carson, Susan) (Filed on 6/8/2009) (Entered: 06/08/2009)

1 Proposed Order

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June 8, 2009

June 8, 2009

PACER
62

ORDER by Judge CLAUDIA WILKEN granting 61 Ex Parte Application to enlarge time to oppose moton for preliminary injunction (scc, COURT STAFF) (Filed on 6/9/2009) (Entered: 06/09/2009)

June 9, 2009

June 9, 2009

PACER
63

Ex Parte Application to Enlarge Time to Oppose Plaintiffs' Motion for Preliminary Injunction filed by Fresno County, Fresno County In-Home Supportive Services Public Authority. (Attachments: # 1 Declaration of Michael G. Woods in Support of Ex Parte Application to Enlarge Application to Oppose Plaintiffs' Motion for Preliminary Injunction)(Woods, Michael) (Filed on 6/10/2009) (Entered: 06/10/2009)

1 Declaration of Michael G. Woods in Support of Ex Parte Application to Enlarge A

View on PACER

June 10, 2009

June 10, 2009

PACER
64

SUMMONS Returned Executed by Leslie Gordon, Lydia Dominguez, Service Employees International Union Local 521, Herbert M. Meyer, Mikesha Martinez, Alex Brown, Willie Beatrice Sheppard, Service Employees International Union California State Council, Andy Martinez, Chloe Lipton, Charlene Ayers, Service Employees International Union United Health Care Workers West, Donna Brown, Service Employees International Union United Long-Term Care Workers. John Chiang served on 5/27/2009, answer due 6/16/2009; Fresno County served on 5/27/2009, answer due 6/16/2009; Fresno County In-Home Supportive Services Public Authority served on 5/28/2009, answer due 6/17/2009; David Maxwell-Jolly served on 5/28/2009, answer due 6/17/2009; Arnold Schwarzenegger served on 5/28/2009, answer due 6/17/2009; John A. Wagner served on 5/28/2009, answer due 6/17/2009. (Leyton, Stacey) (Filed on 6/10/2009) (Entered: 06/10/2009)

June 10, 2009

June 10, 2009

PACER
65

Statement of Non-Opposition; Correction of Inaccurate Statements by Defendants re 63 Ex Parte Application to Enlarge Time to Oppose Plaintiffs' Motion for Preliminary Injunction, filed by Charlene Ayers, Alex Brown, Donna Brown, Lydia Dominguez, Leslie Gordon, Chloe Lipton, Andy Martinez, Mikesha Martinez, Herbert M. Meyer, Service Employees International Union California State Council, Service Employees International Union Local 521, Service Employees International Union United Health Care Workers West, Service Employees International Union United Long-Term Care Workers, Willie Beatrice Sheppard. (Attachments: # 1 Affidavit Declaration of Stacey M. Leyton in Support of Non-Opposition; Correction of Inaccurate Statements by Defendants)(Related document(s) 63 ) (Leyton, Stacey) (Filed on 6/11/2009) Modified on 6/12/2009 (jlm, COURT STAFF). Modified on 6/12/2009 (jlm, COURT STAFF). (Entered: 06/11/2009)

1 Affidavit Declaration of Stacey M. Leyton in Support of Non-Opposition; Correcti

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June 11, 2009

June 11, 2009

PACER
66

CERTIFICATE OF SERVICE as to Fresno In-Home Supportive Services re 43 Declaration in Support, 52 Declaration in Support, 44 Declaration in Support, 38 Declaration in Support, 24 Declaration in Support, 20 Declaration in Support, 34 Declaration in Support, 13 Declaration in Support, 9 Declaration in Support, 28 Declaration in Support, 5 Motion for Preliminary Injunction, 27 Declaration in Support, 58 Certificate of Service, 22 Declaration in Support, 57 Proposed Order, 25 Declaration in Support, 31 Declaration in Support, 26 Declaration in Support, 45 Declaration in Support, 18 Declaration in Support, 30 Declaration in Support, 42 Declaration in Support, 11 Declaration in Support, 19 Declaration in Support, 51 Declaration in Support, 17 Declaration in Support, 47 Declaration in Support, 23 Declaration in Support, 16 Declaration in Support, 39 Declaration in Support, 7 Declaration in Support, 6 Declaration in Support, 33 Declaration in Support, 50 Declaration in Support, 49 Declaration in Support, 53 Request for Judicial Notice, 8 Declaration in Support, 12 Declaration in Support, 37 Declaration in Support, 36 Declaration in Support, 56 Declaration in Support, 40 Declaration in Support, 21 Declaration in Support, 46 Declaration in Support, 41 Declaration in Support, 14 Declaration in Support, 54 Proposed Order, 10 Declaration in Support, 35 Declaration in Support, 32 Declaration in Support, 29 Declaration in Support, 15 Declaration in Support, filed by Charlene Ayers, Alex Brown, Donna Brown, John Chiang, Lydia Dominguez, Leslie Gordon, Chloe Lipton, Andy Martinez, Mikesha Martinez, Herbert M. Meyer, Service Employees International Union California State Council, Service Employees International Union Local 521, Service Employees International Union United Health Care Workers West, Service Employees International Union United Long-Term Care Workers, Willie Beatrice Sheppard (Leyton, Stacey) (Filed on 6/11/2009) Modified on 6/12/2009 (jlm, COURT STAFF). Modified on 6/12/2009 (jlm, COURT STAFF). Modified on 6/12/2009 (jlm, COURT STAFF). (Entered: 06/11/2009)

June 11, 2009

June 11, 2009

PACER
67

CERTIFICATE OF SERVICE as to Fresno County re 43 Declaration in Support, 52 Declaration in Support, 44 Declaration in Support, 38 Declaration in Support, 24 Declaration in Support, 20 Declaration in Support, 34 Declaration in Support, 13 Declaration in Support, 9 Declaration in Support, 28 Declaration in Support, 5 Motion for Preliminary Injunction, 27 Declaration in Support, 58 Certificate of Service, 22 Declaration in Support, 57 Proposed Order, 25 Declaration in Support, 31 Declaration in Support, 26 Declaration in Support, 45 Declaration in Support, 18 Declaration in Support, 30 Declaration in Support, 42 Declaration in Support, 11 Declaration in Support, 19 Declaration in Support, 51 Declaration in Support, 17 Declaration in Support, 47 Declaration in Support, 23 Declaration in Support, 16 Declaration in Support, 39 Declaration in Support, 7 Declaration in Support, 6 Declaration in Support, 33 Declaration in Support, 50 Declaration in Support, 49 Declaration in Support, 53 Request for Judicial Notice, 8 Declaration in Support, 12 Declaration in Support, 37 Declaration in Support, 36 Declaration in Support, 56 Declaration in Support, 40 Declaration in Support, 21 Declaration in Support, 46 Declaration in Support, 41 Declaration in Support, 14 Declaration in Support, 54 Proposed Order, 10 Declaration in Support, 35 Declaration in Support, 32 Declaration in Support, 29 Declaration in Support, 15 Declaration in Support, filed by Charlene Ayers, Alex Brown, Donna Brown, John Chiang, Lydia Dominguez, Leslie Gordon, Chloe Lipton, Andy Martinez, Mikesha Martinez, Herbert M. Meyer, Service Employees International Union California State Council, Service Employees International Union Local 521, Service Employees International Union United Health Care Workers West, Service Employees International Union United Long-Term Care Workers, Willie Beatrice Sheppard Fresno County (Leyton, Stacey) (Filed on 6/11/2009) Modified on 6/12/2009 (jlm, COURT STAFF). Modified on 6/12/2009 (jlm, COURT STAFF). (Entered: 06/11/2009)

June 11, 2009

June 11, 2009

PACER
68

CERTIFICATE OF SERVICE as to Fresno County In-Home Supportive Services re 59 Order on Motion to Shorten Time filed by Charlene Ayers, Alex Brown, Donna Brown, Lydia Dominguez, Leslie Gordon, Chloe Lipton, Andy Martinez, Mikesha Martinez, Herbert M. Meyer, Service Employees International Union California State Council, Service Employees International Union Local 521, Service Employees International Union United Health Care Workers West, Service Employees International Union United Long-Term Care Workers, Willie Beatrice Sheppard (Leyton, Stacey) (Filed on 6/11/2009) Modified on 6/12/2009 (jlm, COURT STAFF). (Entered: 06/11/2009)

June 11, 2009

June 11, 2009

PACER
69

CERTIFICATE OF SERVICE as to Fresno County re 59 Order on Motion to Shorten Time filed by Charlene Ayers, Alex Brown, Donna Brown, Lydia Dominguez, Leslie Gordon, Chloe Lipton, Andy Martinez, Mikesha Martinez, Herbert M. Meyer, Service Employees International Union California State Council, Service Employees International Union Local 521, Service Employees International Union United Health Care Workers West, Service Employees International Union United Long-Term Care Workers, Willie Beatrice Sheppard (Leyton, Stacey) (Filed on 6/11/2009) Modified on 6/12/2009 (jlm, COURT STAFF). (Entered: 06/11/2009)

June 11, 2009

June 11, 2009

PACER
70

CERTIFICATE OF SERVICE as to Fresno County In-Home Supportive Services re 60 Exhibit A to the Declaration of Tamara Rasberry (CD) filed by Charlene Ayers, Alex Brown, Donna Brown, Lydia Dominguez, Leslie Gordon, Chloe Lipton, Andy Martinez, Mikesha Martinez, Herbert M. Meyer, Service Employees International Union California State Council, Service Employees International Union Local 521, Service Employees International Union United Health Care Workers West, Service Employees International Union United Long-Term Care Workers, Willie Beatrice Sheppard (Leyton, Stacey) (Filed on 6/11/2009) Modified on 6/12/2009 (jlm, COURT STAFF). Modified on 6/12/2009 (jlm, COURT STAFF). (Entered: 06/11/2009)

June 11, 2009

June 11, 2009

PACER
71

CERTIFICATE OF SERVICE as to Fresno County re 60 Exhibit A to the Declaration of Tamara Rasberry (CD) filed by Charlene Ayers, Alex Brown, Donna Brown, Lydia Dominguez, Leslie Gordon, Chloe Lipton, Andy Martinez, Mikesha Martinez, Herbert M. Meyer, Service Employees International Union California State Council, Service Employees International Union Local 521, Service Employees International Union United Health Care Workers West, Service Employees International Union United Long-Term Care Workers, Willie Beatrice Sheppard (Leyton, Stacey) (Filed on 6/11/2009) Modified on 6/12/2009 (jlm, COURT STAFF). (Entered: 06/11/2009)

June 11, 2009

June 11, 2009

PACER
72

Memorandum in Opposition re 5 Motion for Preliminary Injunction filed by Fresno County, Fresno County In-Home Supportive Services Public Authority. (Woods, Michael) (Filed on 6/11/2009) Modified on 6/12/2009 (jlm, COURT STAFF). (Entered: 06/11/2009)

June 11, 2009

June 11, 2009

PACER
73

OBJECTIONS to 45 Declaration of John F. Schnelle in Support, filed by Fresno County, Fresno County In-Home Supportive Services Public Authority. (Woods, Michael) (Filed on 6/11/2009) Modified on 6/12/2009 (jlm, COURT STAFF). (Entered: 06/11/2009)

June 11, 2009

June 11, 2009

PACER
74

OBJECTIONS to 50 Declaration of Jusztina Traum in Support, filed by Fresno County, Fresno County In-Home Supportive Services Public Authority. (Woods, Michael) (Filed on 6/11/2009) Modified on 6/12/2009 (jlm, COURT STAFF). Modified on 6/12/2009 (jlm, COURT STAFF). (Entered: 06/11/2009)

June 11, 2009

June 11, 2009

PACER
75

OBJECTIONS to 22 Declaration of Candace Howes in Support, filed by Fresno County, Fresno County In-Home Supportive Services Public Authority. (Woods, Michael) (Filed on 6/11/2009) Modified on 6/12/2009 (jlm, COURT STAFF). (Entered: 06/11/2009)

June 11, 2009

June 11, 2009

PACER
76

OBJECTIONS to 33 Declaration of Carlos Martinez in Support, filed by Fresno County, Fresno County In-Home Supportive Services Public Authority. (Woods, Michael) (Filed on 6/11/2009) Modified on 6/12/2009 (jlm, COURT STAFF). (Entered: 06/11/2009)

June 11, 2009

June 11, 2009

PACER
77

OBJECTIONS to 38 Declaration of Jackie Peppars in Support, by Fresno County, Fresno County In-Home Supportive Services Public Authority. (Woods, Michael) (Filed on 6/11/2009) Modified on 6/12/2009 (jlm, COURT STAFF). (Entered: 06/11/2009)

June 11, 2009

June 11, 2009

PACER
78

OBJECTIONS to 28 Declaration of Mitchell Laplante in Support, filed by Fresno County, Fresno County In-Home Supportive Services Public Authority. (Woods, Michael) (Filed on 6/11/2009) Modified on 6/12/2009 (jlm, COURT STAFF). (Entered: 06/11/2009)

June 11, 2009

June 11, 2009

PACER
79

OBJECTIONS to 25 Declaration of Dionne Jimenez in Support, filed by Fresno County, Fresno County In-Home Supportive Services Public Authority. (Woods, Michael) (Filed on 6/11/2009) Modified on 6/12/2009 (jlm, COURT STAFF). (Entered: 06/11/2009)

June 11, 2009

June 11, 2009

PACER
80

OBJECTIONS to 36 Declaration of Susannah McDevitt in Support, filed by Fresno County, Fresno County In-Home Supportive Services Public Authority. (Woods, Michael) (Filed on 6/11/2009) Modified on 6/12/2009 (jlm, COURT STAFF). (Entered: 06/11/2009)

June 11, 2009

June 11, 2009

PACER
81

OBJECTIONS to 37 Declaration of Hyun Nam in Support, filed by Fresno County, Fresno County In-Home Supportive Services Public Authority. (Woods, Michael) (Filed on 6/11/2009) Modified on 6/12/2009 (jlm, COURT STAFF). (Entered: 06/11/2009)

June 11, 2009

June 11, 2009

PACER
82

OBJECTIONS to 43 Declaration of Deborah Roth in Support, filed by Fresno County, Fresno County In-Home Supportive Services Public Authority. (Woods, Michael) (Filed on 6/11/2009) Modified on 6/12/2009 (jlm, COURT STAFF). (Entered: 06/11/2009)

June 11, 2009

June 11, 2009

PACER
83

OBJECTIONS to 40 Declaration of Tamara Rasberry in Support, filed by Fresno County, Fresno County In-Home Supportive Services Public Authority. (Woods, Michael) (Filed on 6/11/2009) Modified on 6/12/2009 (jlm, COURT STAFF). (Entered: 06/11/2009)

June 11, 2009

June 11, 2009

PACER
84

OBJECTIONS to 6 Declaration of David F. Altman in Support, filed by Fresno County, Fresno County In-Home Supportive Services Public Authority. (Woods, Michael) (Filed on 6/11/2009) Modified on 6/12/2009 (jlm, COURT STAFF). (Entered: 06/11/2009)

June 11, 2009

June 11, 2009

PACER
85

OBJECTIONS to 32 Declaration of Andy Martinez in Support, filed by Fresno County, Fresno County In-Home Supportive Services Public Authority. (Woods, Michael) (Filed on 6/11/2009) Modified on 6/12/2009 (jlm, COURT STAFF). (Entered: 06/11/2009)

June 11, 2009

June 11, 2009

PACER
86

OBJECTIONS to 13 Declaration of Lisa Brown in Support, filed by Fresno County, Fresno County In-Home Supportive Services Public Authority. (Woods, Michael) (Filed on 6/11/2009) Modified on 6/12/2009 (jlm, COURT STAFF). (Entered: 06/11/2009)

June 11, 2009

June 11, 2009

PACER
87

OBJECTIONS to 7 Declaration of Teresa Armas, Plaintiffs and Individuals Outside the County of Fresno in Support, filed by Fresno County, Fresno County In-Home Supportive Services Public Authority. (Woods, Michael) (Filed on 6/11/2009) Modified on 6/12/2009 (jlm, COURT STAFF). Modified on 6/12/2009 (jlm, COURT STAFF). (Entered: 06/11/2009)

June 11, 2009

June 11, 2009

PACER
88

Request for Judicial Notice re 72 Memorandum in Opposition filed by Fresno County, Fresno County In-Home Supportive Services Public Authority. (Related document(s) 72 ) (Woods, Michael) (Filed on 6/11/2009) Modified on 6/12/2009 (jlm, COURT STAFF). (Entered: 06/11/2009)

June 11, 2009

June 11, 2009

PACER
89

Declaration of Catherine E. Basham in Support of 72 Memorandum in Opposition filed by Fresno County, Fresno County In-Home Supportive Services Public Authority. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E, # 6 Exhibit F, # 7 Exhibit G, # 8 Exhibit H)(Related document(s) 72 ) (Woods, Michael) (Filed on 6/11/2009) Modified on 6/12/2009 (jlm, COURT STAFF). (Entered: 06/11/2009)

1 Exhibit A

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2 Exhibit B

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3 Exhibit C

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4 Exhibit D

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5 Exhibit E

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6 Exhibit F

View on PACER

7 Exhibit G

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8 Exhibit H

View on PACER

June 11, 2009

June 11, 2009

PACER
90

Declaration of Sanja Kovacevic in Support of 72 Memorandum in Opposition filed by Fresno County, Fresno County In-Home Supportive Services Public Authority. (Related document(s) 72 ) (Woods, Michael) (Filed on 6/11/2009) Modified on 6/12/2009 (jlm, COURT STAFF). (Entered: 06/11/2009)

June 11, 2009

June 11, 2009

PACER
91

Declaration of Steve Sanchez in Support of 72 Memorandum in Opposition filed by Fresno County, Fresno County In-Home Supportive Services Public Authority. (Related document(s) 72 ) (Woods, Michael) (Filed on 6/11/2009) Modified on 6/12/2009 (jlm, COURT STAFF). (Entered: 06/11/2009)

June 11, 2009

June 11, 2009

PACER
92

Declaration of Kathleen Donawa in Support of 72 Memorandum in Opposition filed by Fresno County, Fresno County In-Home Supportive Services Public Authority. (Related document(s) 72 ) (Woods, Michael) (Filed on 6/11/2009) Modified on 6/12/2009 (jlm, COURT STAFF). (Entered: 06/11/2009)

June 11, 2009

June 11, 2009

PACER
93

Table of Contents and Table of Authorities re 72 Memorandum in Opposition filed by Fresno County, Fresno County In-Home Supportive Services Public Authority. (Related document(s) 72 ) (Woods, Michael) (Filed on 6/12/2009) Modified on 6/15/2009 (kc, COURT STAFF). (Entered: 06/12/2009)

June 12, 2009

June 12, 2009

PACER
94

ORDER re 63 ON MOTION TO ENLARGE TIME. Signed by Judge Claudia Wilken on 6/12/09. (scc, COURT STAFF) (Filed on 6/12/2009) (Entered: 06/12/2009)

June 12, 2009

June 12, 2009

RECAP
95

Memorandum in Opposition to 5 MOTION for Preliminary Injunction filed by David Maxwell-Jolly, Arnold Schwarzenegger, John A. Wagner. (Carson, Susan) (Filed on 6/15/2009) Modified on 6/16/2009 (kc, COURT STAFF). (Entered: 06/15/2009)

June 15, 2009

June 15, 2009

PACER
96

Declaration of Timothy T. Brown, Ph.D. in Support of 95 Memorandum in Opposition, to Plaintiffs' Motion for Preliminary Injunction filed byDavid Maxwell-Jolly, Arnold Schwarzenegger, John A. Wagner. (Attachments: # 1 Exhibit A, # 2 Exhibit B)(Related document(s) 95 ) (Carson, Susan) (Filed on 6/15/2009) (Entered: 06/15/2009)

1 Exhibit A

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2 Exhibit B

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June 15, 2009

June 15, 2009

PACER
97

Declaration of Eileen Carroll in Support of 95 Memorandum in Opposition, to Motion for Preliminary Injunction filed byDavid Maxwell-Jolly, Arnold Schwarzenegger, John A. Wagner. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E, # 6 Exhibit F, # 7 Exhibit G, # 8 Exhibit H, # 9 Exhibit I)(Related document(s) 95 ) (Carson, Susan) (Filed on 6/15/2009) (Entered: 06/15/2009)

1 Exhibit A

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2 Exhibit B

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3 Exhibit C

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4 Exhibit D

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5 Exhibit E

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6 Exhibit F

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7 Exhibit G

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8 Exhibit H

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9 Exhibit I

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June 15, 2009

June 15, 2009

PACER
98

Declaration of Toby Douglas in Support of 95 Memorandum in Opposition, to Motion for Preliminary Injunction filed byDavid Maxwell-Jolly, Arnold Schwarzenegger, John A. Wagner. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C)(Related document(s) 95 ) (Carson, Susan) (Filed on 6/15/2009) (Entered: 06/15/2009)

1 Exhibit A

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2 Exhibit B

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3 Exhibit C

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June 15, 2009

June 15, 2009

PACER

Case Details

State / Territory: California

Case Type(s):

Disability Rights

Special Collection(s):

Multi-LexSum (in sample)

Key Dates

Filing Date: May 26, 2009

Closing Date: 2014

Case Ongoing: No

Plaintiffs

Plaintiff Description:

In-Home Supportive Services (IHSS) Providers and recipients

Plaintiff Type(s):

Private Plaintiff

Public Interest Lawyer: No

Filed Pro Se: No

Class Action Sought: Yes

Class Action Outcome: Granted

Defendants

Arnold Schwarzenegger, Governor of the State of California, State

John A. Wagner, Director of the California Department of Social Services, State

David Maxwell-Jolly, Director of the California Department of Health Care Services, State

John Chiang, California State Controller, State

Fresno County (Fresno), County

Fresno County In-Home Supportive Services Public Authority (Fresno), County

Defendant Type(s):

Hospital/Health Department

Jurisdiction-wide

Case Details

Causes of Action:

42 U.S.C. § 1983

State law

Medicaid, 42 U.S.C §1396 (Title XIX of the Social Security Act)

Constitutional Clause(s):

Supremacy Clause

Availably Documents:

Trial Court Docket

Complaint (any)

Injunctive (or Injunctive-like) Relief

U.S. Supreme Court merits opinion

Outcome

Prevailing Party: Plaintiff

Nature of Relief:

Injunction / Injunctive-like Settlement

Preliminary injunction / Temp. restraining order

Source of Relief:

Litigation

Form of Settlement:

Court Approved Settlement or Consent Decree

Order Duration: 2013 - None

Content of Injunction:

Preliminary relief granted

Issues

General:

Disparate Impact

Disparate Treatment

Government Services

Habilitation (training/treatment)

Payment for care

Public assistance grants

Relative caretakers

Staff (number, training, qualifications, wages)

Discrimination-basis:

Disability (inc. reasonable accommodations)

Disability:

disability, unspecified

Integrated setting

Medical/Mental Health:

Medical care, general

Medical care, unspecified

Benefit Source:

Medicaid