J. et al v. City and County of San Francisco et al

Filing 85

Order by Magistrate Judge Lisa J. Cisneros granting 84 Stipulation re Plaintiffs' Juvenile Records.(bns, COURT STAFF) (Filed on 8/30/2024)

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DAVID CHIU, State Bar #189542
City Attorney
JENNIFER E. CHOI, State Bar #184058
Chief Trial Deputy
SABRINA M. BERDUX, State Bar #248927
MARGARET S. SCHROEDER, State Bar #178586
ZUZANA S. IKELS, State Bar #208671
Deputy City Attorneys
Fox Plaza
1390 Market Street, Sixth Floor
San Francisco, California 94102-5408
Telephone:
[phone] [Berdux]
[phone] [Schroeder]
[phone] [Ikels]
Facsimile:
[phone]
E-Mail:
[e-mail]
[e-mail]
[e-mail]
Attorneys for Defendants
CITY AND COUNTY OF SAN FRANCISCO; WILLIAM SCOTT;
THOMAS HARVEY; and MATT SULLIVAN

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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J.T., through her father and guardian SAMER
TA WASHA; L.R., through her mother and
guardian GWEN LEE; C.L., through her
mother and guardian NAOMI LOPEZ, ON
BEHALF OF THEMSELVES AND ALL
OTHERS SIMILARLY SITUATED,
Plaintiffs,

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vs.
CITY AND COUNTY OF SAN
FRANCISCO, WILLIAM SCOTT, THOMAS
HARVEY, MATT SULLIVAN, and DOES 1100,
R.P.,

Case No. 23-cv-06524-LJC
Case No. 24-cv-00522-LJC
STIPULATION AUTHORIZING THE
DISCLOSURE OF PLAINTIFFS' JUVENILE
RECORDS AND ORDER REGARDING
PRODUCTION OF INDIVIDUAL
PLAINTIFFS' JUVENILE RECORDS
Re: Dkt. No. 79 (23-cv-06524)
Re: Dkt. No. 45 (24-cv-00522)
Trial Date:

Not Set

Defendants.
Plaintiff,
vs.

CITY AND COUNTY OF SAN
FRANCISCO,
Defendant.
Stipulation and Order re Juvenile Records Case No.
23-cv-06524-LJC and Case No. 24-cv-00522

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Pursuant to the August 14, 2024 Order regarding Discovery Letters (Dkt. No. 79) requiring
Plaintiffs to stipulate to the release and production of their Juvenile Records, Plaintiffs J.T., through
her father and guardian Samer Tawasha; L.R., through her mother and guardian Gwen Lee; C.L.,
through her mother and guardian Naomi Lopez, and Plaintiff R.P., through his guardian and mother,
Thidia Penia, along with all other guardians and parents, including attorneys of record (collectively,
"Plaintiffs") and Defendants City and County of San Francisco, William Scott, Thomas Harvey, and
Matt Sullivan (collectively, "City Defendants") stipulate as follows:
1.

Plaintiffs expressly authorize the disclosure of their individual juvenile records,

including but not limited to the incident report, arrest record, and Body Worn Camera video of them,
in this litigation (collectively, the "Juvenile Records"). Plaintiffs waive, forfeit and relinquish any and
all rights or claims related to the mere production and disclosure of their Juvenile Records in this
litigation, under federal or state law, including under the California Welfare and Institutions Code,
Health and Safety Code, and California privacy laws.
2.

Plaintiffs agree and stipulate that their Juvenile Records shall be designated as

"Confidential," and not "Attorneys Eyes Only," and will be used, filed and treated in this litigation in
accordance with the terms of the Protective Order. Plaintiffs waive all rights or claims that the records
will be shielded from production based on rights of privacy under federal law, the California
Constitution or California law, including, but not limited to, the Welfare and Institutions Code, Civil
Code, Penal Code and Health and Safety Code. Plaintiffs expressly waive and agree the City
Defendants are immunized from any and all liability, legal theory, relief and/or claim of any kind
related to the mere production of their Juvenile Records in this litigation.
Dated: August 22, 2024
By: Sa mer Tawasha (Aug 26, 2024 19:00 PDT)
Samer Tawasha (J.T. guardian and parent)

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Dated: August 22, 2024
By:_______________
Anna Vega (J.T. guardian and parent)
Stipulation and Order re Juvenile Records Case No.
23-cv-06524-LJC and Case No. 24-cv-00522

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Pursuant to the August 14, 2024 Order regarding Discovery Letters (Dkt. No. 79) requiring
Plaintiffs to stipulate to the release and production of their Juvenile Records, Plaintiffs J.T., through
her father and guardian Samer Tawasha; L.R., through her mother and guardian Gwen Lee; C.L.,
through her mother and guardian Naomi Lopez, and Plaintiff R.P., through his guardian and mother,
Thidia Penia, along with all other guardians and parents, including attorneys of record (collectively,
"Plaintiffs") and Defendants City and County of San Francisco, William Scott, Thomas Harvey, and
Matt Sullivan (collectively, "City Defendants") stipulate as follows:
1.

Plaintiffs expressly authorize the disclosure of their individual juvenile records,

including but not limited to the incident report, arrest record, and Body Worn Camera video of them,
in this litigation (collectively, the "Juvenile Records"). Plaintiffs waive, forfeit and relinquish any and
all rights or claims related to the mere production and disclosure of their Juvenile Records in this
litigation, under federal or state law, including under the California Welfare and Institutions Code,
Health and Safety Code, and California privacy laws.
2.

Plaintiffs agree and stipulate that their Juvenile Records shall be designated as

"Confidential," and not "Attorneys Eyes Only," and will be used, filed and treated in this litigation in
accordance with the terms of the Protective Order. Plaintiffs waive all rights or claims that the records
will be shielded from production based on rights of privacy under federal law, the California
Constitution or California law, including, but not limited to, the Welfare and Institutions Code, Civil
Code, Penal Code and Health and Safety Code. Plaintiffs expressly waive and agree the City
Defendants are immunized from any and all liability, legal theory, relief and/or claim of any kind
related to the mere production of their Juvenile Records in this litigation.
Dated: August 22, 2024

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By:_____________
Samer Tawasha (J.T. guardian and parent)

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Dated: August 22, 2024
By.• liAnna Vega (J.T. guardian and parent)

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AnaVtga!Aug2'4,102418:J�PDTI

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Stipulation and Order re Juvenile Records Case No.
23-cv-06524-LJC and Case No. 24-cv-00522

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Dated: August 22, 2024
By: � 2024 11:06 PDT)
Naomi Lopez (C.L. guardian and parent)

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Fernando looez

Dated: August 22, 2024

Fernando Lopez (Aug 26, 2of4 11:13 PDT)

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By:____________
Fernando Lopez (C.L. guardian and parent)

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Dated: August 22, 2024

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By:____________
Thidia Penia (R.P. guardian and parent)

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IO

Dated: August 22, 2024

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By:____________
(R.P. guardian and parent)

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Dated: August 22, 2024

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By. en Lee (Aug 26, 2024 12:43 PDT)
Gwen Lee (L.R. guardian and parent)

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Dated: August 22, 2024
By: Rocco Rios (Aug 29, 2024 08:32 PDT)
Rocco Rios (L.R. guardian and parent)

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Dated: August 22, 2024

DAVID CHIU
City Attorney
JENNIFER E. CHOI
Chief Trial Deputy
SABRINA M. BERDUX
MARGARET S. SCHROEDER
ZUZANA S. IKELS
Deputy City Attorneys

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By: _____________
SABRINA M. BERDUX

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Attorneys for Defendants
CITY AND COUNTY OF SAN FRANCISCO;
WILLIAM SCOTT; THOMAS HARVEY; and
MATT SULLIVAN

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Stipulation and Order re Juvenile Records Case No.
23-cv-06524-LJC and Case No. 24-cv-00522

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/s/ Sabrina M. Berdux

/s/ Rachel Lederman

/s/ Gabriela M. Lopez

/s/ Bobbie Stein

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PURSUANT TO STIPULATION, IT IS SO ORDERED.

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August 30, 2024
DATED: ________________________

_____________________________________
Hon. Lisa J. Cisneros
United States Magistrate Judge

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Stipulation and Order re Juvenile Records Case No.
23-cv-06524-LJC and Case No. 24-cv-00522

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