Case: Ocean S. v. Los Angeles County

COMPLAINT Receipt No: ACACDC-35905661 - Fee: $402, filed by Plaintiffs Jackson K., Ocean S., Onyx G., Rosie S., Erykah B., Junior R.. (Attorney Grant A Davis-Denny added to party Erykah B.(pty:pla), Attorney Grant A Davis-Denny added to party Onyx G.(pty:pla), Attorney Grant A Davis-Denny added to party Jackson K.(pty:pla), Attorney Grant A Davis-Denny added to party Junior R.(pty:pla), Attorney Grant A Davis-Denny added to party Ocean S.(pty:pla), Attorney Grant A Davis-Denny added to party Rosie S.(pty:pla))(Davis-Denny, Grant) (Entered: 08/22/2023)

CIVIL COVER SHEET filed by Plaintiffs Erykah B., Onyx G., Jackson K., Junior R., Ocean S., Rosie S.. (Davis-Denny, Grant) (Entered: 08/22/2023)

Request for Clerk to Issue Summons on Complaint (Attorney Civil Case Opening),, 1 filed by Plaintiffs Erykah B., Onyx G., Jackson K., Junior R., Ocean S., Rosie S.. (Davis-Denny, Grant) (Entered: 08/22/2023)

NOTICE of Related Case(s) filed by Plaintiffs Erykah B., Onyx G., Jackson K., Junior R., Ocean S., Rosie S.. Related Case(s): 5:23-cv-00947-MEMF-BFMx; 02-cv-056662-JAK-SHx (Davis-Denny, Grant) (Entered: 08/22/2023)

NOTICE OF ERRATA filed by Plaintiffs Erykah B., Onyx G., Jackson K., Junior R., Ocean S., Rosie S.. correcting Complaint (Attorney Civil Case Opening),, 1 (Davis-Denny, Grant) (Entered: 08/23/2023)

NOTICE OF ASSIGNMENT to District Judge Mark C. Scarsi and Magistrate Judge Charles F. Eick. (et) (Entered: 08/24/2023)

NOTICE TO PARTIES OF COURT-DIRECTED ADR PROGRAM filed. (et) (Entered: 08/24/2023)

Notice to Counsel Re Consent to Proceed Before a United States Magistrate Judge. (et) (Entered: 08/24/2023)

21 DAY Summons Issued re Complaint (Attorney Civil Case Opening) 1 as to Defendants Michelle Baass, California Department of Health Care Services, California Department of Social Services, Mark Ghaly, Kim Johnson, Los Angeles County, Los Angeles County Department of Children and Family Services, Los Angeles Department of Mental Health, Brandon Nichols, Lisa Wong. (et) (Entered: 08/24/2023)

NOTICE OF PRO HAC VICE APPLICATION DUE for Non-Resident Attorney Jessica Zou on behalf of Plaintiffs. A document recently filed in this case lists you as an out-of-state attorney of record. However, the Court has not been able to locate any record that you are admitted to the Bar of this Court, and you have not filed an application to appear Pro Hac Vice in this case. Accordingly, within 5 business days of the date of this notice, you must either (1) have your local counsel file an application to appear Pro Hac Vice (Form G-64) and pay the applicable fee, or (2) complete the next section of this form and return it to the court at cacd_attyadm@cacd.uscourts.gov. You have been removed as counsel of record from the docket in this case, and you will not be added back to the docket until your Pro Hac Vice status has been resolved. (et) (Entered: 08/24/2023)

NOTICE OF DEFICIENCIES in Attorney Case Opening RE: Complaint (Attorney Civil Case Opening) 1 . The following error(s) was found: No Notice of Interested Parties has been filed. A Notice of Interested Parties must be filed with every partys first appearance. See Local Rule 7.1-1. Counsel must file a Notice of Interested Parties immediately. Failure to do so may be addressed by judicial action, including sanctions. See Local Rule 83-7. (et) (Entered: 08/24/2023)

INITIAL STANDING ORDER FOR CIVIL CASES ASSIGNED TO JUDGE MARK C. SCARSI upon filing of the complaint by Judge Mark C. Scarsi. (smo) (Entered: 08/24/2023)

Certification and Notice of Interested Parties filed by Plaintiffs All Plaintiffs, identifying None. (Davis-Denny, Grant) (Entered: 08/24/2023)

NOTICE of Appearance filed by attorney Tara Chantelle Ford on behalf of Plaintiffs Erykah B., Onyx G., Jackson K., Junior R., Ocean S., Rosie S. (Ford, Tara) (Entered: 08/25/2023)

APPLICATION of Non-Resident Attorney Jessica Zou to Appear Pro Hac Vice on behalf of Plaintiffs Onyx G., Jackson K., Junior R., Ocean S., Rosie S. (Pro Hac Vice Fee - $500 Fee Paid, Receipt No. ACACDC-35927644) filed by Counsel of Record for Plaintiffs Ocean S., et al. Onyx G., Jackson K., Junior R., Ocean S., Rosie S.. (Attachments: # 1 Proposed Order) (Ford, Tara) (Entered: 08/25/2023)

ORDER RE TRANSFER PURSUANT to this Court's General Order in the Matter of Assignment of Cases and Duties to the District Judges. Related Case- filed. Related Case No: 2:02-cv-05662 JAK(FFMx). Case transferred from Judge Mark C. Scarsi to Judge John A. Kronstadt for all further proceedings. The case number will now reflect the initials of the transferee Judge 2:23-cv-06921 JAK(Ex). Signed by Judge John A. Kronstadt (rn) (Entered: 08/28/2023)

NOTICE of Deficiency in Electronically Filed Pro Hac Vice Application RE: APPLICATION of Non-Resident Attorney Jessica Zou to Appear Pro Hac Vice on behalf of Plaintiffs Onyx G., Jackson K., Junior R., Ocean S., Rosie S. (Pro Hac Vice Fee - $500 Fee Paid, Receipt No. ACACDC-35927644) 15 . The following error(s) was/were found: Case information is incomplete. DJ and MJ initials missing on application and proposed order. Please note DJ and MJ Notice of Assignment, dated 8/24/23, Dkt. 6. (lt) (Entered: 08/29/2023)

STANDING ORDERS FOR CIVIL CASES ASSIGNED TO JUDGE JOHN A. KRONSTADT upon filing of the complaint by Judge John A. Kronstadt. Please read each Order carefully as they differ in some respects from the Local Rules. Counsel are advised that the Court, at any time, may amend one or more of its Standing Orders. It is the responsibility of counsel to refer to this Court's Procedures and Schedules found on the website for the United States District Court, Central District of California (www.cacd.uscourts.gov) to obtain the operative order. The Court thanks the parties and their counsel for their anticipated cooperation in carrying out these requirements. (tj) (Entered: 08/30/2023)

ORDER ON APPLICATION OF NON-RESIDENT ATTORNEY TO APPEAR IN A SPECIFIC CASE PRO HAC VICE 15 by Judge John A. Kronstadt. APPLICATION to Appear Pro Hac Vice on behalf of Plaintiffs Ocean S.; Jackson K.; Rosie S.; Erykah B.; Junior R.; and Onyx G., et al., designating Tara C. Ford as local counsel. Granting 15 Non-Resident Attorney Jessica Zou (rolm) (Entered: 08/30/2023)

RESPONSE filed by Defendants Los Angeles County, Los Angeles County Department of Children and Family Services, Los Angeles Department of Mental Health, Brandon Nichols, Lisa Wongto Notice of Related Case(s) 4 (Attachments: # 1 Declaration Declaration of Farbod S. Moridani in Support of Response to Notice of Related Cases)(Moridani, Farbod) (Entered: 09/18/2023)

FIRST AMENDED COMPLAINT against Defendants All Defendants amending Complaint (Attorney Civil Case Opening),, 1, filed by Plaintiffs Jackson K., Ocean S., Onyx G., Rosie S., Erykah B., Junior R., Monaie T. (Attachments: # 1 Appendix A - Redline of Original v. FAC)(Attorney Grant A Davis-Denny added to party Monaie T.(pty:pla))(Davis-Denny, Grant) (Entered: 09/21/2023)

Notice of Appearance or Withdrawal of Counsel: for attorney Farbod Moridani counsel for Defendants Los Angeles County, Los Angeles County Department of Children and Family Services, Los Angeles Department of Mental Health, Brandon Nichols, Lisa Wong. Adding Farbod S. Moridani as counsel of record for Los Angeles County, the Department of Children and Family Services, Brandon Nichols, the Department of Mental Health, Lisa Wong for the reason indicated in the G-123 Notice. Filed by Defendant Defendants Los Angeles County, the Department of Children and Family Services, Brandon Nichols, the Department of Mental Health. (Attorney Farbod Moridani added to party Los Angeles County(pty:dft), Attorney Farbod Moridani added to party Los Angeles County Department of Children and Family Services(pty:dft), Attorney Farbod Moridani added to party Los Angeles Department of Mental Health(pty:dft), Attorney Farbod Moridani added to party Brandon Nichols(pty:dft), Attorney Farbod Moridani added to party Lisa Wong(pty:dft))(Moridani, Farbod) (Entered: 09/22/2023)

STIPULATION for Extension of Time to File Response as to Amended Complaint/Petition, 21 filed by Defendants Los Angeles County, Los Angeles County Department of Children and Family Services, Los Angeles Department of Mental Health, Brandon Nichols, Lisa Wong. (Attachments: # 1 Proposed Order Granting Stipulation to Extend Defendants Deadline to Respond to First Amended Complaint by Not More Than 30 Days)(Moridani, Farbod) (Entered: 09/29/2023)

ORDER RE STIPULATION TO EXTEND DEFENDANTS' DEADLINE TO RESPOND TO FIRST AMENDED COMPLAINT BY NOT MORE THAN 30 DAYS 23 by Judge John A. Kronstadt. Therefore, the Stipulation is APPROVED, as follows: The deadline for the Defendants to respond to the First Amended Complaint is extended to November 6, 2023. (rolm) (Entered: 10/03/2023)

NOTICE OF MOTION AND MOTION for Appointment of Craig Schultz as Guardian ad Litem for O.G. filed by Plaintiffs Erykah B., Onyx G., Jackson K., Junior R., Ocean S., Rosie S., Monaie T.. (Davis-Denny, Grant) (Entered: 10/12/2023)

(IN CHAMBERS) ORDER REFERRING PLAINTIFF ONYX G.'S UNOPPOSED MOTION FOR APPOINTMENT OF NEXT FRIEND AND SUPPORTING MEMORANDUM TO MAGISTRATE JUDGE CHARLES F. EICK by Judge John A. Kronstadt: The Court has reviewed the motion and refers the matter to Judge Charles F. Eick for his determination. THERE IS NO PDF DOCUMENT ASSOCIATED WITH THIS ENTRY. (tj) TEXT ONLY ENTRY (Entered: 10/18/2023)

DECLARATION of Onyx G. in support of NOTICE OF MOTION AND MOTION for Appointment of Craig Schultz as Guardian ad Litem for O.G. 25 filed by Plaintiffs Erykah B., Onyx G., Jackson K., Junior R., Ocean S., Rosie S., Monaie T.. (Attachments: # 1 Declaration of Craig Schultz ISO Plaintiff Onyx G.'s Unopposed Motion for Appointment of Next Friend, # 2 Proposed Order)(Davis-Denny, Grant) (Entered: 10/18/2023)

Text Only Scheduling Notice

MINUTES (IN CHAMBERS) by Magistrate Judge Charles F. Eick denying 25 MOTION for Appointment of Next Friend. See document for details. (vmun) (Entered: 10/23/2023)

NOTICE OF MOTION AND MOTION to for Leave to Proceed Using Pseudonyms and Supporting Memorandum filed by Plaintiffs Erykah B., Onyx G., Jackson K., Junior R., Ocean S., Rosie S., Monaie T.. Motion set for hearing on 11/27/2023 at 08:30 AM before Judge John A. Kronstadt. (Attachments: # 1 Declaration of Jimmy P. Biblarz ISO Plaintiffs' Motion for Leave, # 2 Exhibit A to Biblarz Declaration, # 3 Exhibit B to Biblarz Declaration) (Davis-Denny, Grant) (Entered: 10/23/2023)

STIPULATION for Extension of Time to File To extend Defendants' deadline to respond to first amended complaint filed by Defendants Michelle Baass, California Department of Health Care Services, California Department of Social Services, Mark Ghaly, Kim Johnson, California Department of Health and Human Services. (Attachments: # 1 Proposed Order)(Attorney Andrew Zachary Edelstein added to party Michelle Baass(pty:dft), Attorney Andrew Zachary Edelstein added to party California Department of Health Care Services(pty:dft), Attorney Andrew Zachary Edelstein added to party California Department of Social Services(pty:dft), Attorney Andrew Zachary Edelstein added to party Mark Ghaly(pty:dft), Attorney Andrew Zachary Edelstein added to party Kim Johnson(pty:dft), Attorney Andrew Zachary Edelstein added to party California Department of Health and Human Services(pty:dft))(Edelstein, Andrew) (Entered: 10/24/2023)

APPLICATION of Non-Resident Attorney Rebecca J. Ritchin to Appear Pro Hac Vice on behalf of Plaintiff Ocean S. (Pro Hac Vice Fee - $500 Fee Paid, Receipt No. ACACDC-36293094) filed by Plaintiffs Ocean S., et al. Ocean S.. (Attachments: # 1 Proposed Order) (Ford, Tara) (Entered: 10/25/2023)

APPLICATION of Non-Resident Attorney Stephanie Persson to Appear Pro Hac Vice on behalf of Plaintiff Ocean S. (Pro Hac Vice Fee - $500 Fee Paid, Receipt No. ACACDC-36293231) filed by Plaintiffs Ocean S.. (Attachments: # 1 Proposed Order) (Ford, Tara) (Entered: 10/25/2023)

ORDER by Judge John A. Kronstadt: granting 32 Non-Resident Attorney Stephanie Persson APPLICATION to Appear Pro Hac Vice on behalf of Ocean S., Jackson K. Rosie S. Erykah B. Junior R., Onyx G., Monaie T. et al, designating Tara C. Ford as local counsel. (yl) (Entered: 10/27/2023)

ORDER RE STIPULATION TO EXTEND DEFENDANTS' DEADLINE TO RESPOND TO FIRST AMENDED COMPLAINT (DKT. 30) by Judge John A. Kronstadt. The County and State Defendants shall respond to the FAC on or before November 21, 2023. The oppositions to any motions to dismiss shall be due on January 16, 2024. The replies in support of any motions to dismiss shall be filed on or before February 20, 2024. The County and State Defendants are directed to set any motions to dismiss for hearing on March 25, 2024 at 8:30 a.m. IT IS SO ORDERED. (yl) (Entered: 10/27/2023)

ORDER by Judge John A. Kronstadt: granting 31 Non-Resident Attorney Rebecca J. Ritchin APPLICATION to Appear Pro Hac Vice on behalf of Plaintiffs Ocean S., Jackson K., Rosie S. Erykah B, Junior R. Oxyx G. Monaie T. et al., designating Tara C. Ford as local counsel. (yl) (Entered: 11/14/2023)

The County Defendants' Opposition to Plaintiffs' Motion for Leave to Proceed Using Pseudonyms opposition re: NOTICE OF MOTION AND MOTION to for Leave to Proceed Using Pseudonyms and Supporting Memorandum 29 filed by Defendants Los Angeles County, Los Angeles County Department of Children and Family Services, Los Angeles Department of Mental Health, Brandon Nichols, Lisa Wong. (Attachments: # 1 Declaration of Farbod S. Moridani in Support of Defendants' Opposition to Plaintiffs' Motion for Leave to Proceed Using Pseudonyms)(Moridani, Farbod) (Entered: 11/06/2023)

STIPULATION File Stipulation to Seal Docket No. 29 and to Allow Filing of a Corrected Version Under Seal filed by Plaintiffs Erykah B., Onyx G., Jackson K., Junior R., Ocean S., Rosie S., Monaie T..(Davis-Denny, Grant) (Entered: 11/09/2023)

Corrected NOTICE OF MOTION AND MOTION to Proceed Using Pseudonyms and Supporting Memorandum filed by Plaintiffs Erykah B., Onyx G., Junior R., Ocean S., Rosie S., Monaie T.. Motion set for hearing on 11/27/2023 at 08:30 AM before Judge John A. Kronstadt. (Attachments: # 1 Declaration of Jimmy P. Biblarz ISO Plaintiffs' Motion to Leave to Proceed Using Pseudonyms, # 2 Exhibit A to Biblarz Declaration, # 3 Exhibit B to Biblarz Declaration) (Davis-Denny, Grant) (Entered: 11/09/2023)

REPLY in Support of a Motion Corrected NOTICE OF MOTION AND MOTION to Proceed Using Pseudonyms and Supporting Memorandum 37 filed by Plaintiffs Erykah B., Onyx G., Jackson K., Junior R., Ocean S., Rosie S., Monaie T.. (Attachments: # 1 Declaration of Jimmy P. Biblarz in Support of Plaintiffs' Reply in Support of Motion to Proceed Using Pseudonyms, # 2 Exhibit A to Jimmy P. Biblarz Declaration, # 3 Exhibit B to Jimmy P. Biblarz Declaration)(Davis-Denny, Grant) (Entered: 11/13/2023)

JOINT REPORT Rule 26(f) Discovery Plan filed by Plaintiffs Erykah B., Onyx G., Jackson K., Junior R., Ocean S., Rosie S., Monaie T... (Attachments: # 1 Exhibit A)(Davis-Denny, Grant) (Entered: 11/13/2023)

STIPULATION for Order To Modify Briefing Schedule On Defendants' Responses to First Amended Complaint filed by Defendants Michelle Baass, California Department of Health Care Services, California Department of Social Services, Mark Ghaly, Kim Johnson, California Health and Human Services Agency. (Attachments: # 1 Proposed Order)(Attorney Andrew Zachary Edelstein added to party California Health and Human Services Agency(pty:dft))(Edelstein, Andrew) (Entered: 11/14/2023)

ORDER RE STIPULATION TO SEAL DOCKET NO. 29 AND TO ALLOW FILING OF A CORRECTED VERSION (DKT. 36) by Judge John A. Kronstadt. the Stipulation is APPROVED, as follows: Dkts. 29 and 29-1 shall be deemed under seal. Plaintiffs shall file a corrected version of Dkts. 29 and 29-1 that removes Plaintiffs' true first names from the caption and is otherwise identical to the original filing. The filing of the corrected version of Dkts. 29 and 29-1 will not change the briefing deadlines or hearing date for that motion. Nothing in this Order or in the Stipulation waives Plaintiffs' or Defendants' positions on whether the releif requested in Dkts. 29 and 29-1 and the corrected version of that motion should be granted or denied. IT IS SO ORDERED. (yl) (Entered: 11/16/2023)

ORDER RE STIPULATION TO SEAL DOCKET NO. 29 AND TO ALLOW FILING OF A CORRECTED VERSION (DKT. 36 ) by Judge John A. Kronstadt 36 . the Stipulation is APPROVED, as follows: Dkts. 29 and 29-1 shall be deemed under seal. Plaintiffs shall file a corrected version of Dkts. 29 and 29-1 that removes Plaintiffs' true first names from the caption and is otherwise identical to the original filing. The filing of the corrected version of Dkts. 29 and 29-1 will not change the briefing deadlines or hearing date for that motion. Nothing in this Order or in the Stipulation waives Plaintiffs' or Defendants' positions on whether the relief requested in Dkts. 29 and 29-1 and the corrected version of that motion should be granted or denied. IT IS SO ORDERED. (yl) (Entered: 11/16/2023)

NOTICE OF CLERICAL ERROR: Due to clerical error, document 43 is a duplicate of 42 . (yl) (Entered: 11/16/2023)

ORDER RE STIPULATION TO MODIFY BRIEFING SCHEDULE ON DEFENDANTS' RESPONSES TO FIRST AMENDED COMPLAINT (DKT. 41 ) by Judge John A. Kronstadt. The County and State Defendants shall respond to the FAC on or before November 29, 2023. Oppositions to any motions to dismiss shall be filed on or before January 23, 2024. Replies in support of any motions to dismiss shall be filed on or before February 20, 2024. The motions to dismiss shall remain set for hearing on March 25, 2024, at 8:30 a.m. IT IS SO ORDERED. (yl) (Entered: 11/17/2023)

(IN CHAMBERS) TEXT-ONLY ORDER TAKING MOTIONS FOR LEAVE TO PROCEED USING PSEUDONYMS (DKTS. 29 AND 37 ) UNDER SUBMISSION by Judge John A. Kronstadt: Based on a review of the Motions for Leave to Proceed Using Pseudonyms (Dkts. 29 and 37 ), it has been determined that they can be decided without oral argument. Local Rule 7-15. The motions, which were noticed for hearing on November 27, 2023, are taken under submission and off calendar. No appearance by counsel or the parties is necessary on November 27, 2023. THERE IS NO PDF DOCUMENT ASSOCIATED WITH THIS ENTRY. (JAKLC2) TEXT ONLY ENTRY (Entered: 11/20/2023)

MINUTES (IN CHAMBERS) ORDER RE PLAINTIFFS' MOTION FOR LEAVE TO PROCEED USING PSEUDONYMS 29 PLAINTIFF'S CORRECTED MOTION FOR LEAVE TO PROCEED USING PSEUDONYMS 37 by Judge John A. Kronstadt. The Motion is GRANTED. Within 21 days of the issuance of this Order, the parties shall meet and confer regarding the entry of a protective order. If the parties cannot agree on the language of the protective order, within 21 days of the issuance of this Order, the parties shall file a joint report stating their respective positions regarding the scope of the protective order. Each party shall attach to the joint report its proposal for the protective order that should be entered. The matter may then be referred to the Magistrate Judge. The parties' obligations to provide responses to discovery are stayed as to any sensitive information until the protective order is entered. (SEE DOCUMENT FOR FURTHER DETAILS.) (rolm) (Entered: 11/20/2023)

Text Only Scheduling Notice

NOTICE OF MOTION AND MOTION to Dismiss For an Order Dismissing the Entire Action, Wiith Prejudice, as to DHCS filed by Defendants Michelle Baass, California Department of Health Care Services. Motion set for hearing on 3/25/2024 at 08:30 AM before Judge John A. Kronstadt. (Edelstein, Andrew) (Entered: 11/29/2023)

NOTICE OF MOTION AND MOTION to Dismiss For an Order Dismissing the Entire Action, With Predjudice, as to CalHHS. filed by Defendants California Health and Human Services Agency, Mark Ghaly. Motion set for hearing on 3/25/2024 at 08:30 AM before Judge John A. Kronstadt. (Edelstein, Andrew) (Entered: 11/29/2023)

NOTICE OF MOTION AND MOTION to Dismiss For an Order Dismissing The Entire Action, With Prejudice, As To CDSS. filed by For an Order Dismissing the Entire Action, With Prejudice, as to CDSS. California Department of Social Services, Kim Johnson. Motion set for hearing on 3/25/2024 at 08:30 AM before Judge John A. Kronstadt. (Edelstein, Andrew) (Entered: 11/29/2023)

NOTICE OF MOTION AND MOTION to Dismiss for Lack of Jurisdiction filed by defendants Los Angeles County, Los Angeles County Department of Children and Family Services, Los Angeles Department of Mental Health, Brandon Nichols, Lisa Wong. Motion set for hearing on 3/25/2024 at 08:30 AM before Judge John A. Kronstadt. (Attachments: # 1 Memorandum Memorandum of Points in Support of County Defendants' Motion to Dismiss for Lack of Subject Matter Jurisdiction) (Moridani, Farbod) (Entered: 11/29/2023)

NOTICE OF MOTION AND MOTION to Dismiss Failure to State a Claim filed by defendant Los Angeles County. Motion set for hearing on 3/25/2024 at 08:30 AM before Judge John A. Kronstadt. (Attachments: # 1 Memorandum Memorandum of Points and Authorities in Support of Los Angeles County's Motion to Dismiss for Failure to State a Claim Under Federal Rule of Civil Procedure 12(b)(6), # 2 Memorandum in Support for Request for Judicial Notice, # 3 Declaration Declaration of Farbod Moridani in Support of Los Angeles County's Motion to Dismiss, # 4 Exhibit Exhibit 1 to Moridani Declaration, # 5 Exhibit Exhibit 2 to Moridani Declaration, # 6 Exhibit Exhibit 3 to Moridani Declaration, # 7 Exhibit Exhibit 4 to Moridani Declaration, # 8 Exhibit Exhibit 5 to Moridani Declaration, # 9 Exhibit Exhibit 6 to Moridani Declaration, # 10 Exhibit Exhibit 7 to Moridani Declaration, # 11 Exhibit Exhibit 8 to Moridani Declaration, # 12 Exhibit Exhibit 9 to Moridani Declaration, # 13 Exhibit Exhibit 10 to Moridani Declaration, # 14 Exhibit Exhibit 11 to Moridani Declaration, # 15 Exhibit Exhibit 12 to Moridani Declaration, # 16 Exhibit Exhibit 13 to Moridani Declaration, # 17 Exhibit Exhibit 14 to Moridani Declaration, # 18 Exhibit Exhibit 15 to Moridani Declaration, # 19 Exhibit Exhibit 16 to Moridani Declaration, # 20 Exhibit Exhibit 17 to Moridani Declaration, # 21 Exhibit Exhibit 18 to Moridani Declaration, # 22 Exhibit Exhibit 19 to Moridani Declaration, # 23 Exhibit Exhibit 20 to Moridani Declaration, # 24 Exhibit Exhibit 21 to Moridani Declaration, # 25 Exhibit Exhibit 22 to Moridani Declaration, # 26 Exhibit Exhibit 23 to Moridani Declaration, # 27 Exhibit Exhibit 24 to Moridani Declaration, # 28 Exhibit Exhibit 25 to Moridani Declaration, # 29 Exhibit Exhibit 26 to Moridani Declaration, # 30 Exhibit Exhibit 27 to Moridani Declaration, # 31 Exhibit Exhibit 28 to Moridani Declaration) (Moridani, Farbod) (Entered: 11/29/2023)

NOTICE OF MOTION AND MOTION to Dismiss Failure to State a Claim filed by defendants Los Angeles County Department of Children and Family Services, Los Angeles Department of Mental Health, Brandon Nichols, Lisa Wong. Motion set for hearing on 3/25/2024 at 08:30 AM before Judge John A. Kronstadt. (Attachments: # 1 Memorandum Memorandum of Points and Authorities in Support of the Departments and Directors' Motion to Dismiss for Failure to State a Claim) (Moridani, Farbod) (Entered: 11/29/2023)

NOTICE OF MOTION AND MOTION for Joinder in NOTICE OF MOTION AND MOTION to Dismiss Failure to State a Claim 52 filed by defendants Los Angeles County Department of Children and Family Services, Los Angeles Department of Mental Health, Brandon Nichols, Lisa Wong. Motion set for hearing on 3/25/2024 at 08:30 AM before Judge John A. Kronstadt. (Moridani, Farbod) (Entered: 11/29/2023)

NOTICE OF MOTION AND MOTION to Stay pending Ruling on Motion to Dismiss for Lack of Subject Matter Jurisdiction filed by defendants Los Angeles County, Los Angeles County Department of Children and Family Services, Los Angeles Department of Mental Health, Brandon Nichols, Lisa Wong. Motion set for hearing on 1/29/2024 at 08:30 AM before Judge John A. Kronstadt. (Attachments: # 1 Memorandum Memorandum of Points and Authorities in Support of the County Defendants' Motion to Stay Discovery Pending Ruling on Motion to Dismiss for Lack of Subject Matter Jurisdiction, # 2 Declaration Declaration of Farbod Moridani in Support of Los Angeles County's Motion to Dismiss, # 3 Exhibit Exhibit 1 to Moridani Declaration, # 4 Exhibit Exhibit 2 to Moridani Declaration) (Moridani, Farbod) (Entered: 11/29/2023)

NOTICE OF LODGING filed re NOTICE OF MOTION AND MOTION to Dismiss For an Order Dismissing the Entire Action, Wiith Prejudice, as to DHCS 48 (Attachments: # 1 Proposed Order)(Edelstein, Andrew) (Entered: 11/30/2023)

NOTICE OF LODGING filed re NOTICE OF MOTION AND MOTION to Dismiss For an Order Dismissing the Entire Action, With Predjudice, as to CalHHS. 49 (Attachments: # 1 Proposed Order)(Edelstein, Andrew) (Entered: 11/30/2023)

NOTICE OF LODGING filed re NOTICE OF MOTION AND MOTION to Dismiss For an Order Dismissing The Entire Action, With Prejudice, As To CDSS. 50 (Attachments: # 1 Proposed Order)(Edelstein, Andrew) (Entered: 11/30/2023)

STIPULATION for Extension of Time to File Agree Upon Protective Order or Joint Report filed by defendants Los Angeles County, Los Angeles County Department of Children and Family Services, Los Angeles Department of Mental Health, Brandon Nichols, Lisa Wong. (Attachments: # 1 Proposed Order Granting Stipulation to Extend Time to Submit Agreed Upon Protective Order or Joint Report)(Moridani, Farbod) (Entered: 12/08/2023)

OPPOSITION Opposition re: NOTICE OF MOTION AND MOTION to Stay pending Ruling on Motion to Dismiss for Lack of Subject Matter Jurisdiction 55 filed by Plaintiffs Erykah B., Onyx G., Jackson K., Junior R., Ocean S., Rosie S., Monaie T.. (Attachments: # 1 Declaration of Rachel Stein, # 2 Exhibit A, # 3 Exhibit B, # 4 Exhibit C, # 5 Exhibit D, # 6 Exhibit E, # 7 Exhibit F, # 8 Exhibit G, # 9 Exhibit H)(Davis-Denny, Grant) (Entered: 12/13/2023)

ORDER RE STIPULATION TO EXTEND TIME TO SUBMIT AGREED UPON PROTECTIVE ORDER OR JOINT REPORT (DKT. 59 ) by Judge John A. Kronstadt. The Stipulation is APPROVED, as follows: The State Defendants shall provide to the County Defendants revisions, if any, to the County Defendants' protective order proposal by December 12, 2023. The County Defendants and State Defendants shall confer and provide a consolidated protective order proposal to Plaintiffs by December 15, 2023. Plaintiffs shall provide initial revisions to the consolidated protective order proposal by December 18, 2023. The parties shall meet and confer again by no later than December 19, 2023 to discuss any remaining areas of disagreement. The parties' deadline to submit an agreed upon protective order or joint report is extended from December 11, 2023 to December 22, 2023. IT IS SO ORDERED. (yl) (Entered: 12/14/2023)

JOINDER in NOTICE OF MOTION AND MOTION to Stay pending Ruling on Motion to Dismiss for Lack of Subject Matter Jurisdiction 55, NOTICE OF MOTION AND MOTION to Dismiss for Lack of Jurisdiction 51 filed by Defendants Michelle Baass, California Department of Health Care Services, California Department of Health and Human Services, California Department of Social Services, California Health and Human Services Agency, Mark Ghaly, Kim Johnson. (Edelstein, Andrew) (Entered: 12/14/2023)

REPLY in support of NOTICE OF MOTION AND MOTION to Stay pending Ruling on Motion to Dismiss for Lack of Subject Matter Jurisdiction 55 filed by Defendants Los Angeles County, Los Angeles County Department of Children and Family Services, Los Angeles Department of Mental Health, Brandon Nichols, Lisa Wong. (Moridani, Farbod) (Entered: 12/20/2023)

NOTICE OF LODGING filed by Plaintiffs re Order on Motion for Leave,,,,,,, 47 (Attachments: # 1 Stipulated Protective Order)(Davis-Denny, Grant) (Entered: 12/22/2023)

STIPULATED PROTECTIVE ORDER by Magistrate Judge Charles F. Eick. (See document for details) (vmun) (Entered: 12/27/2023)

OPPOSITION Opposition re: NOTICE OF MOTION AND MOTION to Dismiss for Lack of Jurisdiction 51 filed by Plaintiffs Erykah B., Onyx G., Jackson K., Junior R., Ocean S., Rosie S., Monaie T.. (Davis-Denny, Grant) (Entered: 01/23/2024)

OPPOSITION Opposition re: NOTICE OF MOTION AND MOTION to Dismiss Failure to State a Claim 52 filed by Plaintiffs Erykah B., Onyx G., Jackson K., Junior R., Ocean S., Rosie S., Monaie T.. (Davis-Denny, Grant) (Entered: 01/23/2024)

OPPOSITION Opposition re: NOTICE OF MOTION AND MOTION to Dismiss For an Order Dismissing The Entire Action, With Prejudice, As To CDSS. 50 filed by Plaintiffs Erykah B., Onyx G., Jackson K., Junior R., Ocean S., Rosie S., Monaie T.. (Davis-Denny, Grant) (Entered: 01/23/2024)

OPPOSITION Opposition re: NOTICE OF MOTION AND MOTION to Dismiss Failure to State a Claim 53 filed by Plaintiffs Erykah B., Onyx G., Jackson K., Junior R., Ocean S., Rosie S., Monaie T.. (Davis-Denny, Grant) (Entered: 01/23/2024)

OPPOSITION Opposition re: NOTICE OF MOTION AND MOTION to Dismiss Failure to State a Claim 52 filed by Plaintiffs Erykah B., Onyx G., Jackson K., Junior R., Ocean S., Rosie S., Monaie T.. (Davis-Denny, Grant) (Entered: 01/23/2024)

OPPOSITION Opposition re: NOTICE OF MOTION AND MOTION to Dismiss For an Order Dismissing the Entire Action, Wiith Prejudice, as to DHCS 48 filed by Plaintiffs Erykah B., Onyx G., Jackson K., Junior R., Ocean S., Rosie S., Monaie T.. (Davis-Denny, Grant) (Entered: 01/23/2024)

OPPOSITION Opposition re: NOTICE OF MOTION AND MOTION to Dismiss For an Order Dismissing the Entire Action, With Predjudice, as to CalHHS. 49 filed by Plaintiffs Erykah B., Onyx G., Jackson K., Junior R., Ocean S., Rosie S., Monaie T.. (Davis-Denny, Grant) (Entered: 01/23/2024)

(IN CHAMBERS) ORDER CONTINUING COUNTY DEFENDANTS' MOTION TO STAY DISCOVERY PENDING RULING ON MOTION TO DISMISS FOR LACK OF SUBJECT MATTER JURISDICTION (DKT. 55 ) by Judge John A. Kronstadt. On the Court's own motion, the hearing on the motion is continued from January 29, 2024 to February 5, 2024, at 8:30 a.m., with the precise time to be determined once the calendar issues for that date. THERE IS NO PDF DOCUMENT ASSOCIATED WITH THIS ENTRY. (tj) TEXT ONLY ENTRY (Entered: 01/29/2024)

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DECLARATION of Farbod S. Moridani in Support of NOTICE OF MOTION AND MOTION to Stay pending Ruling on Motion to Dismiss for Lack of Subject Matter Jurisdiction 55 filed by Defendants Los Angeles County, Los Angeles County Department of Children and Family Services, Los Angeles Department of Mental Health, Brandon Nichols, Lisa Wong. (Moridani, Farbod) (Entered: 02/01/2024)

(IN CHAMBERS) ORDER CHANGING THE TIME FOR COUNTY DEFENDANTS' MOTION TO STAY DISCOVERY PENDING RULING ON MOTION TO DISMISS FOR LACK OF SUBJECT MATTER JURISDICTION HEARING (DKT. 55 ) by Judge John A. Kronstadt: On the Courts own motion, the TIME for the hearing is RESET from 8:30 a.m., to 9:45 a.m., on February 5, 2024. The hearing will proceed in-person at the First Street Courthouse, Courtroom 10B. THERE IS NO PDF DOCUMENT ASSOCIATED WITH THIS ENTRY. (tj) TEXT ONLY ENTRY (Entered: 02/01/2024)

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STIPULATION for Leave to To file Amicus Briefs, To Modify Briefing Schedule, And to Continue Hearing Date on Motion to Dismiss in Light of Amici Submissions filed by Defendants Michelle Baass, California Department of Health Care Services, California Department of Social Services, California Health and Human Services Agency, Mark Ghaly, Kim Johnson. (Attachments: # 1 Proposed Order)(Edelstein, Andrew) (Entered: 02/02/2024)

COUNTY DEFENDANTS' MOTION TO STAY DISCOVERY PENDING RULING ON MOTION TO DISMISS FOR LACK OF SUBJECT MATTER JURISDICTION (DKT. 55) hearing held before Judge John A. Kronstadt. The Court states its tentative views that it is inclined to deny in part the County Defendants' Motion to Stay Discovery Pending Ruling on Motion to Dismiss for Lack of Subject Matter Jurisdiction at Dkt. 55 (the Motion) and establish a procedure through which the parties could present issues to Judge Eick with respect to discovery, and he could make determinations as to its appropriate scope and timing, including as to discovery prior to the resolution of the Motion, and thereafter if the Motion is denied. Counsel address the Court. The Court takes the Motion UNDER SUBMISSION and a ruling will be issued. Based on a review of the parties' November 13, 2023 Joint Report at Dkt. 39, it has been determined that the following tentative deadlines are proposed; provided, however, they may be modified based on a request by counsel following their meet and confer process: June 3, 2024 is the last day to add parties/amend pleadings. February 5, 2025 is the last date to file a notice of settlement. February 24, 2025 at 8:30 am is the hearing on motion for class certification and post mediation status conference. (See document for further details) Court Reporter: Wil Wilcox. (yl) (Entered: 02/09/2024)

ORDER RE STIPULATION REGARDING LEAVE TO FILE AMICUS BRIEFS, TO MODIFY BRIEFING SCHEDULE AND TO CONTINUE HEARING DATE ON MOTIONS TO DISMISS (DKT. 76 ) by Judge John A. Kronstadt. The Stipulation is APPROVED IN PART, as follows: The amici curiae referenced in the Stipulation are granted leave to file Amicus Briefs without prejudice to Defendants arguments as to their consideration or substance. Each brief shall not exceed 15 pages. The hearing on the pending Motions to Dismiss (the "Motions" (Dkts. 4854)) is continued from March 25, 2024, at 8:30 a.m. to April 8, 2024, at 8:30 a.m.; The deadline for Defendants reply briefs in support of the Motions is continued from February 20, 2024, to February 27, 2024; and Defendants may eac h file briefs in response to the Amicus Briefs on or before March 5, 2024. Defendants shall limit their responses to the issues presented in the Amicus Briefs, including whether the briefs should be considered at all. Defendants' response briefs shall not exceed 15 pages. IT IS SO ORDERED. (yl) (Entered: 02/08/2024)

Notice of Appearance or Withdrawal of Counsel: for attorney Matt Aidan Getz counsel for Amicus Parties CASA of Los Angeles, Children's Legal Services of San Diego, East Bay Children's Law Offices, Dependency Legal Services, Law Foundation of Silicon Valley. Adding Matt Aidan Getz as counsel of record for CASA of Los Angeles, Children's Legal Services of San Diego, East Bay Children's Law Offices, Dependency Legal Services, and Law Foundation of Silicon Valley for the reason indicated in the G-123 Notice. Filed by Amici Curiae CASA of Los Angeles, Children's Legal Services of San Diego, East Bay Children's Law Offices, Dependency Legal Services, and Law Foundation of Silicon Valley. (Attorney Matt Aidan Getz added to party CASA of Los Angeles(pty:am), Attorney Matt Aidan Getz added to party Children's Legal Services of San Diego(pty:am), Attorney Matt Aidan Getz added to party East Bay Children's Law Offices(pty:am), Attorney Matt Aidan Getz added to party Dependency Legal Services(pty:am), Attorney Matt Aidan Getz added to party Law Foundation of Silicon Valley(pty:am))(Getz, Matt) (Entered: 02/08/2024)

Amicus Curiae Brief filed filed by Amicus Parties CASA of Los Angeles, Children's Legal Services of San Diego, Dependency Legal Services, East Bay Children's Law Offices, Law Foundation of Silicon Valley. RE: Order,,,,, Set/Reset Motion Hearing and R&R Deadlines,,,, 77 . (Getz, Matt) (Entered: 02/08/2024)

Amicus Curiae Brief filed filed by Amicus Family Violence Appellate Project. RE: Order,,,,, Set/Reset Motion Hearing and R&R Deadlines,,,, 77 . (Campion, Taylor) (Entered: 02/08/2024)

NOTICE OF DISMISSAL filed by Plaintiffs Jackson K., Ocean S., Onyx G., Rosie S., Erykah B., Monaie T., Junior R. pursuant to FRCP 41a(1) as to Brandon Nichols, Lisa Wong. (Davis-Denny, Grant) (Entered: 02/09/2024)

TRANSCRIPT ORDER as to Defendants Los Angeles County, Los Angeles County Department of Children and Family Services, Los Angeles Department of Mental Health, Brandon Nichols, Lisa Wong for Court Reporter. Court will contact DAndrea Green at dgreen@millerbarondess.com with further instructions regarding this order. Transcript preparation will not begin until payment has been satisfied with the court reporter. (Moridani, Farbod) (Entered: 02/13/2024)

TRANSCRIPT ORDER as to Plaintiffs Erykah B., Onyx G., Jackson K., Junior R., Ocean S., Rosie S., Monaie T. for Court Reporter. Court will contact glenda.hunt@mto.com at glenda.hunt@mto.com with further instructions regarding this order. Transcript preparation will not begin until payment has been satisfied with the court reporter. (Davis-Denny, Grant) (Entered: 02/13/2024)

SCHEDULING NOTICE by Magistrate Judge Charles F. Eick. The Court sets a Telephonic Status Conference regarding the discovery process on March 7, 2024 at 2:00 PM before Magistrate Judge Charles F. Eick. The Courtroom Deputy Clerk will provide the dial-in information.THERE IS NO PDF DOCUMENT ASSOCIATED WITH THIS ENTRY. (vmun) TEXT ONLY ENTRY (Entered: 02/22/2024)

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JOINT STATUS REPORT of RE CASE DEADLINES filed by Plaintiffs Erykah B., Onyx G., Jackson K., Junior R., Ocean S., Rosie S., Monaie T.. (Gratzinger, Peter) (Entered: 02/26/2024)

(IN CHAMBERS) ORDER RE COUNTY DEFENDANTS' MOTION TO STAY DISCOVERY PENDING RULING ON MOTION TO DISMISS FOR LACK OF SUBJECT MATTER JURISDICTION (DKT. 55 ) by Judge John A. Kronstadt. For the reasons stated in this Order, the Motion to Stay is DENIED IN PART, without prejudice to Defendants making particularized objections to specific discovery that has been or will be requested, including the claimed burdens that would result, and with such disputes to be addressed in the manner determined by Judge Eick. IT IS SO ORDERED. (See document for further details) (yl) (Entered: 02/28/2024)

REPLY In Support of NOTICE OF MOTION AND MOTION to Dismiss For an Order Dismissing the Entire Action, Wiith Prejudice, as to DHCS 48 filed by Defendants Michelle Baass, California Department of Health Care Services. (Edelstein, Andrew) (Entered: 02/27/2024)

REPLY In Support of NOTICE OF MOTION AND MOTION to Dismiss For an Order Dismissing the Entire Action, With Predjudice, as to CalHHS. 49 filed by Defendants California Health and Human Services Agency, Mark Ghaly. (Edelstein, Andrew) (Entered: 02/27/2024)

REPLY In Support of NOTICE OF MOTION AND MOTION to Dismiss For an Order Dismissing The Entire Action, With Prejudice, As To CDSS. 50 filed by Defendants California Department of Social Services, Kim Johnson. (Edelstein, Andrew) (Entered: 02/27/2024)

REPLY in support of NOTICE OF MOTION AND MOTION to Dismiss for Lack of Jurisdiction 51 filed by Defendants Los Angeles County, Los Angeles County Department of Children and Family Services, Los Angeles Department of Mental Health. (Moridani, Farbod) (Entered: 02/27/2024)

REPLY in support of NOTICE OF MOTION AND MOTION to Dismiss Failure to State a Claim 52 filed by Defendant Los Angeles County. (Moridani, Farbod) (Entered: 02/27/2024)

REPLY in support of NOTICE OF MOTION AND MOTION to Dismiss Failure to State a Claim 53 filed by Defendants Los Angeles County Department of Children and Family Services, Los Angeles Department of Mental Health. (Moridani, Farbod) (Entered: 02/27/2024)

(IN CHAMBERS) TEXT-ONLY ORDER REGARDING JOINT REPORT (DKT. 86 ) by Judge John A. Kronstadt: Based on a review of the Joint Report (Dkt. 86 ), the parties are directed to file a joint report on or before March 14, 2024, with any updates as to the positions stated in the Joint Report, including as to the proposed schedule each has presented, in light of the proceedings before Judge Eick on March 7, 2024. Based on a review of the updated joint report, a determination will be made as to whether to set a schedule at that time, or to defer doing so. THERE IS NO PDF DOCUMENT ASSOCIATED WITH THIS ENTRY. (JAKCL2) TEXT ONLY ENTRY (Entered: 02/29/2024)

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