Myrah Martinez et al v. County of Sonoma et al

Filing 95

ORDER ADOPTING STIPULATION OF DISMISSAL AND INJUNCTIVE RELIEF re 94 STIPULATION WITH PROPOSED ORDER filed by Jenifer Stum, R.M., Kitara McCray, Madison Marlene Marvel, Myrah Martinez. Signed by Judge Jon S. Tigar on September 27, 2016. (wsn, COURT STAFF) (Filed on 9/27/2016)

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Mark E. Merin (State Bar No. 043849)
Paul H. Masuhara (State Bar No. 289805)

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LAW OFFICE OF MARK E. MERIN

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1010 F Street, Suite 300
Sacramento, California 95814
Telephone:
[phone]
Facsimile:
[phone]
E-Mail:
[e-mail]
[e-mail]

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Attorneys for Plaintiffs

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Bonnie A. Freeman, Esq. (SB 180502)
Marshall E. Bluestone, Esq. (SB 151632)
SENNEFF FREEMAN & BLUESTONE, LLP
50 Old Courthouse Square, Suite 401
P.O. Box 3729
Santa Rosa, CA 95402-3729
Telephone:
707-526-4250
Facsimile:
707-526-0347
[e-mail]
[e-mail]

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Attorneys for Defendants

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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MYRAH MARTINEZ, et al.,

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Plaintiffs,

SAN FRANCISCO DIVISION
Case No. 3:15-cv-01953-JST
ORDER ADOPTING STIPULATION OF
DISMISSAL AND INJUNCTIVE RELIEF

vs.
COUNTY OF SONOMA, et al.,
Defendants.
The parties hereby stipulate to the dismissal of Plaintiffs MYRAH MARTINEZ, KITARA
MCCRAY, MADISON MARLENE MARVEL, and R.M.’s claims, with prejudice, and to the dismissal
of the class claims, without prejudice, with each side to bear their own attorneys’ fees and costs, and with
the Court to retain continuing jurisdiction over the terms of the following stipulated injunction.
STIPULATED INJUNCTION
The County of Sonoma, through its Human Services Department, affirms that the Valley of the
Moon Children’s Home (“VOMCH”) has had the following policies in place and shall continue to follow
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ORDER ADOPTING STIPULATION OF DISMISSAL AND INJUNCTIVE RELIEF
Martinez v. County of Sonoma; United States District Court, Northern District of California, Case No. 3:15-cv-01953-JST

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these policies:
a)

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reasonable suspicion and a supervisor approves of the search, and it shall continue to

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VOMCH does not conduct personal or property searches unless there is individualized

follow this policy; and
b)

VOMCH does not take away clients’ cell phones or chargers unless there is individualized
reasonable cause for such and a supervisor approves, and it shall continue to follow this
policy.

These are the only two stipulations required for this Injunction, and are the only two stipulations
subject to the Court’s continuing jurisdiction. County reserves the right to seek modification of these
stipulations by the court in the future if needed.
Dated: September 26, 2016

LAW OFFICE OF MARK E. MERIN

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/s/ Mark E. Merin

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By: __________________________________
Mark E. Merin

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Attorneys for Plaintiffs
MYRAH MARTINEZ, KITARA MCCRAY,
MADISON MARLENE MARVEL, and R.M.

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Respectfully Submitted,

Dated: September 26, 2016

Respectfully Submitted,

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SENNEFF FREEMAN & BLUESTONE, LLP

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/s/ Bonnie A. Freeman
(as authorized on September 26, 2016)
By: __________________________________
Bonnie A. Freeman

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Attorneys for Defendants County of Sonoma (also sued as
Sonoma County Human Services Department and Sonoma
County Family, Youth and Children’s Services), Jerry
Dunn, Nick Honey and Stacie Kabour

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ORDER ADOPTING STIPULATION OF DISMISSAL AND INJUNCTIVE RELIEF
Martinez v. County of Sonoma; United States District Court, Northern District of California, Case No. 3:15-cv-01953-JST

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[PROPOSED] ORDER
IT IS SO ORDERED.
Dated: September 27, 2016

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_____________________________________
JON S. TIGAR
United States District Judge

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ORDER ADOPTING STIPULATION OF DISMISSAL AND INJUNCTIVE RELIEF
Martinez v. County of Sonoma; United States District Court, Northern District of California, Case No. 3:15-cv-01953-JST