Brantley et al v. Maxwell-Jolly et al

Filing 415

ORDER by Judge ARMSTRONG granting 412 Motion for Settlement (lrc, COURT STAFF) (Filed on 12/14/2011)

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Elissa Gershon, State Bar No. 169741
[e-mail]
Elizabeth Zirker, State Bar No. 233487
[e-mail]
Kim Swain, State Bar No. 100340
[e-mail]
DISABILITY RIGHTS CALIFORNIA
1330 Broadway, Suite 500
Oakland, CA 94612
Telephone: [phone]
Facsimile: 510.267.1201

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IN THE UNITED STATES DISTRICT COURT
FOR THENORTHERN DISTRICT OF CALIFORNIA

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ESTHER DARLING; RONALD BELL by his
guardian ad litem Rozene Dilworth; GILDA
GARCIA; WENDY HELFRICH by her guardian
ad litem Dennis Arnett; JESSIE JONES; RAIF
NASYROV by his guardian ad litem Sofiya
Nasyrova; ALLIE JO WOODARD, by her
guardian ad litem Linda Gaspard-Berry;
individually and on behalf of all others similarly
situated,

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Plaintiffs,
v.
TOBY DOUGLAS, Director of the Department of
Health Care Services, State of California,
DEPARTMENT OF HEALTH CARE
SERVICES,
Defendants.

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Case No.: C-09-03798 SBA
CLASS ACTION
[PROPOSED] ORDER GRANTING
PRELIMINARY APPROVAL OF
SETTLEMENT AGREEMENT,
DIRECTING NOTICE TO THE CLASS,
SETTING A SCHEDULING ORDER
AND FAIRNESS HEARING
Hearing Date:
Time:
Judge:
Hon. Saundra Armstrong
Address:
1301 Clay Street
Oakland, CA 94102
Courtroom:
1, 4th Floor

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DARLING, ET AL. V. DOUGLAS, ET AL., C09-03798 SBA; [PROPOSED] ORDER GRANTING PRELIMINARY
APPROVAL OF SETTLEMENT AGREEMENT, DIRECTING NOTICE TO THE CLASS, SETTING A SCHEDULING
ORDER AND FAIRNESS HEARING

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Kenneth A. Kuwayti, State Bar No. 145384
[e-mail]
Benjamin A. Petersen, State Bar No. 267120
[e-mail]
Morrison & Foerster LLP
755 Page Mill Road
Palo Alto, California 94304-1018
Telephone:
650.813.5600
Facsimile:
650.494.0792

Anna Rich, State Bar No. 230195
[e-mail]
Kevin Prindiville, State Bar No. 235835
[e-mail]
NATIONAL SENIOR CITIZENS LAW
CENTER
1330 Broadway, Suite 525
Oakland, California 94612
Telephone: [phone]
Facsimile:
510.663.1051

Eric Carlson, State Bar No. 141538
[e-mail]
NATIONAL SENIOR CITIZENS LAW CENTER
3435 Wilshire Boulevard, Suite 2860
Los Angeles, CA 90010
Telephone:
213.674.2813
Facsimile:
213.639.0934

Barbara Jones, State Bar No. 88448
[e-mail]
AARP FOUNDATION LITIGATION
200 So. Los Robles, Suite 400
Pasadena, California 91101
Telephone:
626.585.2628
Facsimile:
626.583.8538

Kenneth W. Zeller, Pro Hac Vice
[e-mail]
Kelly Bagby, Pro Hac Vice
[e-mail]
AARP FOUNDATION LITIGATION
601 E Street N.W.
Washington, D.C. 20049
Telephone:
202.434.2060
Facsimile:
202.434.6424

Sarah Somers, State Bar No. 170118
[e-mail]
Martha Jane Perkins, State Bar No. 104784
[e-mail]
NATIONAL HEALTH LAW PROGRAM
101 East Weaver Street, Suite G-7
Carrboro, North Carolina 27510
Telephone:
919.968.6308
Facsimile:
919.968.8855

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Attorneys for Defendants
KAMALA D. HARRIS
Attorney General of California
[e-mail]
SUSAN M. CARSON (CA SBN 135875)
Supervising Deputy Attorney General
[e-mail]
455 Golden Gate Avenue, Suite 1100
San Francisco, California 94102-7004
Telephone: [phone]
Facsimile: 415.703.5480

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ii
DARLING, ET AL. V. DOUGLAS, ET AL., C09-03798 SBA; [PROPOSED] ORDER GRANTING PRELIMINARY
APPROVAL OF SETTLEMENT AGREEMENT, DIRECTING NOTICE TO THE CLASS, SETTING A SCHEDULING
ORDER AND FAIRNESS HEARING

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Plaintiffs Esther Darling, Ronald Bell by his Guardian ad Litem, Rozene Dilworth, Gilda

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Garcia,Wendy Helfrich by her Guardian ad Litem, Dennis Arnett, Jessie Jones, Raif Nasyrov by his

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Guardian ad Litem, Sofiya Nasyrova, and Allie Jo Woodard by her Guardian ad Litem, Linda

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Gaspard-Berry, (“Plaintiffs”), and Defendants Toby Douglas and the Department of Health Care

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Services (DHCS), (“Defendants”) have filed a Joint Request for Preliminary Approval of Settlement

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Agreement, Directing Notice to the Class, Setting a Scheduling Order and Fairness Hearing.

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The Court, having considered the joint moving papers of the Parties and the Settlement
Agreement and proposed notice to the class submitted therewith, for good cause appearing,1
IT IS HEREBY ORDERED THAT:
1.

The parties’ joint motion for preliminary approval (Dkt. 414) is GRANTED. The

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proposed settlement set forth in the Settlement Agreement attached as Exhibit 1 to the declaration of

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Elissa Gershon and attached hereto, and the proposed modification of the class definition set forth

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therein, are preliminarily approved as being within the range of reasonableness such that notice

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should be given to the Settlement Class.

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2.

For settlement purposes only, pursuant to Federal Rule of Civil Procedure 23(a) and

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23(b)(2), the Court conditionally certifies the following Settlement Class: “All Medi-Cal

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beneficiaries in the State of California for whom Adult Day Health Care benefits will be eliminated

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under the provisions of AB 97 including those who met or will meet the current eligibility and

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medical necessity criteria for ADHC at any point prior to the Effective Date of this Settlement; or

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who will meet the eligibility and medical necessity criteria for CBAS at any point prior to

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Termination of this Agreement.”

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3.

For settlement purposes only, the Court appoints Wendy Helfrich, Jessie Jones, Raif

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Nasyrov, Esther Darling, Ronald Bell, Gilda Garcia, and Allie Jo Woodard are Class Representatives

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for the Settlement Class.

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The Court, in its discretion, finds this matter suitable for resolution without a hearing. See
Fed. R. Civ. P. 78(b); N.D. Cal. Civ. L.R. 7-1(b).

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DARLING, ET AL. V. DOUGLAS, ET AL., C09-03798 SBA; [PROPOSED] ORDER GRANTING PRELIMINARY APPROVAL
OF SETTLEMENT AGREEMENT, DIRECTING NOTICE TO THE CLASS, SETTING A SCHEDULING ORDER AND FAIRNESS
HEARING

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4.

For settlement purposes only, the Court appoints Disability Rights California,

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National Health Law Program, National Senior Citizens Law Center, AARP Foundation Litigation,

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and Morrison & Foerster LLP as Class Counsel for the Settlement Class.

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5.

The contents of the class notice, attached as Exhibit 2 to the declaration of Elissa

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Gershon (as subsequently modified) and attached hereto, is adequate under Rule 23 of the Federal

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Rules of Civil Procedure and approved as to form. The parties shall provide class members with

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notice in the form and in the manner specified in the Settlement Agreement and Joint Motion.

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6.

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The parties shall adhere to the following general time schedule:
a.

Notice to the class shall be mailed, posted and/or published in the manner

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specified in the Settlement Agreement and Joint Motion by December 14, 2011 or as soon as

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reasonably practicable thereafter;

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b.

Each class member shall have until January 10, 2012, in order to file an

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objection and/or provide notice of intent to appear, as the case may be, under the procedures

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specified in the Settlement Agreement, Joint Motion, and Notice to Class. Such date shall be

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determined by the postmark of the document filed;

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7.

The Court finds that the forms of notice to Plaintiff Settlement Class Members

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regarding the pendency of the litigation and of this settlement, including the methods of

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dissemination to the proposed Plaintiff Settlement Class Members in accordance with the terms of

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this order, constitute the best notice practicable under the circumstances.

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8.

Plaintiffs shall file a Notice of Motion and Motion, and Points and Authorities in

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Support of the Parties' Agreement re Attorneys' Fees and Costs ("Fee Motion") no later than

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December 14, 2011. Defendants shall file a Notice of Non-Opposition to Plaintiffs' Fee Motion no

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later than December 28, 2011.

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9.

The Parties shall file a Joint Motion for Final Approval of the Settlement, including

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Certification of the Settlement Class no later than January 17, 2012. The filing shall include all

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papers in support of the Joint Motion for Final Approval of the Settlement and/or response(s) to any

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DARLING, ET AL. V. DOUGLAS, ET AL., C09-03798 SBA; [PROPOSED] ORDER GRANTING PRELIMINARY APPROVAL
OF SETTLEMENT AGREEMENT, DIRECTING NOTICE TO THE CLASS, SETTING A SCHEDULING ORDER AND FAIRNESS
HEARING

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valid and timely objection with the Court. The Parties shall serve copies of such papers upon any

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objector who has complied with the provisions of Paragraph 6.b. of this Order.

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10.

The Court shall conduct a Fairness Hearing regarding final approval of the Settlement

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Agreement and Plaintiffs’ Fee Motion on January 24, 2012 at 1:00 p.m. to hear any objections to the

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Settlement, and to consider and determine whether the proposed settlement of the litigation on the

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terms set forth in the Settlement Agreement should be approved as fair, just, reasonable, adequate

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and in the best interests of the Plaintiff Settlement Class; whether Plaintiffs’ Counsels’ attorneys’

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fees and reimbursement of expenses should be approved; and whether the Order approving the

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settlement should be entered.

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IT IS SO ORDERED.

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Dated: 12-13-11
Honorable Saundra Brown Armstrong
United States District Judge

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DARLING, ET AL. V. DOUGLAS, ET AL., C09-03798 SBA; [PROPOSED] ORDER GRANTING PRELIMINARY APPROVAL
OF SETTLEMENT AGREEMENT, DIRECTING NOTICE TO THE CLASS, SETTING A SCHEDULING ORDER AND FAIRNESS
HEARING

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UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF CALIFORNIA
If you are in Medi-Cal and receive (or recently received) Adult Day Health
Care (ADHC), this is a Notice of a Class Action Settlement Which May
Affect You.
A federal court authorized this notice. This is not a solicitation from a lawyer.
A lawsuit was filed asking the Court to stop California from ending the Medi-Cal
ADHC program unless other services were in place for people receiving ADHC
services. The parties to the lawsuit have reached a settlement of the lawsuit. If
the settlement is approved by the Court, the ADHC program will end on February
29, 2012. Beginning March 1, 2012, you will receive other services depending
on your situation. A full description of services which will be available and who
will qualify for which services is set forth below. Also listed below is information
about the Settlement Agreement that should answer the questions you have
about it and a place to contact if you have more questions.
This Settlement will not affect your ability to continue to see your primary care
provider if you are currently in Medicare. The services that are available under
the settlement agreement will be in addition to the services you currently receive
through Medicare.
This case is not one for money damages.
The Court still has to decide whether to approve the Settlement Agreement.
This Notice explains your rights and your options – and the deadlines to
act on them. READ THIS NOTICE CAREFULLY.
YOUR LEGAL RIGHTS AND OPTIONS IN THIS SETTLEMENT
If you do nothing, the court will evaluate the Settlement
DO NOTHING
without your comments. You will give up the right to
challenge the end of the ADHC program in another
lawsuit. If you receive ADHC services now, you do not
have to respond to this Notice to get the services
created by this Settlement.
Write to the Court about why you don’t like the
OBJECT IN WRITING BY
Settlement. In addition, you may ask to speak in Court
JANUARY 10, 2012
about your objections. Your objection must be sent to
the Court by January 10, 2012 to be considered.
If you want to speak at the Fairness Hearing, make sure
GO TO THE FAIRNESS
HEARING ON JANUARY 24, to say that in your letter to the Court. However, you do
not have to appear at the Fairness Hearing for your
2012.
objection to be considered.

NOTICE OF CLASS ACTION SETTLEMENT AGREEMENT
Darling et al. v. Douglas et al., C09-03798 SBA

1.

Why am I getting this Notice?

You are getting this notice because you are now receiving or, at some point since
July 1, 2011, have received Medi-Cal Adult Day Health Care (AHDC) services
and are considered a Class Member in this lawsuit.
You have a right to know about a proposed settlement of a class action lawsuit,
and about your options, before the Court decides whether to approve the
Settlement. This Notice explains the lawsuit, what Class Members will get if the
Court approves the Settlement, and your legal rights regarding the Settlement.
The Court in charge of the case is the United States District Court for the
Northern District of California. The case is named Darling et al. v Douglas et al.
The Case Number is C:09-03798 SBA. The seven ADHC participants who sued
are called named Plaintiffs, and the Defendants are the Department of Health
Care Services (DHCS) and its Director Toby Douglas. All other individuals who
receive ADHC services are called Class Members.

2.

What is this lawsuit about?

In 2009, people receiving Medi-Cal Adult Day Health Care (ADHC) (the Plaintiffs)
sued the Defendants. They asked the Court to stop Defendants from reducing
ADHC services, which it did. In 2011, the Plaintiffs asked the Court to stop the
Defendants from ending the ADHC benefit. They argued that, unless Defendants
provided services to replace ADHC, ending the program would violate the
Americans with Disabilities Act (ADA) and other laws. The State Defendants
deny these arguments.

3.

Why is this a class action?

In a class action, one or more people, called Class Representatives or named
plaintiffs, sue on behalf of people who have similar claims. All of these people are
Class Members. One court resolves the issues for all Class Members. In this
case, Esther Darling and the other named Plaintiffs sued on behalf of everyone
receiving the Medi-Cal ADHC benefit. Any decision by the Court in this case will
affect all Class Members.

4.

Why is there a settlement?

The Plaintiffs and Defendants have agreed to a settlement in which they have
worked together to design new programs to replace the ADHC program. The
Class Representatives and the Plaintiffs’ attorneys think the Settlement is fair. A
Fairness Hearing to approve the final settlement will be held in the U.S.

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NOTICE OF CLASS ACTION SETTLEMENT AGREEMENT
Darling et al. v. Douglas et al., C09-03798 SBA
District Court in Oakland on January 24, 2012 at 1:00 p.m. See questions
14-17 below for more information about the Court hearing.

5.

How do I know if I am part of the settlement?

You are a class member and are part of the Settlement if you fit this description:
“All Medi-Cal beneficiaries in the State of California for whom Adult
Day Health Care benefits will be eliminated under the provisions of
AB 97 including those who met or will meet the current eligibility and
medical necessity criteria for ADHC at any point prior to the Effective
Date of this Settlement; or who will meet the eligibility and medical
necessity criteria for CBAS at any point prior to Termination of this
Agreement.”
This means you are covered by the Settlement if you would have had your MediCal ADHC benefit eliminated by Assembly Bill 97 (AB 97) or you will qualify for
ADHC before March 1, 2012. It also means that people who qualify for the new
program, Community Based Adult Services (CBAS), will be covered by the
Settlement. “AB 97” (Assembly Bill 97) is a new law that eliminated ADHC as a
Medi-Cal benefit.

6.

What does the Settlement provide?

Under the Settlement Agreement, DHCS will set up a new Medi-Cal program
called Community Based Adult Services (“CBAS”).
 CBAS allows eligible people in Medi-Cal to get skilled nursing care,
social services, therapies, personal care, family/caregiver training and
support, meals, transportation, and case management in one central
location.
 CBAS will be available at some former ADHC centers that are approved
by DHCS as CBAS providers.
 CBAS will start on March 1, 2012.
The Settlement will set up “Enhanced Case Management” for those who were in
ADHC, but who do not qualify for CBAS.
 Enhanced Case Management will help eligible people get the medical
and social services they need once ADHC ends. You will have a say in
what services they get and how they get them.
ADHC services will continue until February 29, 2012 to give people time to
change from getting their services from ADHC providers to getting their services

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NOTICE OF CLASS ACTION SETTLEMENT AGREEMENT
Darling et al. v. Douglas et al., C09-03798 SBA
from CBAS providers or to begin receiving Enhanced Case Management. All
class members will receive either CBAS or Enhanced Case Management.
This is not a case for money damages, so no Plaintiffs or Class Members will
receive payment for being part of the lawsuit.

7.

What happens to me under the Settlement?

 If you have Medi-Cal and are in ADHC now:
o You will be assessed for CBAS sometime between December
2011 and February 2012. Your ADHC provider will give you more
information about the assessment process.
o If you qualify for CBAS, you will receive these services as soon
as ADHC services end, March 1, 2012.
o If you do not qualify for CBAS, February 29, 2012 will be your last
day of ADHC services. You will get Enhanced Case Management
services to help you transition to other services that you need.
 If you have Medi-Cal but are not in ADHC now:
o You may still apply for ADHC until February 29, 2012.
o You may ask to be assessed for CBAS.

8.

How do I know if I qualify for CBAS?

You can receive CBAS if you are in Medi-Cal AND currently qualify for ADHC,
AND:
 Need enough nursing to meet “Nursing Facility Level of Care A” (NF-A)
or above; OR
 Have a moderate to severe cognitive impairment, including moderate to
severe Alzheimer’s Disease or other dementia; OR
 Have a developmental disability; OR
 Have a mild to moderate cognitive disability, including Alzheimer’s or
dementia AND need assistance or supervision with two of the following:
bathing, dressing, self-feeding, toileting, ambulation, transferring,
medication management, or hygiene; OR
 Have a chronic mental illness or a brain injury AND need assistance or
supervision with two of the following: bathing, dressing, self-feeding,

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NOTICE OF CLASS ACTION SETTLEMENT AGREEMENT
Darling et al. v. Douglas et al., C09-03798 SBA
toileting, ambulation, transferring, medication management, and
hygiene; OR one need from the above list and one of the following:
money management, accessing resources, meal preparation, and
transportation.

9.

If I am assessed and I qualify, do I automatically get CBAS?

Yes. Once you are found eligible for CBAS, you will get instructions on how to
enroll if there is a CBAS center where you live. If there is no CBAS center where
you live, you will be able to get the services that are offered at CBAS centers, but
from other providers.
 Between March 1, 2012 and approximately July 1, 2012, CBAS will be
available through regular Medi-Cal. Eventually, CBAS will mostly be
available through Medi-Cal managed care.
 Once CBAS is mostly available only through Medi-Cal managed care, if
you live in a county that offers Medi-Cal managed care, and you qualify
to enroll in a managed care plan, you may ONLY get CBAS through
managed care.
o If you enroll in Medi-Cal managed care any time before July 1,
2012, or if you are already enrolled in Medi-Cal managed care,
your managed care plan will pay for CBAS when it becomes a
managed care option. You will not need to make any changes to
continue to get CBAS.
o If you could be enrolled in Medi-Cal managed care but are not
now, you will have to enroll to continue to get CBAS when it
becomes available through Medi-Cal managed care.
o If you get Medicare, enrollment into Medi-Cal managed care
WILL NOT affect your ability to choose your Medicare doctors.
 If you live in a county that does not have Medi-Cal managed care or
you cannot get managed care, you do not need to make any changes
to continue to get CBAS. You may continue to receive CBAS as a
regular Medi-Cal benefit.

10.

Will I Be Able to Go to the Same Center to Get CBAS?

It depends. Many ADHC centers will be able to offer CBAS. ADHC centers can
apply to the state to become CBAS providers. If you qualify for CBAS and your
ADHC center is approved to be a CBAS provider by February 29, 2012, you will
be able to keep receiving services at the same center once ADHC ends. If your

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NOTICE OF CLASS ACTION SETTLEMENT AGREEMENT
Darling et al. v. Douglas et al., C09-03798 SBA
ADHC center does not become a CBAS provider, you will be given information
about other CBAS providers.

11.

What if I don’t qualify for CBAS?

If you are in ADHC, but don’t qualify for CBAS, you will get “Enhanced Case
Management” to help you get the medical and social services you need after
ADHC ends. Case managers in this program will work with you so that you have
a say as to what services you get and how you get them.
You will have the choice to receive Enhanced Case Management as a regular
Medi-Cal service or through Medi-Cal managed care.

12.

Do I have a lawyer in the case?

Yes. Disability Rights California, the National Senior Citizens Law Center, the
National Health Law Program, AARP Foundation Litigation, and the law firm of
Morrison & Foerster LLP were approved by the Court to represent you and other
Class Members. Together, the lawyers are called Class Counsel. You will not be
charged for these lawyers.

13.

How will the lawyers be paid?

If the Settlement is approved, the Defendants will pay attorneys’ fees to plaintiffs’
attorneys for their work on this case. The Court must approve the amount of
fees. Plaintiffs and Defendants will ask the court to approve fees of $2.2 million
for the work done over the last 2-1/2 years. They will also ask the Court to
approve up to $400,000 for Plaintiffs’ lawyers to monitor the settlement over the
next 2-1/2 years. You do not need to pay the attorneys.

14.

What are my options about the Settlement?

You may do nothing, and you will remain a Class Member. You may write a
letter to the Court stating the reasons why you do not like the Settlement, and
mail it by January 10, 2012. If you want to speak at the Fairness Hearing on
January 24, 2012, you MUST say that in your letter. It is up to the Court whether
you will be permitted to speak at the hearing. However, you do not have to
appear in Court on January 24, 2012 in order for your objection to be considered.

15.

If the Settlement is approved, what does that mean?

If this Settlement is approved, you will be able to get either CBAS or Enhanced
Case Management depending on your situation. You will not be able to be part of
another lawsuit about whether California can end the Medi-Cal ADHC benefit.

6

NOTICE OF CLASS ACTION SETTLEMENT AGREEMENT
Darling et al. v. Douglas et al., C09-03798 SBA
16.

How do I tell the court if I don’t like the Settlement?

If you’re a Class Member, you can tell the Court that you do not agree with the
Settlement or with any part of it by sending a letter with your objections by
January 10, 2012. You may write the letter yourself or through an attorney at
your own expense.
To object, you must send a letter to the Court saying that you object and explain
the reasons for your objection. At the top of the letter, be sure to include your
name, address, telephone number, and write “Darling v. Douglas, C 09-3798
SBA.” Be sure to sign your letter.
Mail the original letter to the Clerk of the Court and copies of the letter to the
attorneys for the parties. The objection must be mailed to these three different
places postmarked no later than January 10, 2012:
Clerk of the Court:
U.S. District Court
1301 Clay Street
Oakland, CA 94612
Reference: Darling
et al. v. Douglas et
al., Case No. C0907398 SBA

17.

Attorneys for Class
Members:
Elissa Gershon
Disability Rights California.
1330 Broadway, Suite 500,
Oakland, CA 94612
ATTN: Darling v. Douglas

Attorneys for DHCS:
Susan M. Carson
Office of the Attorney
General
455 Golden Gate
Avenue,
Suite 11000
San Francisco, CA
94102-7004

When and where will the Court decide whether to approve the
Settlement?

The Court will hold a “Fairness Hearing” to decide whether to approve the
settlement on January 24, 2012 at 1:00 p.m. The Court will consider whether
the settlement is fair, reasonable, and adequate. The Judge will listen to Class
Members who have asked to speak at the hearing. You may attend even if you
do not wish to speak. The hearing will take place at:
United States District Court
Northern District of California
1301 Clay Street
Courtroom 1, 4th Floor
Oakland, CA 94612

7

NOTICE OF CLASS ACTION SETTLEMENT AGREEMENT
Darling et al. v. Douglas et al., C09-03798 SBA
18.

What happens if I do nothing at all?

If you do nothing, you will remain a class member. If this Settlement is approved,
you will be able to get CBAS or Enhanced Case Management depending on your
situation. You will not be able to be part of another lawsuit about whether
California can end the Medi-Cal ADHC benefit.
GETTING MORE INFORMATION

19.

How do I get more details about the Settlement?

To get more information, a copy of the Settlement Agreement, or help in making
an objection to the Court, you may contact Disability Rights California:
[e-mail]

20.

[phone]

How do I get more information about the case?

You can get more information about the case by looking at the case file located
in the office of the Clerk of the U.S. District Court located at the address listed in
question 17. You can also look at the full settlement and get other information at:
 http://www.disabilityrightsca.org/advocacy/Darling-v-Douglas/index.html
OR
 http://www.dhcs.ca.gov/services/medi-cal/Pages/ADHC/ADHC.aspx

21.

How do I get copies of this notice in other languages or in
formats that accommodate people with disabilities?

If you need a copy of this notice in another language, have a disability and need
an accommodation such as an alternate format for notice (for example, Braille, or
large print), or an alternate way to ask questions about the notice (for example, a
sign language interpreter), you can:
 Contact Plaintiffs’ attorney Disability Rights California at [phone];
OR
 Visit the Disability Right California or DHCS websites listed in Question 20.

8