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8

UNITED STATES DISTRICT COURT

9

FOR THE CENTRAL DISTRICT OF CALIFORNIA

10

11

K.L., by her Guardian Ad Litem Osiel Lopez; et al.,

12

Plaintiffs,

13 vs.

14 CITY OF GLENDALE; et al.,

15

Defendants.

16

17

) CASE NO.:

) CV-11-08484 ODW (SHx)

)

) )

CLASS ACTION

) ) ) ) ) ) )

ORDER GRANTING REQUEST FOR DISMISSAL AND VACATING THE ORDER TO SHOW CAUSE HEARING

)

18

In accordance with Plaintiffs’ request, the Court DISMISSES WITH

19 PREJUDICE the claims against Defendants the County of Los Angeles, Gilda

20 Davis, and Thomas Van Hoof. Because all Plaintiffs have reached the age of

21 majority, the case no longer involves any minor and no minor’s compromises are

22 needed for its resolution. See Central District Local Rule 83-5.1. The Court,

23 however, retains jurisdiction to enforce the terms of the settlement agreement for a

24 period of one year from the date of this order.

25

It is so ORDERED.

26

27 Dated: September 16, 2013

HONORABLE

28

United

______________________________ OTIS D. WRIGHT, II
States District Judge

 
 Case 2:11-cv-08484-ODW-SH Document 11 Filed 10/17/11 Page 1 of 24 Page ID #:36

1 David B. Sapp (SBN 264464) dsapp@ac1u-sc.org
2 Peter Bibring (SBN223981) pbibring@ac!u-sc.org.
3 ACLU FOUNDATION OF SOUTHERN CALIFORNIA
4 1313 West Eighth Street Los An.zeles California 90017
5 T: (21.1) 977-9500, F: (213) 977-5297

6 Bert Voorhees (SBN 137623) bv@tvlega1.com
7 TRABER & VOORHEES 128 N. Fair Oaks, Suite 204
8 Pasadena, CA 91103 T: (626) 585-9611, F: (626) 585-1400

9 Attorneys for Plaintiffs

10

UNITED STATES DISTRICT COURT

11

FOR THE CENTRAL DISTRICT OF CALIFORNIA

12 K;.~ by her Guardian Ad Litem Osiel Lopez~

13

Al'oHHONY PARKER; Ad Litem Juana Farfan;

Lc..PM. .,bbyyhihsisGuGauradridainaLn~

14 Ad Litem Christine Clavesilla; GIOVANNI

PABLO; A.F. by her Guardian Ad Litem

15 Cristina Pablo; and ALEJANDRO

BARAJAS, on behalf of themselves and all

16 those similarly situated,

17

Plaintiffs,

COMPLAINT FOR INJUNCTIVE RELIEF, DECLARATORY RELIE:[, AND DAMAuES

18

vs.

JURY TRIAL DEMANDED

19 ACINTGYEOLFESG;LCEINTYDAOLFE1',CosOAUNNGTYELOEFS;LOS
20 MICHAEL ROCK, in his individual and official capacities; OFFICER RILEY...,in his
21 individual capacity; OFFICER BICKtLLS, his individual capacity; OFFICER
22 8UINTERO, his indiVIdual capacity; FFICER PARK"This individual capacity;
in 23 THOMAS VAN tlOOF, in his official and individual capacity; GILDA DAVIS" her 24 individual capacity; JENNIFER EAKL in her
individual and ofticial capacities; HAGOP 25 EULMESSEKIA1t, in his individual capacity;
CAROLINE SWEtNE~ in her individual 26 capacity; ARA MGRDIcHIAN in his
inClividuru capacity; ALEX GAikTA, in his 27 individual capacity; and DOES 1- \0, in their
individual capacitIes,
28

Case 2:11-cv-08484-ODW-SH Document 11 Filed 10/17/11 Page 2 of 24 Page ID #:37

1

INTRODUCTION!

2

1. It is not against the law to be a Latino high school student. Yet, on

3 Friday, September 24, 20 I0, administrators at Hoover High School ("HHS") in

4 Glendale, California, in coordination with officers from the Glendale Police

5 Department ("GPD"), the Los Angeles Police Department ("LAPD"), and the Los

6 Angeles County Probation Department ("Probation Department"), acted as though

7 it were, when they rounded up, interrogated, photographed, and collected personal

8 information from approximately 56 students solely because they are or appear to

9 be Latino.

10

2. At the start of the lunch period, school administrators rounded up

11 students into two classrooms, where approximately a dozen armed uniformed and

12 plainclothes police officers were stationed. Police, probation officers, and school

13 administrators proceeded to detain the students for between 30 and 90 minutes.

14 During that time, the police officers interrogated the students about their personal

15 information and activities, forced them to pose for mock "mug shots," threatened

16 them with recurring police visits, told students to "sit down and shut up" when they

17 asked why they were being detained, and in some cases searched students and their

18 belongings without consent. Police and administrators told the students that they

19 could not leave until they had submitted to interrogation, and enforced this order

20 with armed police officers stationed around the classrooms and by the classroom

21 doors.

22

3. During their detention, police officers told various students that they

23 could no longer eat lunch at certain tables on school property; that they could no

24 longer spend time with their Latino classmates who had also been targeted; that the

25

26 1 The allegations of this Complaint are based on information and belief, unless 27 otherwise specified.

28

1

Case 2:11-cv-08484-ODW-SH Document 11 Filed 10/17/11 Page 3 of 24 Page ID #:38

1 police officers would show up at their houses at 6 a.m. if the students did not

2 provide their personal information as the officers demanded; that they were on a

3 "gang list" and that the police would keep their photographs and information

4 collected during the operation on file; that if the students got in trouble in the

5 future, the police would easily identify them based on the information they were

6 collecting; and that their personal information was being collected so that the

7 officers could assess whether the students were "on the right path."

8

4. At the time they were targeted, the students were doing nothing

9 wrong. They were not violating any laws or school rules, and the school officials

10 and law enforcement officers who conducted the operation had no basis to believe

11 any of the students were engaged in unlawful conduct.

12

5. All of the students whom Defendants targeted are or appear to be

13 Latino, even though the student body at HHS is only about 25 percent Latino.

14 Additionally, in identifying students who were to be detained in a classroom on the

15 first floor of HHS, HHS administrators ordered a group of Latino males sitting at a

16 cluster of tables to report to a classroom, while allowing another student sitting at

17 those tables, who does not appear to be Latino, to remain outside. Although this

18 student regularly sits with the group of Latino students, he was not required to

19 report to the classroom because he does not appear to be Latino. Finally,

20 Defendant Michael Rock, a captain in GPD who approved the operation,

21 responded to concerns that Defendants had targeted only Latino students by stating

22 that, at the time Defendants planned and executed the roundup of the Latino

23 students, they planned to conduct a similar operation targeting Armenian students.

24

6. This operation was illegal and violated the rights of the students

25 whom Defendants targeted. It also was harmful to the students, many of whom

26 were terrified and intimidated by the show of force and believed they might be

27 arrested, even though they had broken no laws and had not violated any school

28 rules. Finally, the operation undermined trust between school officials and law

2

Case 2:11-cv-08484-ODW-SH Document 11 Filed 10/17/11 Page 4 of 24 Page ID #:39

I enforcement officers, on the one hand, and students, parents and the community,

2 on the other hand. Those harms were compounded by the refusal of administrators

3 at HHS and within Glendale Unified School District and supervisory officers

4 within GPD and LAPD to confirm, in writing, that any information collected by

5 HHS or the police during the September 24 operation had been destroyed or to

6 acknowledge formally that the operation was a mistake and that similar operations

7 would not occur in the future.

8

7. The government employees who planned, coordinated, and executed

9 this operation acted under color of state law and used their positions of authority

10 not only to violate the rights of Plaintiffs and their peers, but also to intimidate

11 students, most of whom were minors, into changing behavior that was not illegal

12 and forcing them to stop hanging out with certain other students at HHS, even

13 though they were not breaking any laws by associating with their friends. This

14 outrageous conduct is all the more offensive because it occurred at school, which is

15 supposed to be a safe place with a welcoming environment that supports academic

16 success, and occurred with the active involvement of school administrators, who

17 are supposed to be educators first and foremost. In a free society, such coercive

18 tactics cannot and should not be tolerated.

19

8. Although each Defendant took an active role in planning and

20 executing the roundup, the plan for the roundup was based on similar roundups

21 that Los Angeles County Probation officers regularly plan and conduct at other

22 schools.

23

9. Plaintiffs seek injunctive relief and declaratory relief on behalf of

24 themselves and a class of similarly situated students whom Defendants subjected to

25 detention, interrogation, threats, photographing, and in some cases search, because

26 of their race and without their consent, at Hoover High School on September 24,

27 2010. Additionally, the named Plaintiffs seek compensatory and punitive damages

28 for themselves against Defendants for the violations of numerous rights during the

3

Case 2:11-cv-08484-ODW-SH Document 11 Filed 10/17/11 Page 5 of 24 Page ID #:40

I September 24 roundup.

2

3

JURISDICTION

4

10. Plaintiffs' claims for declaratory, injunctive, and monetary relief are

5 brought pursuant to the Fourth, and Fourteenth Amendments to the Constitution of

6 the United States; 42 U.S.C. § 1983; 42 U.S.C. § 1985; Article I, Sections 7 and 13

7 of the California Constitution; and Cal. Civ. Code §§ 52 and 52.1.

8

II. This Court has jurisdiction over Plaintiffs' federal claims under 28

9 U.S.C. §§ 1331, 1343, and 2201. The Court has supplemental jurisdiction over the

10 state law claims alleged in this complaint pursuant to 28 U.S.C. § 1367.

II Declaratory relief is authorized under 28 U.S.C. §§ 2201 and 2202.

12

12. All administrative remedies have been exhausted. Plaintiffs have each

13 filed administrative claims for damages under the California Government Claims

14 Act, based on the violations of California law alleged in this complaint, and those

15 claims have been denied.

16

17

VENUE

18

13. Venue is proper in the Central District of California under 28 U.S.c.

19 § 1391 (b) because all of the acts and/or omissions complained of herein occurred

20 or will occur in the District.

21

22

PARTIES

23

14. PlaintiffK.L. is a 16-year old resident of Los Angeles County,

24 California. KL. was a tenth-grade student at HHS at the time of the roundup.

25

15. Plaintiff Anthony Parker is an 18-year old resident of Los Angeles

26 County, California. Mr. Parker was a tenth-grade student at the time of the

27 roundUp.

28

16. PlaintiffL.P. is a 16-year old resident of Los Angeles County,

4

Case 2:11-cv-08484-ODW-SH Document 11 Filed 10/17/11 Page 6 of 24 Page ID #:41

1 California. L.P. was a tenth-grade student at the time of the roundup.

2

17. PlaintiffC.M. is a 17-year old resident of Los Angeles County,

3 California. C.M. was an eleventh-grade student at the time of the roundup.

4

18. Plaintiff Giovanni Pablo is an 18-year old resident of Los Angeles

5 County, California. Mr. Pablo was an eleventh-grade student at the time of the

6 roundup.

7

19. Plaintiff A.F. is a 16-year old resident of Los Angeles County,

8 California. A.F. was a tenth-grade student at the time of the roundup.

9

20. Plaintiff Alejandro Barajas is an 18-year old resident of Los Angeles

10 County, California. Mr. Barajas was an eleventh-grade student at the time of the

11 roundup.

12

21. Defendant Michael Rock is and was at all relevant times a Captain in

13 GPD and Supervisor of the Detective Division, acting in the course and scope of

14 his employment and under color of state law. As more fully set forth herein,

15 Defendant Rock personally approved of and authorized the seizure, search,

16 detention, interrogation, and/or collection and maintenance of personal data

17 relating to one or more of the Plaintiffs. Defendant Rock is sued in his individual

18 and official capacities.

19

22. Defendant Officers Riley, Bickells, Quintero, Park, and Does 1-10 are

20 and at all relevant times were, duly appointed and employed as police officers by

21 the GPD and were at all relevant times acting in the course and scope of their

22 employment and under color of state law. As more fully set forth herein, each of

23 these defendants participated in the seizure, search, detention, interrogation, and/or

24 collection and maintenance of personal data relating to one or more of the

25 Plaintiffs. These police officers are sued in their individual capacities.

26

23. Defendant City of Glendale ("City") is a municipality duly organized

27 under the laws of the State of California. At all relevant times, the Glendale Police

28 Department was a branch or agency of City. Liability under California law for

5

Case 2:11-cv-08484-ODW-SH Document 11 Filed 10/17/11 Page 7 of 24 Page ID #:42

I Defendant City and its employees is based on California Government Code § 815.2

2 and § 820. Plaintiffs timely filed a tort claim with Defendant City and therefore

3 complied with the California Government Claims Act.

4

24. Defendant Los Angeles County ("County") is a municipality duly

5 organized under the laws of the State of California. At all relevant times, the Los

6 Angeles Probation Department was a branch or agency of County. Liability under

7 California law for Defendant County and its employees is based on California

8 Government Code § 815.2 and § 820. Plaintiffs timely filed a tort claim with

9 Defendant County and therefore complied with the California Government Claims

10 Act.

11

25. Defendant City of Los Angeles is a municipality duly organized under

12 the laws of the State of California. At all relevant times, the Los Angeles Police

13 Department was a branch or agency of the City of Los Angeles. Liability under

14 California law for Defendant City of Los Angeles and its employees is based on

15 California Government Code § 815.2 and § 820. Plaintiffs timely filed a tort claim

16 with Defendant City of Los Angeles and therefore complied with the California

17 Government Claims Act

18

26. Defendant Officers Does 11-20 are, and at all relevant times were,

19 duly appointed and employed as police officers by the LAPD, acting in the course

20 and scope of their employment and under color of state law. As more fully set

21 forth herein, each of these defendants participated in the seizure, search, detention,

22 interrogation, and/or collection and maintenance of personal data relating to one or

23 more of the Plaintiffs. These officers are sued in their individual and official

24 capacities. Liability under California law for Defendant City of Los Angeles and

25 its employees is based on California Government Code § 815.2 and § 820.

26 Plaintiffs timely filed a tort claim with Defendant County and therefore complied

27 with the California Government Claims Act.

28

27. Defendant Thomas Van Hoof is and was at all times duly appointed

6

Case 2:11-cv-08484-ODW-SH Document 11 Filed 10/17/11 Page 8 of 24 Page ID #:43

1 and employed by the Los Angeles County Probation Department as a supervising

2 probation officer, in which capacity Defendant Van Hoof directs school-based

3 probation officers. As more fully set forth herein, Defendant Van Hoof was

4 involved in the planning and the seizure, search, detention, interrogation, and/or

5 collection and maintenance of personal data relating Plaintiffs, and was present at

6 HHS and in at least one of the rooms during the roundups. He is sued in his

7 individual and official capacities.

8

28. Defendant Gilda Davis is and was at all relevant times duly appointed

9 and employed by the Los Angeles Probation Department as a school-based

10 probation officer and was at all relevant times acting in the course and scope of her

11 employment and acting under color of state law. As more fully set forth herein,

12 Defendant Davis was involved in the planning and the seizure, search, detention,

13 interrogation, and/or collection and maintenance of personal data relating to one or

14 more of the Plaintiffs. She is sued in her individual capacity.

15

29. Defendant Jennifer Earl is and was at all relevant times employed by

16 the Glendale Unified School District as Principal at Hoover High School. All

17 actions taken by Defendant Earl at Hoover High School were taken while acting in

18 the course and scope of her employment and were taken under color of state law.

19 As more fully set forth herein, Defendant Earl was involved in the planning and the

20 seizure, search, detention, interrogation, and/or collection and maintenance of

21 personal data relating to one or more of the Plaintiffs. She is sued in her individual

22 and official capacities.

23

30. Defendant Hagop Eulmessekian is and was at all relevant times

24 employed by the Glendale Unified School District as an Assistant Principal at

25 Hoover High School. All actions taken by Defendant Eulmessekian at Hoover

26 High School were taken while acting in the course and scope of his employment

27 and were taken under color of state law. As more fully set forth herein, Defendant

28 Eulmessekian was involved in the planning and the seizure, search, detention,

7

Case 2:11-cv-08484-ODW-SH Document 11 Filed 10/17/11 Page 9 of 24 Page ID #:44

1 interrogation, and/or collection and maintenance of personal data relating to one or

2 more of the Plaintiffs. He is sued in his individual capacity.

3

31. Defendant Caroline Sweeney is and was at all relevant times

4 employed by the Glendale Unified School District as an Assistant Principal at

5 Hoover High Schoo!. All actions taken by Defendant Sweeney at Hoover High

6 School were taken while acting in the course and scope of her employment and

7 were taken under color of state law. As more fully set forth herein, Defendant

8 Sweeney was involved in the planning and the seizure, search, detention,

9 interrogation, and/or collection and maintenance of personal data relating to one or

10 more of the Plaintiffs. She is sued in her individual capacity.

11

32. Defendant Ara Mgrdichian is and was at all relevant times employed

12 by the Glendale Unified School District as a Counselor. All actions taken by

13 Defendant Mgrdichian at Hoover High School were taken while acting in the

14 course and scope of his employment and were taken under color of state law. As

15 more fully set forth herein, Defendant Mgrdichian was involved in the planning

16 and the seizure, search, detention, interrogation, and/or collection and maintenance

17 of personal data relating to one or more of the Plaintiffs. He is sued in his

18 individual capacity.

19

33. Defendant Alex Garcia is and was at all relevant times employed by

20 the Glendale Unified School District as a Counselor. All actions taken by

21 Defendant Garcia at Hoover High School were taken while acting in the course and

22 scope of his employment and were taken under color of state law. As more fully

23 set forth herein, Defendant Garcia was involved in the planning and the seizure,

24 search, detention, interrogation, and/or collection and maintenance of personal data

25 relating to one or more of the Plaintiffs. He is sued in his individual capacity.

26

34. Defendants Does 21-25 are and were at all relevant times employed

27 by the Glendale Unified School District and acting under color of state law and in

28 the course and scope of their employment. Does 21-25 were involved in the

8

Case 2:11-cv-08484-ODW-SH Document 11 Filed 10/17/11 Page 10 of 24 Page ID #:45

1 planning and the seizure, search, detention, interrogation, and/or collection and

2 maintenance of personal data relating to one or more of the Plaintiffs. They are

3 sued in their individual capacities.

4

35. Defendants Does 26-30 are and were at all relevant times employed

5 by the County of Los Angeles Probation Department and acting under color of

6 state law and in the course and scope of their employment. Does 26-30 were

7 involved in the planning and the seizure, search, detention, interrogation, and/or

8 collection and maintenance of personal data relating to one or more of the

9 Plaintiffs. They are sued in their individual capacities.

10

11

FACTUAL ALLEGATIONS

12

36. Approximately 2,100 students attend HHS. The student body is

13 diverse. About 57 percent ofthe students are Caucasian (of which 43 percent are

14 of Middle Eastern, primarily of Armenian descent); 25 percent are Latino; 9 15 percent are Asian; 7 percent are Filipino; and 2 percent are of other backgrounds.2

16

37. Various groups of friends and classmates eat lunch in different places

17 around the campus. One group of mostly Latino students, including Plaintiffs K.L,

18 Parker, L.P., C.M., Pablo, and A.F., regularly ate lunch at a cluster of tables on the

19 first floor ofHHS. Another group of mostly Latino students, including Plaintiff

20 Barajas, regularly ate lunch on the second floor ofHHS.

21

The Roundup of Latino Students on September 24, 2010

22

38. Before the lunch period on Friday, September 24,2010, gang officers

23 from GPD and LAPD arrived at HHS and stationed themselves in two classrooms,

24 which were near the tables where the two groups of mostly Latino students

25

26 2 Hoover High School History and Info, available at
27 http;//www.hooverhs.org/23191 0911856411 03/site/default.asp (last visited 28 October 11,2011).

9

Case 2:11-cv-08484-ODW-SH Document 11 Filed 10/17/11 Page 11 of 24 Page ID #:46

1 regularly ate lunch. As the students walked to the tables, HHS administrators

2 stopped them and directed them to the classrooms, one on the first floor and one on

3 the second floor.

4

39. Two HHS administrators - Defendants Eulmessekian and Mgrdichian

5 - approached the students on the first floor and told them that they needed to attend

6 a "meeting." The administrators then escorted the students into a classroom where

7 at least four uniformed GPD officers and one plainclothes police officer were

8 waiting. These officers included Defendants Bickells, Riley, Quintero, and Park.

9 Also in the room were Defendant Sweeney, an assistant principal, and Defendant

10 Davis, the school-based probation officer, and, for a portion of the incident,

11 Defendant Earl. Plaintiffs K.L, Parker, L.P., C.M., Pablo, and A.F. and

12 approximately 20 other students - all of whom are Latino - were corralled into this

13 first-floor classroom. Armed and uniformed police officers were stationed near the

14 classroom's two doors, and other police officers, as well as HHS administrators,

15 were arrayed around the room. Toward the end of the incident, three or four

16 officers wearing LAPD uniforms entered the room and helped process the students.

17

40. Meanwhile, on the second floor, an HHS administrator - Defendant

18 Garcia - directed students into the second-floor classroom. At least three LAPD

19 officers, one GPD officer, and an HHS administrator were waiting inside. As in

20 the first floor classroom, armed and uniformed police officers were stationed near

21 the classroom's entrance, and other police officers, as well as HHS administrators,

22 were arrayed around the room. Officers in this classroom frisked many of the

23 students as they were brought into the room. In total, approximately 25 Latino

24 students, including Plaintiff Barajas, were detained in the second-floor classroom.

25

41. In both classrooms, police officers told students that the police would

26 interview each student and that they had to provide the police with their personal

27 information. The students were informed that they could not leave the classroom

28 until they had provided their information.

10

Case 2:11-cv-08484-ODW-SH Document 11 Filed 10/17/11 Page 12 of 24 Page ID #:47

I

42. The police officers in both rooms then interrogated students

2 individually. Officers demanded students' personal information such as their

3 name, address, phone number, hair and eye color, age, weight, and birthday. The

4 officers asked about any tattoos or scars, took notes based on the students'

5 responses, and took photographs of students' tattoos. Officers also asked students

6 about criminal involvement, including whether they had ever been arrested or

7 placed on probation. Some officers used their police radios to relay information

8 that students provided.

9

43. During the individual interrogations, officers in both classrooms wrote

10 notes of what students told them on white index cards. The officers then took

11 "mug shots" of each student by instructing the student to hold up the card with his

12 or her information, facing out, and then taking a photograph of the student with the

13 card. Each one of the Plaintiffs was interviewed and photographed in this manner.

14 When one student objected and said that he wanted the information that had been

15 collected shredded because he had done nothing wrong, the police ignored him and

16 took his picture before releasing him.

17

44. During the operation, police officers told various students that they

18 were on a "gang list," that the police were gathering the students' photographs and

19 personal information so the police could easily identify the students if they got in

20 trouble in the future, and that the students' personal information was being

21 collected so that the officers could assess whether the students were "on the right

22 path." Defendants also asserted that the students who had been targeted either

23 belonged to or admired particular gangs.

24

45. While the students were detained, the police officers threatened the

25 students and used their official authority to intimidate the students into complying

26 with their demands, including, but not limited to the following:

27 • When one student raised his voice and asked why the police were targeting

28

only one race, a police officer handcuffed the student and announced to the

II

Case 2:11-cv-08484-ODW-SH Document 11 Filed 10/17/11 Page 13 of 24 Page ID #:48

1

rest ofthe students, "This is what happens to tough guys," as police officers

2

removed the student from the classroom.

3 • When other students asked why they were being detained, a police officer

4

told them, "Be quiet and keep your mouths shut."

5 • Another police officer told the students that they could no longer sit together

6

at lunch or hang out with each other in or outside of school and that, if they

7

did, the police would come back and the students would be in "even more

8

trouble."

9 • When another student protested that he was not a gang member, a police

10

officer proceeded to interrogate the student over his objections.

11 • When one male student tried to refuse to have his picture taken, the officers

12

threatened him and the other students, saying that if the students did not

13

cooperate, the officers would have to go to their homes at 6 a.m. and tell

14

their parents that the students were associating with gang members and

15

would obtain the students' information then.

16

46. During the operation, police officers confiscated several students' cell

17 phones and held them until the students were released. Officers reviewed text

18 messages on at least one student's phone. Neither the police nor the school

19 administrators asked for the consent of these students to search their cell phones,

20 nor did police or administrators have any reasonable basis to suspect that the cell

21 phones contained contraband or evidence of wrongdoing.

22

47. During the operation, defendants also confiscated the backpacks of

23 several students, including Plaintiffs K.L. and A.F., searched the bags, and

24 removed student IDs that had been kept in the bags. Neither the police nor the

25 school administrators asked for the consent of these students to search their

26 backpacks, nor did police or administrators have any reasonable basis to suspect

27 that the bags contained contraband or evidence of wrongdoing.

28

48. During the time the students were detained in the classrooms,

12

Case 2:11-cv-08484-ODW-SH Document 11 Filed 10/17/11 Page 14 of 24 Page ID #:49

1 Defendants made it clear that the students were not free to leave. When one

2 student asked why he was there and stated that he wanted to leave, a police officer

3 told him to "sit down and shut up," while Defendant Eulmessekian told him that he

4 needed to be interviewed before he could leave. When another student asked to

5 use the bathroom, a police officer told her that she could not leave the room until

6 after her interview. When a third student protested that the police were intruding

7 on their lunch period, Defendant Eulmessekian called security officials who then

8 brought food for the students to the classroom. Finally, Plaintiff K.L. ' s sister

9 learned that students, including her sister, were being questioned by police and

10 went directly to HSS to request an early dismissal for her sister. When the school

11 employee at the front office contacted Defendant Eulmessekian via radio to notify

12 him that K.L. needed to report to the front office for early dismissal, Defendant

13 Eulmessekian told the police officers that K.L. had to be interrogated and

14 photographed because she had to leave the classroom. Only after she had been

15 interrogated and photographed was she allowed to leave.

16

49. Students on the first floor were detained between about 60 and 90

17 minutes. Students on the second floor were detained for between about 30 and 60

18 minutes. Many students missed most or all of their fifth-period classes following

19 the lunch period because the police did not let them leave until they were

20 interviewed and photographed.

21

Defendants Conspired to Violate Plaintiffs' Rights by Targeting Them

22 Because They Are or Appear to Be Latino and by Detaining and Searching

23

Them without Individualized Suspicion

24

50. Based on the execution of the roundup and the interaction of the

25 various officers, the operation was clearly coordinated among the various

26 government agencies involved, with the police officers from GPD and LAPD

27 arriving just prior to lunch and positioning themselves in classrooms near where

28 the targeted students typically sat for lunch. School administrators identified the

13

Case 2:11-cv-08484-ODW-SH Document 11 Filed 10/17/11 Page 15 of 24 Page ID #:50

1 students who were required to enter the classrooms for interrogation as they

2 approached the tables, and Defendant Davis maintained a list of the students who

3 were detained during the operation. When the police officers who had been

4 stationed in the classroom on the second floor finished interrogating the students

5 on the second floor, they proceeded downstairs to the first floor classroom to assist

6 the school administrators and police officers in processing the remaining students.

7

51. Defendants targeted the students because they were or appeared to be

8 Latino. One student who is part Filipino and does not appear Latino regularly sat

9 at the tables on the first floor. This student was not instructed by the police

10 officers or school administrators to join the other students with whom he regularly

11 sits, and he continued to eat lunch while the other students, all of whom are or

12 appear to be Latino, were detained and interrogated in the classroom. Defendant

l3 Rock later suggested that Defendants had not targeted only Latino students because

14 they had planned a similar operation at HHS targeting Armenian students.

15

52. In total, approximately 56 students - all Latino, and all of whom were

16 on school property and engaged in ordinary and proper activities associated with

17 attending school- were directed to enter one of the two classrooms, detained,

18 interrogated, threatened, and in many cases photographed and searched.

19 Defendants never identified any particular reason to believe that plaintiffs or any

20 other students in either room had violated any school policy, rule, or regulation or

21 had otherwise engaged in any unlawful conduct, nor did they have any such reason

22 or belief.

23

53. In coordinating and executing the roundup, the individual Defendants

24 abused their authority, took advantage of the weakness of Plaintiffs' position to

25 violate Plaintiffs' rights, and acted with willful and conscious disregard of the

26 plaintiff's rights and with knowledge that their conduct would cause emotional

27 harm to Plaintiffs.

28 II

14

Case 2:11-cv-08484-ODW-SH Document 11 Filed 10/17/11 Page 16 of 24 Page ID #:51

1

Defendants' Actions Caused Plaintiffs Emotional Harm

2

54. The event left many of the students traumatized, fearful that they

3 would be arrested or detained in the future as a consequence of being targeted in

4 this operation, and wondering why only they - and not their non-Latino classmates

5 - had been targeted by the police and HHS administration.

6

55. Some of the Plaintiffs and other students became terrified from the

7 moment they first entered the classrooms filled with school administrators and

8 armed police, and remained terrified while Defendants held them there against

9 their will and subjected them to abusive language, invasive questioning, and threats

10 of further police action. Plaintiffs felt powerless and humiliated while police

11 questioned them, photographed tattoos, and forced them to pose for mock mug

12 shots. Because the officers told the students that they would come back if the

13 students continued hanging out together and that their photographs would be kept

14 in a gang file, Plaintiffs and other students believed that the police and school had

15 somehow marked them as gang members.

16

56. Following the incident, Plaintiffs and other students continued to

17 suffer from fear and shock. Plaintiffs variously lost their appetites, became

18 withdrawn around family, and stopped spending time with friends or sitting

19 regularly at the lunch tables. At least one Plaintiff became concerned about

20 associating with a cousin whom Defendants also detained in the roundup.

21 Plaintiffs remain fearful that the police and school administrators are watching

22 them and will follow through on their threats to engage in further action.

23

57. Students, teachers and administrators at HHS act differently toward

24 Plaintiffs since Defendants targeted them in the September 24 roundup. Plaintiffs

25 feel that teachers, administrators and even other students at HHS have identified

26 them as troublemakers because they were targeted in the roundup, and Plaintiffs no

27 longer view their high school as a safe and supportive environment. Indeed, one

28 Plaintifftransferred to another school in part because of how administrators treated

15

Case 2:11-cv-08484-ODW-SH Document 11 Filed 10/17/11 Page 17 of 24 Page ID #:52

I him on September 24 and afterwards.

2

58. Because Defendants targeted them in the roundup and collected

3 information on them, Plaintiffs also fear that they have been identified by police as

4 gang members or likely criminals. Since the roundup, the police have stopped at

5 least one Plaintiff and questioned him about affiliating with the same gang he had

6 been questioned about during the roundup, even though the police had never asked

7 about him about gang affiliation before the roundup.

8

59. The roundup has also affected the hopes and aspirations of the high

9 school students whom Defendants detained. Among Plaintiffs are students who

10 want to join the military or become police officers, but who now fear that because

II of Defendants' actions they have been placed on lists as gang members that will

12 prevent them from attaining their goals.

13

Defendants' Shifting Explanations for the Roundup

14

60. During the weeks that followed the roundup, parents and family

15 members of the targeted students and other adults spoke with various Defendants,

16 including Defendants Earl, Rock, and Davis, as well as with other representatives

17 of GUSD, about the roundup on several occasions. The parents and other adults

18 expressed concerns about the roundup, sought additional information about its

19 planning and execution, and requested that Defendants ensure that all information

20 collected during the roundup was destroyed.

21

61. Defendants responded to the expressed concerns with shifting and

22 conflicting explanations of who had initiated the roundups and what purpose they

23 served. School officials (including Defendant Earl) first maintained that the police

24 had requested the roundup and that they did not have a list of the students targeted

25 or that the list had been destroyed, but later admitted having such a list. GPD

26 officials (including Captain Rock) told Plaintiffs and others that the roundup was

27 an "educational seminar" intended to teach them the risks of gang involvement and

28 that the operations had been requested by the school. Other Defendants stated that

16

Case 2:11-cv-08484-ODW-SH Document 11 Filed 10/17/11 Page 18 of 24 Page ID #:53

1 the idea for the roundup had come from Defendant Davis, the school-based

2 probation officer assigned to HHS.

3

62. For months after the September 24 incident, Plaintiffs, their parents,

4 and others repeatedly requested written confirmation from Defendants that the

5 information gathered in the roundups would be destroyed and not retained in any

6 of Defendants' files. Although various Defendants initially agreed and stated that

7 the September 24,2010 operation was a mistake, they later retracted their offer to

8 provide such written confirmation that all information collected would be

9 destroyed, and none was ever provided.

10 The September 24, 2010 Roundup Is Part of a Custom and Practice by the

11 Probation Department and GPD of Detaining Students based on Their Race

12

or Ethnicity and without Individualized Suspicion of Wrongdoing

l3

63. Similar roundups have been conducted at the behest of school-based

14 probation officers on other campuses in Los Angeles County, and those operations

15 served as the model for the September 24 roundup at HHS. The plan for the

16 roundup was approved by Defendant Van Hoof, who supervises school-based

17 probation officers for the County, and who was personally present during the

18 September 24 roundup and approved the manner in which the roundup was

19 conducted.

20

64. In the days following the roundup, Defendant Rock, in responding to

21 concerns that the GPD had discriminatorily targeted Latino students, stated that

22 GPD intended to conduct similar operations targeting Armenian students at HHS.

23

24

CLASS ALLEGATIONS

25

65. Plaintiffs K.L., Parker, L.P., C.M., Pablo, A.F., and Barajas bring all

26 claims for injunctive and declaratory relief on behalf of themselves and all other

27 persons similarly situated, pursuant to Federal Rule of Civil Procedure 23.

28

66. The plaintiff class consists of:

17

Case 2:11-cv-08484-ODW-SH Document 11 Filed 10/17/11 Page 19 of 24 Page ID #:54

1

Students at Hoover High School who were detained during lunch

2

and/or the following period by Defendants on September 24,2010.

3

67. Class action status for this litigation is proper because:

4

(a) The plaintiff class is so numerous that joinder of all members is

5 impractical;

6

(b) There are questions of law and fact common to the class;

7

(c) Plaintiffs' claims are typical of the claims of the class, in that

8 Plaintiffs, like all of their peers who were targeted by Defendants, were detained

9 and interrogated by Defendants without lawful justification, as part of an operation

10 that was planned and executed by Defendants with the intent of targeting Latino

11 students.

12

(d) Plaintiffs will fairly and adequately protect the interests of the

13 class as there is no conflict between Plaintiffs and the other class members; and

14

(e) Plaintiffs can adequately represent the interests of the class

15 members and have retained counsel experienced in class action litigation.

16

68. Defendants have acted and/or refused to act on grounds generally

17 applicable to the class, thereby making final declaratory and injunctive relief

18 appropriate with respect to the class as a whole, under Federal Rule of Civil

19 Procedure 23(b)(2).

20

21

FIRST CAUSE OF ACTION

22

Violation of 42 U.S.c. § 1983

23

(Unlawful Search and Seizure in Violation of the Fourth Amendment)

24

69. Plaintiffs incorporate by reference the foregoing paragraphs of this

25 Complaint as though fully set forth herein.

26

70. Defendants, acting in concert with one another, violated Plaintiffs'

27 right to be free from unreasonable searches and seizures under the Fourth

28 Amendment to the United States Constitution during the operation conducted at

18

Case 2:11-cv-08484-ODW-SH Document 11 Filed 10/17/11 Page 20 of 24 Page ID #:55

1 Hoover High School on September 24,2010.

2

71. Defendants were acting under color of state law, thereby violating 42

3 U.S.C. § 1983.

4

5

SECOND CAUSE OF ACTION

6

Violation of 42 U.S.C. § 1983

7 (Discrimination on Account of Race, Ancestry or National Origin in Violation

8

of the Equal Protection Clause of the Fourteenth Amendment)

9

72. Plaintiffs incorporate by reference the foregoing paragraphs of this

10 Complaint as though fully set forth herein.

11

73. Defendants, acting in concert with one another, targeted Plaintiffs in

12 the roundup because ofthe race, ancestry, or national origin during the operation
13 conducted at Hoover High School on September 24,2010, in violation of the Equal

14 Protection Clause ofthe Fourteenth Amendment.

15

74. Defendants were acting under color of state law, thereby violating 42

16 U.S.C. § 1983.

17

18

THIRD CAUSE OF ACTION

19

Violation of 42 U.S.C. § 1985(3)

20

(Conspiracy to Violate Civil Rights)

21

75. Plaintiffs incorporate by reference the foregoing paragraphs of this

22 Complaint as though fully set forth herein.

23

76. In planning and executing the roundup at Hoover High School on

24 September 24, 2010, Defendants conspired to target students who are or appear to 25 be Latino and then to detain and interrogate only the targeted students, without

26 lawful justification, thereby depriving them of their right to equal protection under

27 the law.

28

77. Defendants did, in fact, intentionally target students during the

19

Case 2:11-cv-08484-ODW-SH Document 11 Filed 10/17/11 Page 21 of 24 Page ID #:56

1 roundup because they are or appear to be Latino, and understood at the time they

2 were conducting the operation that the operation was intended to target students

3 who are or appear to be Latino.

4

78. The acts done by Defendants in furtherance of the conspiracy,

5 including directing Plaintiffs to enter the classrooms and then detaining Plaintiffs

6 in the classroom until they had submitted to interrogation and, in some cases,

7 searches and being photographed, resulted in an injury to Plaintiffs and prevented

8 them from enjoying the rights to equal protection and to be free of unreasonable

9 searches and seizures.

10

11

FOURTH CAUSE OF ACTION

12

Violation of Article 1, Section 7 of the California Constitution

13

(Discrimination on Account of Race, Ancestry, and National Origin)

14

79. Plaintiffs incorporate by reference the foregoing paragraphs of this

15 Complaint as though fully set forth herein.

16

80. Defendants, acting in concert with one another, targeted Plaintiffs in

17 the roundup because of the race, ancestry, or national origin during the operation

18 conducted at Hoover High School on September 24,2010, in violation Article 1,

19 Section 7 of the California Constitution.

20

21

FIFTH CAUSE OF ACTION

22

Violation of Article I, Section 13 of the California Constitution

23

(Unlawful Search and Seizure)

24

81. Plaintiffs incorporate by reference the foregoing paragraphs of this

25 Complaint as though fully set forth herein.

26

82. Defendants, acting in concert with one another, violated Plaintiffs'

27 right to be free from unreasonable searches and seizures under Article 1, Section

28 13 ofthe California Constitution during the operation conducted at Hoover High

20

Case 2:11-cv-08484-ODW-SH Document 11 Filed 10/17/11 Page 22 of 24 Page ID #:57

1 School on September 24,2010.

2

3

SIXTH CAUSE OF ACTION

4

Violation of California Civil Code Section 52.1

5

83. Plaintiffs incorporate by reference the foregoing paragraphs of this

6 Complaint as though fully set forth herein.

7

84. Defendants threatened, intimidated, and coerced plaintiffs in a manner

8 that interfered with their exercise and enjoyment of rights secured by the

9 Constitution and laws of the United States and rights secured by the Constitution

10 and laws of the State of California, including but not limited to their rights to be

11 free from unreasonable searches and their right to equal protection of the laws.

12

85. Defendants' conduct described above interfered and/or attempted to

13 interfere with Plaintiffs' exercise and/or enjoyment of their rights secured by the

14 Constitution and laws of the United States and by the Constitution and laws of the

15 state of California, in violation of California Civil Code Section 52.1.

16

17

REQUEST FOR RELIEF

18

Plaintiffs respectfully request that this Court grant the following relief:

19

A. Certify a class for all claims for injunctive and declaratory relief in

20 this Complaint pursuant to Federal Rule of Civil Procedure 23, in accordance with

21 the allegations in this Complaint and the forthcoming class certification motion.

22

B. Issue an injunction prohibiting Defendants, and all those acting in

23 concert with them or acting under their supervision or control, from detaining,

24 searching, seizing the belongings of, interrogating, or photographing students at

25 Hoover High School, without probable cause or reasonable suspicion to believe

26 that the student has violated a valid school rule or has violated the law, or based on

27 their race, ethnicity, or national origin;

28

C. Issue an injunction requiring the Defendants to destroy or return any

21

Case 2:11-cv-08484-ODW-SH Document 11 Filed 10/17/11 Page 23 of 24 Page ID #:58

1 information about Plaintiffs and the Plaintiff class gathered by Defendants during

2 the September 24, 2010 roundup, to ensure that no information about Plaintiffs and 3 the Plaintiff class gathered during the September 24, 2010 roundup is retained in

4 any file, database, or other system maintained by Defendants or to which

5 Defendants have access, and to clear Plaintiffs of any wrongdoing in connection

6 with the September 24,2010 roundup before any entities with whom Defendants

7 have shared information about the roundup;

8

D. Award Plaintiffs compensatory and general damages, in an amount to

9 be proven at trial, against the City of Glendale and the Los Angeles Probation

10 Department and against each of the individual Defendants sued in his or her

11 personal capacity;

12

E. Award Plaintiffs exemplary damages for violations of California law

13 and punitive damages for violations of federal law, each in an amount to be proven

14 at trial, against each of the individual Defendants sued in his or her personal

15 capacity;

16

F. Award statutory damages and penalties to Plaintiffs pursuant to

17 California Civil Code §§ 52 and 52.l(b) against the City Glendale and the Los

18 Angeles County Probation Department and against each of the individual

19 defendants sued in his or her personal capacity;

20

G. Declare that Defendants' conduct, as described in this Complaint,

21 violated the rights of Plaintiffs and the Plaintiff class under the constitutions and

22 laws of the United States and the State of California;

23

H. Award Plaintiffs their costs, expenses and reasonable attorney's fees

24 pursuant to 42 U.S.C. § 1988, California Civil Codes §§ 52(b) and 52.1 (h),

25 California Code of Civil Procedure § 1021.5, and any other appropriate statutory

26 basis; and

27 28

22

Case 2:11-cv-08484-ODW-SH Document 11 Filed 10/17/11 Page 24 of 24 Page ID #:59

1

I. Grant such other relief as the Court may deem just and proper.

2

3 Respectfully Submitted, 4

ACLU FOUNDATION OF SOUTHERN CALIFORNIA

5 6 Dated: October 13, 2011
7

By: j5?u,; / ~ David B. Sapp Attorneys for Plaintiffs

8

9 10 11 Dated: October 13, 2011 12 13

TRABER & VOORHEES

&!vc By:

~G()J'vh,pa Cdc)

Bert Voorhees

Attorneys for Plaintiffs

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

23

K. L. et al v. City of Glendale et al, Docket No. 2:11-cv-08484 (C.D. Cal. Oct 13, 2011), Court Docket
General Information

Court Nature of Suit Docket Number Status

United States District Court for the Central District of California Civil Rights: Other 2:11-cv-08484 Closed

© 2014 The Bureau of National Affairs, Inc. All Rights Reserved. Terms of Service // PAGE 25

 
 Case 2:11-cv-08484-ODW-SH Document 19 Filed 11/01/11 Page 1 of 24 Page ID #:81

1 David B. Sapp (SBN 264464)
dsapp~aclu-sc.org

2

Peter Biliring (SBN223981)
pbibril!&@aclu-sc.org ~

3 ACLU FOlJNDATION OF SOUTHERN CALIFORNIA

4 1313 West Eighth Street

Los An,ge1es California 90017

5 T: (21j) 977-9500, F: (213) 977-5297

FILED CLERK U.S. DISTRICT COURT
NOV - I 2011
' _ _C~EY.N..~ TRAL =D=IS-T-R-IC=T-O_F_CALIOFEOPRUNTIA_Y.

6 Bert Voorhees (SBN 137623) bv~tv legal.com

7 TRA-:BER & VOORHEES

128 N. Fair Oaks, Suite 204

8 Pasadena, CA 91103

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NY PARKER; L.P. by hIS Guardian Juana Farfan; C.M., by his Guardian

Lit~ Christine Clavesilla; GIOVANNI

ABLO; A.F. by her Guardian Ad Litem

CASE NO.: CV-ll-08484 ODW (SHx) CLASS ACTION

15 Cristina Pablo; ALEJANDRO BARAJAS; and M.A. by her Guardian Ad Litem Araceli
16 Terracena, on behalf of themselves and all

FIRST AMENDED COMPLAINT

those similarly situated,

17 Plaintiffs,

18 vs.
19 CITY OF GLENDALE; COUNTY OF LOS
20 ANGELES; CITY OF LOS ANGELES; MICHAEL ROCK, in his individual and
21 oinfdfiicviiadlucaalpcaacpiaticeist;y;OOFFFFICICEERRRBILIECY:KEinLhLi~s his 22 individual capacity; OFFICER OUINTERu~
his individua capaci!Y; OFFICE"R PARK, hIS 23 individual capacIty; THOMAS VAN HOOF,
in his officiaf and mdividual cap'acity.;, GILDA 24 DAVIS, in her individual capacity'; JbNNIFER
EARL, in her individual and official capacities; 25 HAGOP EULMESSEKIAN-I-,in his indIvidual
capacity; CAROLINE SWEbNEY, in her 26 individual capacity; ARA MGRDICHIAN, in
his individua capacity; ALEX GARCIA, in his 27 individual capacIty; and DOES 1-30, in their
individual capacitIes, 28

Case 2:11-cv-08484-ODW-SH Document 19 Filed 11/01/11 Page 2 of 24 Page ID #:82

1

INTRODUCTION}

2

1. It is not against the law to be a Latino high school student. Yet, on

3 Friday, September 24,2010, administrators at Hoover High School ("HHS") in

4 Glendale, California, in coordination with officers from the Glendale Police

5 Department ("GPD"), the Los Angeles Police Department ("LAPD"), and the Los

6 Angeles County Probation Department ("Probation Department"), acted as though

7 it were, when they rounded up, interrogated, photographed, and collected personal

8 information from approximately 56 students solely because they are or appear to

9 be Latino.

10

2. At the start of the lunch period, school administrators rounded up

11 students into two classrooms, where approximately a dozen armed uniformed and

12 plainclothes police officers were stationed. Police officers, probation officers, and

13 school administrators proceeded to detain the students for between 30 and 90

14 minutes. During that time, the police officers interrogated the students about their

15 personal information and activities, forced them to pose for mock "mug shots,"

16 threatened them with recurring police visits, told students to "sit down and shut

17 up" when they asked why they were being detained, and in some cases searched

18 students and their belongings without consent. Police and administrators told the

19 students that they could not leave until they had submitted to interrogation, and

20 enforced this order with armed police officers stationed around the classrooms and

21 by the classroom doors.

22

3. During their detention, police officers told various students that they

23 could no longer eat lunch at certain tables on school property; that they could no

24 longer spend time with their Latino classmates who had also been targeted; that the

25

26

I The allegations of this Complaint are based on information and belief,

27 unless otherwise specified.

28

1

Case 2:11-cv-08484-ODW-SH Document 19 Filed 11/01/11 Page 3 of 24 Page ID #:83

1 police officers would show up at their houses at 6 a.m. if the students did not

2 provide their personal information as the officers demanded; that they were on a

3 "gang list" and that the police would keep their photographs and information

4 collected during the operation on file; that if the students got in trouble in the

5 future, the police would easily identify them based on the information they were

6 collecting; and that their personal information was being collected so that the

7 officers could assess whether the students were "on the right path."

8

4. At the time they were targeted, the students were doing nothing

9 wrong. They were not violating any laws or school rules, and the school officials

10 and law enforcement officers who conducted the operation had no basis to believe

11 any of the students were engaged in unlawful conduct.

12

5. All of the students whom Defendants targeted are or appear to be

13 Latino, even though the student body at HHS is only about 25 percent Latino.

14 Additionally, in identifying students who were to be detained in a classroom on the

15 first floor, HHS administrators ordered a group of Latino males sitting at a cluster

16 of tables to report to a classroom, while allowing another student sitting at those

17 tables, who does not appear to be Latino, to remain outside. Although this student

18 regularly sits with the group of Latino students, he was not required to report to the

19 classroom because he does not appear to be Latino. Finally, Defendant Michael

20 Rock, a captain in GPD who approved the operation, responded to concerns that

21 Defendants had targeted only Latino students by stating that, at the time

22 Defendants planned and executed the roundup of the Latino students, they planned

23 to conduct a similar operation targeting Armenian students.

24

6. This operation was illegal and violated the rights of the students

25 whom Defendants targeted. It also was harmful to the students, many of whom

26 were terrified and intimidated by the show of force and believed they might be

27 arrested, even though they had broken no laws and had not violated any school

28 rules. Finally, the operation undermined trust between school officials and law

2

Case 2:11-cv-08484-ODW-SH Document 19 Filed 11/01/11 Page 4 of 24 Page ID #:84

1 enforcement officers, on the one hand, and students, parents and the community,

2 on the other hand. Those harms were compounded by the refusal of administrators

3 at HHS and within Glendale Unified School District and supervisory officers

4 within GPD and LAPD to confirm, in writing, that any information collected by

5 HHS or the police during the September 24 operation had been destroyed or to

6 acknowledge formally that the operation was a mistake and that similar operations

7 would not occur in the future.

8

7. The government employees who planned, coordinated, and executed

9 this operation acted under color of state law and used their positions of authority

10 not only to violate the rights of Plaintiffs and their peers, but also to intimidate

11 students, most of whom were minors, into changing behavior that was not illegal

12 and forcing them to stop hanging out with certain other students at HHS, even

13 though they were not breaking any laws by associating with their friends. This

14 outrageous conduct is all the more offensive because it occurred at school, which is

15 supposed to be a safe place with a welcoming environment that supports academic

16 success, and occurred with the active involvement of school administrators, who

17 are supposed to be educators first and foremost. In a free society, such coercive

18 tactics cannot and should not be tolerated.

19

8. Although each Defendant took an active role in planning and

20 executing the roundup, the plan for the roundup was based on similar roundups

21 that Los Angeles County Probation officers regularly plan and conduct at other

22 schools.

23

9. Plaintiffs seek injunctive relief and declaratory relief on behalf of

24 themselves and a class of similarly situated students whom Defendants subjected to

25 detention, interrogation, threats, photographing, and in some cases search, because

26 of their race and without their consent, at Hoover High School on September 24,

27 2010. Additionally, the named Plaintiffs seek compensatory and punitive damages

28 for themselves against Defendants for the violations of numerous rights during the

3

Case 2:11-cv-08484-ODW-SH Document 19 Filed 11/01/11 Page 5 of 24 Page ID #:85

1 September 24 roundup.

2

3

JURISDICTION

4

10. Plaintiffs' claims for declaratory, injunctive, and monetary relief are

5 brought pursuant to the Fourth and Fourteenth Amendments to the Constitution of

6 the United States; 42 U.S.C. § 1983; 42 U.S.C. § 1985; Article 1, Sections 7 and 13

7 of the California Constitution; and Cal. Civ. Code §§ 52 and 52.1.

8

11. This Court has jurisdiction over Plaintiffs' federal claims under 28

9 U.S.C. §§ 1331, 1343, and 2201. The Court has supplemental jurisdiction over the

10 state law claims pursuant to 28 U.S.C. § 1367. Declaratory relief is authorized

11 under 28 U.S.C. §§ 2201 and 2202.

12

12. All administrative remedies have been exhausted. Plaintiffs have each

13 filed administrative claims for damages under the California Government Claims

14 Act, based on the violations of California law alleged in this complaint, and those

15 claims have been denied.

16

17

VENUE

18

13. Venue is proper in the Central District of California under 28 U.S.C.

19 § 1391(b) because all of the acts and/or omissions complained of herein occurred

20 or will occur in the District.

21

22

PARTIES

23

14. PlaintiffK.L. is a 16-year old resident of Los Angeles County,

24 California. K.L. was a tenth-grade student at HHS at the time of the roundup.

25

15. Plaintiff Anthony Parker is an 18-year old resident of Los Angeles

26 County, California. Mr. Parker was a tenth-grade student at the time of the

27 roundup.

28

16. PlaintiffL.P. is a 16-year old resident of Los Angeles County,

4

Case 2:11-cv-08484-ODW-SH Document 19 Filed 11/01/11 Page 6 of 24 Page ID #:86

1 California. L.P. was a tenth-grade student at the time of the roundup.

2

17. Plaintiff C.M. is a 17-year old resident of Los Angeles County,

3 California. C.M. was an eleventh-grade student at the time of the roundup.

4

18. Plaintiff Giovanni Pablo is an 18-year old resident of Los Angeles

5 County, California. Mr. Pablo was an eleventh-grade student at the time of the

6 roundup.

7

19. Plaintiff A.F. is a 16-year old resident of Los Angeles County,

8 California. A.F. was a tenth-grade student at the time of the roundup.

9

20. Plaintiff Alejandro Barajas is an 18-year old resident of Los Angeles

10 County, California. Mr. Barajas was an eleventh-grade student at the time of the

11 roundup.

12

21. Plaintiff M.A. is a 17-year old resident of Los Angeles County,

13 California. M.A. was a tenth-grade student at the time of the roundup.

14

22. Defendant Michael Rock is and was at all relevant times a Captain in

15 GPD and Supervisor of the Detective Division, acting in the course and scope of

16 his employment and under color of state law. As more fully set forth herein,

17 Defendant Rock personally approved of and authorized the seizure, search,

18 detention, interrogation, and/or collection and maintenance of personal data

19 relating to one or more of the Plaintiffs. Defendant Rock is sued in his individual

20 and official capacities.

21

23. Defendant Officers Riley, Bickells, Quintero, Park, and Does 1-10 are

22 and at all relevant times were, duly appointed and employed as police officers by

23 the GPD and were at all relevant times acting in the course and scope of their

24 employment and under color of state law. As more fully set forth herein, each of

25 these defendants participated in the seizure, search, detention, interrogation, and/or

26 collection and maintenance of personal data relating to one or more of the

27 Plaintiffs. These police officers are sued in their individual capacities.

28

24. Defendant City of Glendale ("City") is a municipality duly organized

5

Case 2:11-cv-08484-ODW-SH Document 19 Filed 11/01/11 Page 7 of 24 Page ID #:87

1 under the laws of the State of California. At all relevant times, the Glendale Police

2 Department was a branch or agency of City. Liability under California law for

3 Defendant City and its employees is based on California Government Code § 815.2

4 and § 820. Plaintiffs timely filed a tort claim with Defendant City and therefore

5 complied with the California Government Claims Act.

6

25. Defendant Los Angeles County ("County") is a municipality duly

7 organized under the laws of the State of California. At all relevant times, the Los

8 Angeles Probation Department was a branch or agency of County. Liability under

9 California law for Defendant County and its employees is based on California

10 Government Code § 815.2 and § 820. Plaintiffs timely filed a tort claim with

11 Defendant County and therefore complied with the California Government Claims

12 Act.

13

26. Defendant City of Los Angeles is a municipality duly organized under

14 the laws of the State of California. At all relevant times, the Los Angeles Police

15 Department was a branch or agency of the City of Los Angeles. Liability under

16 California law for Defendant City of Los Angeles and its employees is based on

17 California Government Code § 815.2 and § 820. Plaintiffs timely filed a tort claim

18 with Defendant City of Los Angeles and therefore complied with the California

19 Government Claims Act

20

27. Defendant Officers Does 11-20 are, and at all relevant times were,

21 duly appointed and employed as police officers by the LAPD, acting in the course

22 and scope of their employment and under color of state law. As more fully set

23 forth herein, each of these defendants participated in the seizure, search, detention,

24 interrogation, and/or collection and maintenance of personal data relating to one or

25 more of the Plaintiffs. These officers are sued in their individual and official

26 capacities. Liability under California law for Defendant City of Los Angeles and

27 its employees is based on California Government Code § 815.2 and § 820.

28 Plaintiffs timely filed a tort claim with Defendant City of Los Angeles and

6

Case 2:11-cv-08484-ODW-SH Document 19 Filed 11/01/11 Page 8 of 24 Page ID #:88

1 therefore complied with the California Government Claims Act.

2

28. Defendant Thomas Van Hoof is and was at all times duly appointed

3 and employed by the Los Angeles County Probation Department as a supervising

4 probation officer, in which capacity Defendant Van Hoof directs school-based

5 probation officers. As more fully set forth herein, Defendant Van Hoof was

6 involved in the planning and the seizure, search, detention, interrogation, and/or

7 collection and maintenance of personal data relating Plaintiffs, and was present at

8 HHS and in at least one of the rooms during the roundups. He is sued in his

9 individual and official capacities.

10

29. Defendant Gilda Davis is and was at all relevant times duly appointed

11 and employed by the Los Angeles Probation Department as a school-based

12 probation officer and was at all relevant times acting in the course and scope of her

13 employment and acting under color of state law. As more fully set forth herein,

14 Defendant Davis was involved in the planning and the seizure, search, detention,

15 interrogation, and/or collection and maintenance of personal data relating to one or

16 more of the Plaintiffs. She is sued in her individual capacity.

17

30. Defendant Jennifer Earl is and was at all relevant times employed by

18 the Glendale Unified School District as Principal at Hoover High School. All

19 actions taken by Defendant Earl at Hoover High School were taken while acting in

20 the course and scope of her employment and were taken under color of state law.

21 As more fully set forth herein, Defendant Earl was involved in the planning and the

22 seizure, search, detention, interrogation, and/or collection and maintenance of

23 personal data relating to one or more of the Plaintiffs. She is sued in her individual

24 and official capacities.

25

31. Defendant Hagop Eulmessekian is and was at all relevant times

26 employed by the Glendale Unified School District as an Assistant Principal at

27 Hoover High School. All actions taken by Defendant Eulmessekian at Hoover

28 High School were taken while acting in the course and scope of his employment

7

Case 2:11-cv-08484-ODW-SH Document 19 Filed 11/01/11 Page 9 of 24 Page ID #:89

1 and were taken under color of state law. As more fully set forth herein, Defendant

2 Eulmessekian was involved in the planning and the seizure, search, detention,

3 interrogation, andlor collection and maintenance of personal data relating to one or

4 more of the Plaintiffs. He is sued in his individual capacity.

5

32. Defendant Caroline Sweeney is and was at all relevant times

6 employed by the Glendale Unified School District as an Assistant Principal at

7 Hoover High School. All actions taken by Defendant Sweeney at Hoover High

8 School were taken while acting in the course and scope of her employment and

9 were taken under color of state law. As more fully set forth herein, Defendant

10 Sweeney was involved in the planning and the seizure, search, detention,

11 interrogation, and/or collection and maintenance of personal data relating to one or

12 more of the Plaintiffs. She is sued in her individual capacity.

13

33. Defendant Ara Mgrdichian is and was at all relevant times employed

14 by the Glendale Unified School District as a Counselor. All actions taken by

15 Defendant Mgrdichian at Hoover High School were taken while acting in the

16 course and scope of his employment and were taken under color of state law. As

17 more fully set forth herein, Defendant Mgrdichian was involved in the planning

18 and the seizure, search, detention, interrogation, andlor collection and maintenance

19 of personal data relating to one or more of the Plaintiffs. He is sued in his

20 individual capacity.

21

34. Defendant Alex Garcia is and was at all relevant times employed by

22 the Glendale Unified School District as a Counselor. All actions taken by

23 Defendant Garcia at Hoover High School were taken while acting in the course and

24 scope of his employment and were taken under color of state law. As more fully

25 set forth herein, Defendant Garcia was involved in the planning and the seizure,

26 search, detention, interrogation, and/or collection and maintenance of personal data

27 relating to one or more of the Plaintiffs. He is sued in his individual capacity.

28

35. Defendants Does 21-25 are and were at all relevant times employed

8

Case 2:11-cv-08484-ODW-SH Document 19 Filed 11/01/11 Page 10 of 24 Page ID #:90

1 by the Glendale Unified School District and acting under color of state law and in

2 the course and scope of their employment. Does 21-25 were involved in the

3 planning and the seizure, search, detention, interrogation, and/or collection and

4 maintenance of personal data relating to one or more of the Plaintiffs. They are

5 sued in their individual capacities.

6

36. Defendants Does 26-30 are and were at all relevant times employed

7 by the County of Los Angeles Probation Department and acting under color of

8 state law and in the course and scope of their employment. Does 26-30 were

9 involved in the planning and the seizure, search, detention, interrogation, and/or

10 collection and maintenance of personal data relating to one or more of the

11 Plaintiffs. They are sued in their individual capacities.

12

13

FACTUAL ALLEGATIONS

14

37. Approximately 2,100 students attend HHS. The student body is

15 diverse. About 57 percent of the students are Caucasian (of which 43 percent are

16 of Middle Eastern, primarily of Armenian descent); 25 percent are Latino; 9

17 percent are Asian; 7 percent are Filipino; and 2 percent are of other backgrounds?

18

38. Various groups of friends and classmates eat lunch in different places

19 around the campus. One group of mostly Latino students, including Plaintiffs K.L,

20 Parker, L.P., C.M., Pablo, A.F., and M.A., regularly ate lunch at a cluster of tables

21 on the first floor ofHHS. Another group of mostly Latino students, including

22 Plaintiff Barajas, regularly ate lunch on the second floor of HHS.

23

The Roundup of Latino Students on September 24, 2010

24

39. Before the lunch period on Friday, September 24,2010, gang officers

25

26 2 Hoover High School History and Info, available at
27 http://www.hooverhs.org/23191091185641103/site/default.asp (last visited 28 October 11,2011).

9

Case 2:11-cv-08484-ODW-SH Document 19 Filed 11/01/11 Page 11 of 24 Page ID #:91

1 from GPD and LAPD arrived at HHS and stationed themselves in two classrooms,

2 which were near the tables where the two groups of mostly Latino students

3 regularly ate lunch. As the students walked to the tables, HHS administrators

4 stopped them and directed them to the classrooms, one on the first floor and one on

5 the second floor.

6

40. Two HHS administrators - Defendants Eulmessekian and Mgrdichian

7 - approached the students on the first floor and told them that they needed to attend

8 a "meeting." The administrators then escorted the students into a classroom where

9 at least four uniformed GPD officers and one plainclothes police officer were

10 waiting. These officers included Defendants Bickells, Riley, Quintero, and Park.

11 Also in the room were Defendant Sweeney, an assistant principal, and Defendant

12 Davis, the school-based probation officer, and, for a portion of the incident,

13 Defendant Earl. Plaintiffs K.L, Parker, L.P., C.M., Pablo, A.F., and M.A., and

14 approximately 20 other students - all of whom are Latino - were corralled into this

15 first-floor classroom. Armed and uniformed police officers were stationed near the

16 classroom's two doors, and other police officers, as well as HHS administrators,

17 were arrayed around the room. Toward the end of the incident, three or four

18 officers wearing LAPD uniforms entered the room and helped process the students.

19

41. Meanwhile, on the second floor, an HHS administrator - Defendant

20 Garcia - directed students into the second-floor classroom. At least three LAPD

21 officers, one GPD officer, and an HHS administrator were waiting inside. As in

22 the first floor classroom, armed and uniformed police officers were stationed near

23 the classroom's entrance, and other police officers, as well as HHS administrators,

24 were arrayed around the room. Officers in this classroom frisked many of the

25 students as they were brought into the room. In total, approximately 25 Latino

26 students, including Plaintiff Barajas, were detained in the second-floor classroom.

27

42. In both classrooms, police officers told students that the police would

28 interview each student and that they had to provide the police with their personal

10

Case 2:11-cv-08484-ODW-SH Document 19 Filed 11/01/11 Page 12 of 24 Page ID #:92

1 information. The students were informed that they could not leave the classroom

2 until they had provided their information.

3

43. The police officers in both rooms then interrogated students

4 individually. Officers demanded students' personal information such as their

5 name, address, phone number, hair and eye color, age, weight, and birthday. The

6 officers asked about any tattoos or scars, took notes based on the students'

7 responses, and took photographs of students' tattoos. Officers also asked students

8 about criminal involvement, including whether they had ever been arrested or

9 placed on probation. Some officers used their police radios to relay information

10 that students provided.

11

44. During the individual interrogations, officers in both classrooms wrote

12 notes of what students told them on white index cards. The officers then took

13 "mug shots" of each student by instructing the student to hold up the card with his

14 or her information, facing out, and then taking a photograph of the student with the

15 card. Each one of the Plaintiffs was interviewed and photographed in this manner.

16 When one student objected and said that he wanted the information that had been

17 collected shredded because he had done nothing wrong, the police ignored him and

18 took his picture before releasing him.

19

45. During the operation, police officers told various students that they

20 were on a "gang list," that the police were gathering the students' photographs and

21 personal information so the police could easily identify the students if they got in

22 trouble in the future, and that the students' personal information was being

23 collected so that the officers could assess whether the students were "on the right

24 path." Defendants also asserted that the students who had been targeted either

25 belonged to or admired particular gangs.

26

46. While the students were detained, the police officers threatened the

27 students and used their official authority to intimidate the students into complying

28 with their demands, including, but not limited to the following:

11

Case 2:11-cv-08484-ODW-SH Document 19 Filed 11/01/11 Page 13 of 24 Page ID #:93

1 • When one student raised his voice and asked why the police were targeting

2

only one race, a police officer handcuffed the student and announced to the

3

rest of the students, "This is what happens to tough guys," as police officers

4

removed the student from the classroom.

5 • When other students asked why they were being detained, a police officer

6

told them, "Be quiet and keep your mouths shut."

7 • Another police officer told the students that they could no longer sit together

8

at lunch or hang out with each other in or outside of school and that, if they

9

did, the police would come back and the students would be in "even more

1 0

trouble."

11 • When another student protested that he was not a gang member, a police

12

officer proceeded to interrogate the student over his objections.

13 • When one male student tried to refuse to have his picture taken, the officers

14

threatened him and the other students, saying that if the students did not

15

cooperate, the officers would have to go to their homes at 6 a.m. and tell

16

their parents that the students were associating with gang members and

17

would obtain the students' information then.

18

47. During the operation, police officers confiscated several students' cell

19 phones and held them until the students were released. Officers reviewed text

20 messages on at least one student's phone. Neither the police nor the school

21 administrators asked for the consent of these students to search their cell phones,

22 nor did police or administrators have any reasonable basis to suspect that the cell

23 phones contained contraband or evidence of wrongdoing.

24

48. During the operation, Defendants also confiscated the backpacks of

25 several students, including Plaintiffs K.L. and A.F., searched the bags, and

26 removed student IDs that had been kept in the bags. Neither the police nor the

27 school administrators asked for the consent of these students to search their

28 backpacks, nor did police or administrators have any reasonable basis to suspect

12

Case 2:11-cv-08484-ODW-SH Document 19 Filed 11/01/11 Page 14 of 24 Page ID #:94

1 that the bags contained contraband or evidence of wrongdoing.

2

49. During the time the students were detained in the classrooms,

3 Defendants made it clear that the students were not free to leave. When one

4 student asked why he was there and stated that he wanted to leave, a police officer

5 told him to "sit down and shut up," while Defendant Eulmessekian told him that he

6 needed to be interviewed before he could leave. When another student asked to

7 use the bathroom, a police officer told her that she could not leave the room until

8 after her interview. When a third student protested that the police were intruding

9 on their lunch period, Defendant Eulmessekian called security officials who then

10 brought food for the students to the classroom. Finally, Plaintiff K.L.' s sister

11 learned that students, including her sister, were being questioned by police and

12 went directly to HSS to request an early dismissal for her sister. When the school

13 employee at the front office contacted Defendant Eulmessekian via radio to notify

14 him that K.L. needed to report to the front office for early dismissal, Defendant

15 Eulmessekian told the police officers that K.L. had to be interrogated and

16 photographed because she had to leave the classroom. Only after she had been

17 interrogated and photographed was she allowed to leave.

18

50. Students on the first floor were detained between about 60 and 90

19 minutes. Students on the second floor were detained for between about 30 and 60

20 minutes. Many students missed most or all of their fifth-period classes following

21 the lunch period because the police did not let them leave until they were

22 interviewed and photographed.

23

Defendants Conspired to Violate Plaintiffs' Rights by Targeting Them

24 Because They Are or Appear to Be Latino and by Detaining and Searching

25

Them without Individualized Suspicion

26

51. Based on the execution of the roundup and the interaction of the

27 various officers, the operation was clearly coordinated among the various

28 government agencies involved, with the police officers from GPD and LAPD

13

Case 2:11-cv-08484-ODW-SH Document 19 Filed 11/01/11 Page 15 of 24 Page ID #:95

1 arriving just prior to lunch and positioning themselves in classrooms near where

2 the targeted students typically sat for lunch. School administrators identified the

3 students who were required to enter the classrooms for interrogation as they

4 approached the tables, and Defendant Davis maintained a list of the students who

5 were detained during the operation. When the police officers who had been

6 stationed in the classroom on the second floor finished interrogating the students

7 on the second floor, they proceeded downstairs to the first floor classroom to assist

8 the school administrators and police officers in processing the remaining students.

9

52. Defendants targeted the students because they were or appeared to be

10 Latino. One student who is part Filipino and does not appear Latino regularly sat

11 at the tables on the first floor. This student was not instructed by the police

12 officers or school administrators to join the other students with whom he regularly

13 sits, and he continued to eat lunch while the other students, all of whom are or

14 appear to be Latino, were detained and interrogated in the classroom. Defendant

15 Rock later suggested that Defendants had not targeted only Latino students because

16 they had planned a similar operation at HHS targeting Armenian students.

17

53. In total, approximately 56 students - all Latino, and all of whom were

18 on school property and engaged in ordinary and proper activities associated with

19 attending school - were directed to enter one of the two classrooms, detained,

20 interrogated, threatened, and in many cases photographed and searched.

21 Defendants never identified any particular reason to believe that plaintiffs or any

22 other students in either room had violated any school policy, rule, or regulation or

23 had otherwise engaged in any unlawful conduct, nor did they have any such reason

24 or belief.

25

54. In coordinating and executing the roundup, the individual Defendants

26 abused their authority, took advantage of the weakness of Plaintiffs' position to

27 violate Plaintiffs' rights, and acted with willful and conscious disregard of the

28 Plaintiffs rights and with knowledge that their conduct would cause emotional

14

Case 2:11-cv-08484-ODW-SH Document 19 Filed 11/01/11 Page 16 of 24 Page ID #:96

1 harm to Plaintiffs.

2

Defendants' Actions Caused Plaintiffs Emotional Harm

3

55. The event left many of the students traumatized, fearful that they

4 would be arrested or detained in the future as a consequence of being targeted in

5 this operation, and wondering why only they - and not their non-Latino classmates

6 - had been targeted by the police and HHS administration.

7

56. Some of the Plaintiffs and other students became terrified from the

8 moment they first entered the classrooms filled with school administrators and

9 armed police officers, and remained terrified while Defendants held them there

10 against their will and subjected them to abusive language, invasive questioning,

11 and threats of further police action. Plaintiffs felt powerless and humiliated while

12 police questioned them, photographed tattoos, and forced them to pose for mock

13 mug shots. Because the officers told the students that they would come back if the

14 students continued hanging out together and that their photographs would be kept

15 in a gang file, Plaintiffs and other students believed that the police and school had

16 somehow marked them as gang members.

17

57. Following the incident, Plaintiffs and other students continued to

18 suffer from fear and shock. Plaintiffs variously lost their appetites, became

19 withdrawn around family, and stopped spending time with friends or sitting

20 regularly at the lunch tables. At least one Plaintiff became concerned about

21 associating with a cousin whom Defendants also detained in the roundup.

22 Plaintiffs remain fearful that the police and school administrators are watching

23 them and will follow through on their threats to engage in further action.

24

58. Students, teachers and administrators at HHS act differently toward

25 Plaintiffs since Defendants targeted them in the September 24 roundup. Plaintiffs

26 feel that teachers, administrators and even other students at HHS have identified

27 them as troublemakers because they were targeted in the roundup, and Plaintiffs no

28 longer view their high school as a safe and supportive environment. Indeed, one

15

Case 2:11-cv-08484-ODW-SH Document 19 Filed 11/01/11 Page 17 of 24 Page ID #:97

1 Plaintiff transferred to another school in part because of how administrators treated

2 him on September 24 and afterwards.

3

59. Because Defendants targeted them in the roundup and collected

4 information on them, Plaintiffs also fear that they have been identified by police as

5 gang members or likely criminals. Since the roundup, the police have stopped at

6 least one Plaintiff and questioned him about affiliating with the same gang he had

7 been questioned about during the roundup, even though the police had never asked

8 about him about gang affiliation before the roundup.

9

60. The roundup has also affected the hopes and aspirations of the high

10 school students whom Defendants detained. Among Plaintiffs are students who

11 want to join the military or become police officers, but who now fear that because

12 of Defendants' actions they have been placed on lists as gang members that will

13 prevent them from attaining their goals.

14

Defendants' Shifting Explanations for the Roundup

15

61. During the weeks that followed the roundup, parents and family

16 members of the targeted students and other adults spoke with various Defendants,

17 including Defendants Earl, Rock, and Davis, as well as with other representatives

18 of GUSD, about the roundup on several occasions. The parents and other adults

19 expressed concerns about the roundup, sought additional information about its

20 planning and execution, and requested that Defendants ensure that all information

21 collected during the roundup was destroyed.

22

62. Defendants responded to the expressed concerns with shifting and

23 conflicting explanations of who had initiated the roundups and what purpose they

24 served. School officials (including Defendant Earl) first maintained that the police

25 had requested the roundup and that they did not have a list of the students targeted

26 or that the list had been destroyed, but later admitted having such a list. GPD

27 officials (including Captain Rock) told Plaintiffs and others that the roundup was

28 an "educational seminar" intended to teach them the risks of gang involvement and

16

Case 2:11-cv-08484-ODW-SH Document 19 Filed 11/01/11 Page 18 of 24 Page ID #:98

1 that the operations had been requested by the school. Other Defendants stated that

2 the idea for the roundup had come from Defendant Davis, the school-based

3 probation officer assigned to HHS.

4

63. For months after the September 24 incident, Plaintiffs, their parents,

5 and others repeatedly requested written confirmation from Defendants that the

6 information gathered in the roundups would be destroyed and not retained in any

7 of Defendants' files. Although various Defendants initially agreed and stated that

8 the September 24, 2010 operation was a mistake, they later retracted their offer to

9 provide such written confirmation that all information collected would be

10 destroyed, and none was ever provided.

11 The September 24, 2010 Roundup Is Part of a Custom and Practice by the

12 Probation Department and GPD of Detaining Students Based on Their Race

13

or Ethnicity and without Individualized Suspicion of Wrongdoing

14

64. Similar roundups have been conducted at the behest of school-based

15 probation officers on other campuses in Los Angeles County, and those operations

16 served as the model for the September 24 roundup at HHS. The plan for the

17 roundup was approved by Defendant Van Hoof, who supervises school-based

18 probation officers for the County, and who was personally present during the

19 September 24 roundup and approved the manner in which the roundup was

20 conducted.

21

65. In the days following the roundup, Defendant Rock, in responding to

22 concerns that the GPD had discriminatorily targeted Latino students, stated that

23 GPD intended to conduct similar operations targeting Armenian students at HHS.

24

25

CLASS ALLEGATIONS

26

66. Plaintiffs K.L., Parker, L.P., C.M., Pablo, A.F., Barajas, and M.A.

27 bring all claims for injunctive and declaratory relief on behalf of themselves and all

28 other persons similarly situated, pursuant to Federal Rule of Civil Procedure 23.

17

Case 2:11-cv-08484-ODW-SH Document 19 Filed 11/01/11 Page 19 of 24 Page ID #:99

I

67. The plaintiff class consists of:

2

Students at Hoover High School who were detained during lunch

3

and/or the following period by Defendants on September 24,2010.

4

68. Class action status for this litigation is proper because:

5

(a) The plaintiff class is so numerous that joinder of all members is

6 impractical;

7

(b) There are questions of law and fact common to the class;

8

(c) Plaintiffs' claims are typical of the claims of the class, in that

9 Plaintiffs, like all of their peers who were targeted by Defendants, were detained

10 and interrogated by Defendants without lawful justification, as part of an operation

II that was planned and executed by Defendants with the intent of targeting Latino

12 students;

13

(d) Plaintiffs will fairly and adequately protect the interests of the

14 class, as there is no conflict between Plaintiffs and the other class members; and

15

(e) Plaintiffs can adequately represent the interests of the class

16 members and have retained counsel experienced in class action litigation.

17

69. Defendants have acted and/or refused to act on grounds generally

18 applicable to the class, thereby making final declaratory and injunctive relief

19 appropriate with respect to the class as a whole, under Federal Rule of Civil

20 Procedure 23(b)(2).

21

22

FIRST CAUSE OF ACTION

23

Violation of 42 U.S.C. § 1983

24

(Unlawful Search and Seizure in Violation of the Fourth Amendment)

25

70. Plaintiffs incorporate by reference the foregoing paragraphs of this

26 Complaint as though fully set forth herein.

27

71. Defendants, acting in concert with one another, violated Plaintiffs'

28 right to be free from unreasonable searches and seizures under the Fourth

18

Case 2:11-cv-08484-ODW-SH Document 19 Filed 11/01/11 Page 20 of 24 Page ID #:100

1 Amendment to the United States Constitution during the operation conducted at

2 Hoover High School on September 24,2010.

3

72. Defendants were acting under color of state law, thereby violating 42

4 U.S.C. § 1983.

5

6

SECOND CAUSE OF ACTION

7

Violation of 42 U.S.C. § 1983

8 (Discrimination on Account of Race, Ancestry or National Origin in Violation

9

of the Equal Protection Clause of the Fourteenth Amendment)

10

73. Plaintiffs incorporate by reference the foregoing paragraphs of this

11 Complaint as though fully set forth herein.

12

74. Defendants, acting in concert with one another, targeted Plaintiffs in

13 the roundup because of their race, ancestry, or national origin during the operation

14 conducted at Hoover High School on September 24,2010, in violation of the Equal

15 Protection Clause of the Fourteenth Amendment.

16

75. Defendants were acting under color of state law, thereby violating 42

17 U.S.C. § 1983.

18

19

THIRD CAUSE OF ACTION

20

Violation of 42 U.S.C. § 1985(3)

21

(Conspiracy to Violate Civil Rights)

22

76. Plaintiffs incorporate by reference the foregoing paragraphs of this

23 Complaint as though fully set forth herein.

24

77. In planning and executing the roundup at Hoover High School on

25 September 24,2010, Defendants conspired to target students who are or appear to

26 be Latino and then to detain and interrogate only the targeted students, without

27 lawful justification, thereby depriving them of their right to equal protection under

28 the law.

19

Case 2:11-cv-08484-ODW-SH Document 19 Filed 11/01/11 Page 21 of 24 Page ID #:101

1

78. Defendants did, in fact, intentionally target students during the

2 roundup because they are or appear to be Latino, and understood at the time they

3 were conducting the operation that the operation was intended to target students

4 who are or appear to be Latino.

5

79. The acts done by Defendants in furtherance of the conspiracy,

6 including directing Plaintiffs to enter the classrooms and then detaining Plaintiffs

7 in the classroom until they had submitted to interrogation and, in some cases,

8 searches and being photographed, resulted in an injury to Plaintiffs and prevented

9 them from enjoying the rights to equal protection and to be free of unreasonable

10 searches and seizures.

11

12

FOURTH CAUSE OF ACTION

13

Violation of Article 1, Section 7 of the California Constitution

14

(Discrimination on Account of Race, Ancestry, and National Origin)

15

80. Plaintiffs incorporate by reference the foregoing paragraphs of this

16 Complaint as though fully set forth herein.

17

81. Defendants, acting in concert with one another, targeted Plaintiffs in

18 the roundup because of their race, ancestry, or national origin during the operation

19 conducted at Hoover High School on September 24,2010, in violation Article 1,

20 Section 7 of the California Constitution.

21

22

FIFTH CAUSE OF ACTION

23

Violation of Article I, Section 13 of the California Constitution

24

(Unlawful Search and Seizure)

25

82. Plaintiffs incorporate by reference the foregoing paragraphs of this

26 Complaint as though fully set forth herein.

27

83. Defendants, acting in concert with one another, violated Plaintiffs'

28 right to be free from unreasonable searches and seizures under Article 1, Section

20

Case 2:11-cv-08484-ODW-SH Document 19 Filed 11/01/11 Page 22 of 24 Page ID #:102

1 13 of the California Constitution during the operation conducted at Hoover High

2 School on September 24,2010.

3

4

SIXTH CAUSE OF ACTION

5

Violation of California Civil Code § 52.1

6

84. Plaintiffs incorporate by reference the foregoing paragraphs of this

7 Complaint as though fully set forth herein.

8

85. Defendants threatened, intimidated, and coerced plaintiffs in a manner

9 that interfered with their exercise and enjoyment of rights secured by the

10 Constitution and laws of the United States and rights secured by the Constitution

11 and laws of the State of California, including but not limited to their rights to be

12 free from unreasonable searches and their right to equal protection of the laws.

13

86. Defendants' conduct described above interfered and/or attempted to

14 interfere with Plaintiffs' exercise and/or enjoyment of their rights secured by the

15 Constitution and laws of the United States and by the Constitution and laws of the

16 state of California, in violation of California Civil Code § 52.1.

17

18

REQUEST FOR RELIEF

19

Plaintiffs respectfully request that this Court grant the following relief:

20

A. Certify a class for all claims for injunctive and declaratory relief in

21 this Complaint pursuant to Federal Rule of Civil Procedure 23, in accordance with

22 the allegations in this Complaint and the forthcoming class certification motion;

23

B. Issue an injunction prohibiting Defendants, and all those acting in

24 concert with them or acting under their supervision or control, from detaining,

25 searching, seizing the belongings of, interrogating, or photographing students at

26 Hoover High School, without probable cause or reasonable suspicion to believe

27 that the student has violated a valid school rule or has violated the law, or based on

28 their race, ethnicity, or national origin;

21

Case 2:11-cv-08484-ODW-SH Document 19 Filed 11/01/11 Page 23 of 24 Page ID #:103

1

C. Issue an injunction requiring the Defendants to destroy or return any

2 information about Plaintiffs and the Plaintiff class gathered by Defendants during

3 the September 24, 2010 roundup, to ensure that no information about Plaintiffs and

4 the Plaintiff class gathered during the September 24,2010 roundup is retained in

5 any file, database, or other system maintained by Defendants or to which

6 Defendants have access, and to clear Plaintiffs of any wrongdoing in connection

7 with the September 24, 2010 roundup before any entities with whom Defendants

8 have shared information about the roundup;

9

D. Award Plaintiffs compensatory and general damages, in an amount to

lObe proven at trial, against the City of Glendale, the County of Los Angeles, and the

11 City of Los Angeles and against each of the individual Defendants sued in his or

12 her personal capacity;

13

E. Award Plaintiffs exemplary damages for violations of California law

14 and punitive damages for violations of federal law, each in an amount to be proven

15 at trial, against each of the individual Defendants sued in his or her personal

16 capacity;

17

F. Award statutory damages and penalties to Plaintiffs pursuant to

18 California Civil Code §§ 52 and 52.1 (b) against the City of Glendale, the County

19 of Los Angeles, and the City of Los Angeles, and against each of the individual

20 defendants sued in his or her personal capacity;

21

G. Declare that Defendants' conduct, as described in this Complaint,

22 violated the rights of Plaintiffs and the Plaintiff class under the constitutions and

23 laws of the United States and the State of California;

24

H. Award Plaintiffs their costs, expenses and reasonable attorney's fees

25 pursuant to 42 U.S.C. § 1988, California Civil Codes §§ 52(b) and 52.1 (h),

26 California Code of Civil Procedure § 1021.5, and any other appropriate statutory

27 basis; and

28

22

Case 2:11-cv-08484-ODW-SH Document 19 Filed 11/01/11 Page 24 of 24 Page ID #:104

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I. Grant such other relief as the Court may deem just and proper.

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3 Respectfully Submitted, 4

ACLU FOUNDATION OF SOUTHERN CALIFORNIA

5 6 Dated: October 21, 2011
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By:._...Y-.m_-w;---_ -=-~_ _~ _
David B. Sapp
Attorneys for Plaintiffs

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9 10 11 Dated: October 21, 2011 12 13

TRABER & VOORHEES
By: 5J4t-- ~~ (tA.$)
Bert Voorhees Attorneys for Plaintiffs

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 Case: 2:11-cv-8484 As of: 05/28/2014 06:56 AM PDT 1 of 14 (SHx),CLOSED,DISCOVERY
UNITED STATES DISTRICT COURT for the CENTRAL DISTRICT OF CALIFORNIA (Western Division − Los Angeles)
CIVIL DOCKET FOR CASE #: 2:11−cv−08484−ODW−SH

K. L. et al v. City of Glendale et al Assigned to: Judge Otis D. Wright, II Referred to: Magistrate Judge Stephen J. Hillman Related Case: 2:12−cv−02763−ODW−SH Cause: 42:1983 Civil Rights Act
Plaintiff

Date Filed: 10/13/2011 Date Terminated: 09/16/2013 Jury Demand: Both Nature of Suit: 440 Civil Rights: Other Jurisdiction: Federal Question

K. L. by her Guardian Ad Litem Osiel Lopez, on behalf of themselves and all those similarly situated

represented by Bertram G Voorhees Traber &Voorhees 128 North Fair Oaks Suite 204 Pasadena, CA 91103 626−585−9611 Fax: 626−585−1400 Email: bv@tvlegal.com ATTORNEY TO BE NOTICED

David B Sapp ACLU Foundation of Southern California 1313 West Eighth Street Los Angeles, CA 90017 213−977−9500 Fax: 213−977−5297 Email: dsapp@aclu−sc.org ATTORNEY TO BE NOTICED

Lauren K Teukolsky Traber and Voorhees 128 North Fair Oaks Avenue Pasadena, CA 91103−3614 626−585−9611 Fax: 626−585−1400 Email: lt@tvlegal.com ATTORNEY TO BE NOTICED

Peter Bibring ACLU Foundation of Southern California 1313 West Eight Street Los Angeles, CA 90017 213−977−9500 Fax: 213−977−5297 Email: pbibring@aclu−sc.org ATTORNEY TO BE NOTICED

Plaintiff
Anthony Parker on behalf of themselves and all those similarly situated

represented by Bertram G Voorhees (See above for address) ATTORNEY TO BE NOTICED

David B Sapp (See above for address) ATTORNEY TO BE NOTICED

Lauren K Teukolsky (See above for address) ATTORNEY TO BE NOTICED

Case: 2:11-cv-8484 As of: 05/28/2014 06:56 AM PDT 2 of 14

Peter Bibring (See above for address) ATTORNEY TO BE NOTICED

Plaintiff
L. P. by his Guardian Ad Litem Juana Farfan, on behalf of themselves and all those similarly situated

represented by Bertram G Voorhees (See above for address) ATTORNEY TO BE NOTICED
David B Sapp (See above for address) ATTORNEY TO BE NOTICED

Lauren K Teukolsky (See above for address) ATTORNEY TO BE NOTICED

Peter Bibring (See above for address) ATTORNEY TO BE NOTICED

Plaintiff
C. M. by his Guardian Ad Litem Christine Clavesilla, on behalf of themselves and all those similarly situated

represented by Bertram G Voorhees (See above for address) ATTORNEY TO BE NOTICED
David B Sapp (See above for address) ATTORNEY TO BE NOTICED

Lauren K Teukolsky (See above for address) ATTORNEY TO BE NOTICED

Peter Bibring (See above for address) ATTORNEY TO BE NOTICED

Plaintiff
Giovanni Pablo on behalf of themselves and all those similarly situated

represented by Bertram G Voorhees (See above for address) ATTORNEY TO BE NOTICED

David B Sapp (See above for address) ATTORNEY TO BE NOTICED

Lauren K Teukolsky (See above for address) ATTORNEY TO BE NOTICED

Peter Bibring (See above for address) ATTORNEY TO BE NOTICED

Plaintiff
A. F. by her Guardian Ad Litem Cristina Pablo,on behalf of themselves and all those similarly situated

represented by Bertram G Voorhees (See above for address) ATTORNEY TO BE NOTICED
David B Sapp (See above for address)

Case: 2:11-cv-8484 As of: 05/28/2014 06:56 AM PDT 3 of 14

ATTORNEY TO BE NOTICED

Lauren K Teukolsky (See above for address) ATTORNEY TO BE NOTICED

Peter Bibring (See above for address) ATTORNEY TO BE NOTICED

Plaintiff
Alejandro Barajas on behalf of themselves and all those similarly situated

represented by Bertram G Voorhees (See above for address) ATTORNEY TO BE NOTICED

David B Sapp (See above for address) ATTORNEY TO BE NOTICED

Lauren K Teukolsky (See above for address) ATTORNEY TO BE NOTICED

Peter Bibring (See above for address) ATTORNEY TO BE NOTICED

V. Defendant City of Glendale TERMINATED: 09/21/2012
Defendant County of Los Angeles TERMINATED: 09/16/2013
Defendant City of Los Angeles TERMINATED: 09/27/2013
Defendant

represented by Ann M Maurer Glendale City Attorney 613 East Broadway Suite 220 Glendale, CA 91206 818−548−2080 Fax: 818−547−4302 Email: amaurer@ci.glendale.ca.us ATTORNEY TO BE NOTICED
represented by Jennifer A D Lehman Los Angeles County Counsel 651 Kenneth Hahn Hall of Administration 500 West Temple Street Los Angeles, CA 90012−2713 213−974−1908 Email: jlehman@counsel.lacounty.gov ATTORNEY TO BE NOTICED
represented by Colleen R Smith Office of the City Attorney City Hall East 200 North Main Street 6th Floor Los Angeles, CA 90012−4129 213−978−7027 Fax: 213−978−8785 Email: colleen.smith@lacity.org ATTORNEY TO BE NOTICED

Case: 2:11-cv-8484 As of: 05/28/2014 06:56 AM PDT 4 of 14

Michael Rock individual TERMINATED: 02/06/2013

Defendant
Michael Rock in his official capacities TERMINATED: 02/06/2013

represented by Ann M Maurer (See above for address) ATTORNEY TO BE NOTICED

Defendant
Officer Riley in his individual capacity TERMINATED: 02/06/2013

represented by Ann M Maurer (See above for address) ATTORNEY TO BE NOTICED

Defendant
Officer Bickells his individual capacity TERMINATED: 02/06/2013

represented by Ann M Maurer (See above for address) ATTORNEY TO BE NOTICED

Defendant
Officer Quintero his individual capacity TERMINATED: 02/06/2013

Defendant
Officer Park his individual capacity

represented by Colleen R Smith (See above for address) ATTORNEY TO BE NOTICED

Defendant
Thomas Van Hoof individual TERMINATED: 09/16/2013

represented by Jennifer A D Lehman (See above for address) ATTORNEY TO BE NOTICED

Defendant
Thomas Van Hoof in his official capacity TERMINATED: 09/16/2013

represented by Jennifer A D Lehman (See above for address) ATTORNEY TO BE NOTICED

Defendant
Gilda Davis in her individual capacity TERMINATED: 09/16/2013

represented by Jennifer A D Lehman (See above for address) ATTORNEY TO BE NOTICED

Defendant
Jennifer Earl individual TERMINATED: 03/06/2013

Defendant
Jennifer Earl in her official capacities TERMINATED: 03/06/2013

Defendant
Hagop Eulmessekian in his individual capacity TERMINATED: 03/06/2013

Case: 2:11-cv-8484 As of: 05/28/2014 06:56 AM PDT 5 of 14
Defendant Caroline Sweeney in her individual capacity TERMINATED: 03/06/2013
Defendant Ara Mgrdichian in his individual capacity TERMINATED: 03/06/2013
Defendant Alex Garcia in his individual capacity TERMINATED: 03/06/2013
Defendant Does 1−10 in their individual capacities

Date Filed 10/13/2011 10/13/2011
10/17/2011 10/17/2011 10/17/2011 10/17/2011
10/17/2011 10/17/2011 10/17/2011 10/17/2011

# Docket Text
LODGED COMPLAINT forwarded to DUTY Magistrate Judge Ralph Zarefsky. Complaint sought to be filed by Plaintiffs Alejandro Barajas, A. F., K. L., C. M., L. P., Giovanni Pablo, Anthony Parker. (ghap) (Entered: 10/18/2011)
1 EX PARTE APPLICATION Plaintiffs respectfully request permission to file Petitions for Appointment of Guardian ad Litem for Plaintiffs K.L., L.P., C.M. and A.F. under seal, in order to comply with Federal Rule of Civil Procedure 5.2 and Local Rule 79−5.4. Plaintiffs are filing their Petitions for Appointment of Guardian ad Litem concurrently with this application to seal, filed by plaintiffs Alejandro Barajas, A. F., K. L., C. M., L. P., Giovanni Pablo, Anthony Parker. Lodged Proposed Order.(ghap) (mg). (Entered: 10/18/2011)
2 SEALED DOCUMENT − PETITION for Appointment of Juana Farfan as Guardian ad Litem for L.P. Lodged Proposed Order.(car) Modified on 10/20/2011 (car). (mg). (Entered: 10/20/2011)
3 SEALED ORDER by Magistrate Judge Ralph Zarefsky: granting 2 Petition to Appoint Guardian ad Litem. Appointing Juana Farfan as Guardian ad Litem for L.P. (car) Modified on 10/28/2011 (car). (Entered: 10/20/2011)
4 SEALED DOCUMENT PETITION for Appointment of Osiel Lopez as Guardian ad Litem for K.L. Lodged Proposed Order.(car) (mg). (Entered: 10/20/2011)
5 SEALED ORDER by Magistrate Judge Ralph Zarefsky: granting 4 Petition to Appoint Guardian ad Litem. Appointing Osiel Lopez as Guardian ad Litem for K.L. (car) Modified on 10/20/2011 (car). Modified on 10/20/2011 (car). Modified on 10/28/2011 (car). (Entered: 10/20/2011)
6 SEALED DOCUMENT − PETITION for Appointment of Christine Clavesilla as Guardian ad Litem for C.M. Lodged Proposed Order.(car) Modified on 10/20/2011 (car). (mg). (Entered: 10/20/2011)
7 SEALED ORDER by Magistrate Judge Ralph Zarefsky: granting 6 Petition to Appoint Guardian ad Litem. Appointing Christine Clavesilla as Guardian ad Litem for C.M. (car) Modified on 10/28/2011 (car). (Entered: 10/20/2011)
8 SEALED DOCUMENT − PETITION for Appointment of Cristina Pablo as Guardian ad Litem for A.F. Lodged Proposed Order.(car) Modified on 10/20/2011 (car). (mg). (Entered: 10/20/2011)
9 SEALED ORDER by Magistrate Judge Ralph Zarefsky: granting 8 Petition to Appoint Guardian ad Litem. Appointing Cristina Pablo as Guardian ad Litem for A.F. (car) Modified on 10/28/2011 (car). (Entered: 10/20/2011)

Case: 2:11-cv-8484 As of: 05/28/2014 06:56 AM PDT 6 of 14

10/17/2011 10/17/2011
10/17/2011
10/17/2011 10/17/2011 10/17/2011 10/21/2011
10/21/2011 10/27/2011 10/31/2011 10/31/2011
11/01/2011

10 ORDER by Magistrate Judge Ralph Zarefsky: granting 1 Ex Parte Application to Seal Petitions for Appointment of Guardian ad Litem. (car) (Entered: 10/20/2011)
11 COMPLAINT against Defendants. Case assigned to Judge Otis D Wright, II for all further proceedings. Discovery referred to Magistrate Judge Stephen J Hillman.(Filing fee $ 350 PAID) Jury Demanded, filed by plaintiffs A. F., Giovanni Pablo, K. L., C. M., Alejandro Barajas, L. P., Anthony Parker.(car) (Additional attachment(s) added on 10/27/2011: # 1 Ntc of Assignment, # 2 Summons) (mg). (Additional attachment(s) added on 10/27/2011: # 3 Civil Cover Sheet) (mg). (Entered: 10/20/2011)
21 DAY Summons Issued re Complaint 11 as to Defendants Officer Bickells, City of Glendale, City of Los Angeles, County of Los Angeles, Gilda Davis, Jennifer Earl, Jennifer Earl, Hagop Eulmessekian, Alex Garcia, Thomas Van Hoof(in his official capacity), Thomas Van Hoof(individual), Ara Mgrdichian, Officer Park, Officer Quintero, Officer Riley, Michael Rock(in his official capacities), Michael Rock(individual), Caroline Sweeney. (car) (Entered: 10/21/2011)
12 NOTICE of Interested Parties filed by Plaintiffs Alejandro Barajas, A.F., K.L., C.M., L.P., Giovanni Pablo, Anthony Parker (car) (mg). (Entered: 10/21/2011)
13 NOTICE of Related Case(s) filed by plaintiffs Alejandro Barajas, A. F., K. L., C. M., L. P., Giovanni Pablo, Anthony Parker. Related Case(s): No related cases (car) (mg). (Entered: 10/21/2011)
14 DECLARATION of David B. Sapp In Compliance With Local Rule 7−19.1 filed by Plaintiffs Alejandro Barajas, A. F., K. L., C. M., L. P., Giovanni Pablo, Anthony Parker. (car) (mg). (Entered: 10/21/2011)
15 NOTICE of Manual Filing filed by Plaintiffs Alejandro Barajas, A. F., K. L., C. M., L. P., Giovanni Pablo, Anthony Parker of First Amended Complaint; Ex Parte Application to File Under Seal Petition for Guardian Ad Litem of M.A.; Proposed Order Granting Ex Parte Application; Petition for Appointment of Guardian Ad Litem of M.A.; Proposed Order Granting Petiition for Guardian Ad Litem of M.A.. (Bibring, Peter) (Entered: 10/21/2011)
16 EX PARTE APPLICATION to file under seal petition for appointment of guardian ad litem of M.A. ; declaration of David b Sapp in support filed by plaintiff Alejandro Barajas.(lc) (Entered: 10/26/2011)
17 ORDER by Judge Otis D Wright, II: granting 16 Plaintiffs Petition for Appointment of Guardian Ad Litem for Plaintiff M.A. be filed under seal in order to protect the identity of the minor Plaintiff in this matter. (lc) (Entered: 10/28/2011)
18 NOTICE of Change of Attorney Information for attorney Lauren K Teukolsky counsel for Plaintiffs Alejandro Barajas, A. F., K. L., C. M., L. P., Giovanni Pablo, Anthony Parker. Adding Lauren Teukolsky as attorney as counsel of record for K.L., et al. for the reason indicated in the G−06 Notice. Filed by Plaintiffs Lauren Teukolsky (Teukolsky, Lauren) (Entered: 10/31/2011)
22 ORDER GRANTING EX PARTE APPLICATION TO FILE UNDER SEAL PETITION FOR APPOINTMENT OFGUARDIAN AD LITEM OF M.A. by Magistrate Judge Ralph Zarefsky. IT IS THEREFORE ORDERED that Plaintiffs' Petition for Appointment of Guardian Ad Litem for Plaintiff M.A. be filed under seal in order to protect the identity of the minor Plaintiff in this matter. (mz) (Entered: 11/04/2011)
19 FIRST AMENDED COMPLAINT against defendants Bickells, City of Glendale, City of Los Angeles, County of Los Angeles, Gilda Davis, Does, Jennifer Earl, Jennifer Earl, Hagop Eulmessekian, Alex Garcia, Thomas Van Hoof(in his official capacity), Thomas Van Hoof(individual), Ara Mgrdichian, Park, Quintero, Riley, Michael Rock(in his official capacities), Michael Rock(individual), Caroline Sweeney amending Complaint − (Discovery) 11 filed by plaintiffs A. F., Giovanni Pablo, K. L., C. M., Alejandro Barajas, L. P., Anthony Parker (lc) (Additional attachment(s) added on 11/8/2011: # 1 issued summons) (lc). (Entered: 11/04/2011)

Case: 2:11-cv-8484 As of: 05/28/2014 06:56 AM PDT 7 of 14

11/01/2011 11/01/2011 11/07/2011 11/23/2011 11/28/2011
11/30/2011 12/13/2011
02/02/2012 02/16/2012
02/22/2012 02/27/2012

20 SEALED DOCUMENT− PETITION for Appointment of Guardian ad Litem for M.A.(mat) (Entered: 11/04/2011)
21 SEALED DOCUMENT− ORDER granting Petition for Appointment of Guardian ad Litem M.A. (mat) (Entered: 11/04/2011)
21 DAY Summons Issued re Amended Complaint,, 19 as to defendants Bickells, City of Glendale, City of Los Angeles, County of Los Angeles, Gilda Davis, Does, Jennifer Earl, Jennifer Earl, Hagop Eulmessekian, Alex Garcia, Thomas Van Hoof(in his official capacity), Thomas Van Hoof(individual), Ara Mgrdichian, Park, Quintero, Riley, Michael Rock(in his official capacities), Michael Rock(individual), Caroline Sweeney. (lc) (Entered: 11/08/2011)
23 (Attachments: # 1 Proposed Order)(Maurer, Ann) (Entered: 11/23/2011)
24 NOTICE TO FILER OF DEFICIENCIES in Electronically Filed Documents RE: Miscellaneous Document 23 . The following error(s) was found: Incorrect event selected. The correct event is: Request (for leave to or continue). In response to this notice the court may order (1) an amended or correct document to be filed (2) the document stricken or (3) take other action as the court deems appropriate. You need not take any action in response to this notice unless and until the court directs you to do so. (sch) (Entered: 11/28/2011)
25 ORDER by Judge Otis D Wright, II, upon stipulation 23 : The time for service of the first amended complaint on the named defendants be extended to allow service within 90 days from date of entry of this order. The case be Referred forthwith to Magistrate Judge Woehrle for a mandatory settlement conference and that the mandatory settlement conference take place prior to the expiration of the 90 days noted above. (lc) (Entered: 11/30/2011)
26 SETTLEMENT CONFERENCE ORDER by Magistrate Judge Carla Woehrle, This matter having been referred to U.S. Magistrate Judge Carla Woehrle for settlement conference by U.S. District Judge Wright, IT IS ORDERED that a settlement conference shall be held in the chambers of Judge Woehrle on February 2, 2012 at 3:00 p.m., Room 640, 6th Floor of the Roybal Courthouse, 255 E. Temple Street, Los Angeles, CA. The conference should be attended by persons with meaningful authority to negotiate and agree to a settlement of the case. The parties shall submit settlement conference statements directly to Judge Woehrles chambers not later than three (3) court days before the conference. These statements are to be exchanged with opposing counsel. The statements shall not be filed in the court record. (SEE ORDER FOR FURTHER DETAILS) (lmh) (Entered: 12/14/2011)
27 MINUTES OF Settlement Conference held before Magistrate Judge Carla Woehrle, Settlement conference held. Counsel are to confer further and are to contact the court clerk to schedule a continued settlement conference. (lmh) (Entered: 02/08/2012)
28 ORDER by Magistrate Judge Carla Woehrle, The parties are notified that a further settlement conference is set to take place on March 1, 2012 at 10:00 a.m. before the Honorable Carla M. Woehrle, Room 640, 6th Floor of the Roybal Courthouse, 255 E. Temple Street, Los Angeles, CA. The conference should be attended by persons with meaningful authority to negotiate and agree to a settlement of the case. The parties shall submit an updated settlement conference statements directly to Judge Woehrles chambers not later than three (3) court days before the conference. These statements are to be exchanged with opposing counsel. The statements shall not be filed in the court record. (SEE ORDER FOR FURTHER DETAILS) (lmh) (Entered: 02/16/2012)
29 (Attachments: # 1 Proposed Order)(Maurer, Ann) (Entered: 02/22/2012)
30 NOTICE TO FILER OF DEFICIENCIES in Electronically Filed Documents RE: Miscellaneous Document 29 . The following error(s) was found: Incorrect event selected. The correct event is: Stipulation: order. In response to this notice the court may order (1) an amended or correct document to be filed (2) the document stricken or (3) take other action as the court deems appropriate. You need not take any action in response to this notice unless and until the court directs you to do so. (lc) (Entered: 02/27/2012)

Case: 2:11-cv-8484 As of: 05/28/2014 06:56 AM PDT 8 of 14

02/28/2012 03/01/2012 03/12/2012
03/14/2012 04/12/2012 05/03/2012 05/04/2012 05/11/2012 05/18/2012 05/30/2012

31 MINUTE ORDER IN CHAMBERS by Magistrate Judge Carla Woehrle, The parties are notified that the further settlement conference set to take place on March 1, 2012, is continued and now scheduled for Monday, March 12, 2012 at 10:00 a.m. before the Honorable Carla M. Woehrle, Room 640, 6th Floor of the Roybal Courthouse, 255 E. Temple Street, Los Angeles, CA. re: Order, Set/Reset Hearing 28 (lmh) (Entered: 02/28/2012)
32 ORDER by Judge Otis D Wright, II, 29 That the time for service of the First Amended Complaint under Federal Rule of Civil Procedure 4(m) on the named defendants be extended to allow service within 90 days from the date of entry of this order. (lc) (Entered: 03/01/2012)
33 MINUTES OF Settlement Conference held before Magistrate Judge Carla Woehrle, Settlement conference held. Agreement is reached in principle between Plaintiffs and City of Glendale/Glendale Unified School District defendants. Agreement is subject to agency approval, approval of minors compromise, and motion for determination of good faith settlement. A telephonic conference regarding settlement status is set for April 12, 2012, at 4:00 p.m. The court clerk will provide a call−in number for the conference. No settlement agreement is reached at this time with City of Los Angeles and County of Los Angeles defendants. The court will schedule further settlement proceedings as warranted. (lmh) (Entered: 03/13/2012)
34 MINUTE ORDER IN CHAMBERS by Magistrate Judge Carla Woehrle, Counsel are notified of the call−in−information for the Telephonic Conference scheduled to take place on Thursday, April 12, 2012 at 4:00 p.m. The call−in information for the hearing is listed below: Call−in Number: 213−894−0800, Meeting ID: 7002#, User Password: 0371#. If you have any problems connecting to this call, please contact Donna Thomas at 213−894−6825. re: Settlement Conference, Set/Reset Hearing 33 . (lmh) (Entered: 03/14/2012)
35 MINUTES OF Settlement Conference held before Magistrate Judge Carla Woehrle: Parties are to confer further regarding documentation of agreement. A continued telephonic status conference is set for May 3, 2012 at 3:00 p.m. **SEE ORDER FOR FURTHER DETAILS** (dt) (Entered: 04/13/2012)
36 MINUTE ORDER IN CHAMBERS by Magistrate Judge Carla Woehrle: Counsel are notified that the conference call scheduled for Thursday, May 3, 2012 at 3:00 p.m. is continued and now scheduled to take place on Friday, May 4, 2012 at 3:00 p.m. The call−in information for the telephonic conference is listed. **SEE ORDER FOR FURTHER DETAILS** (dt) (Entered: 05/03/2012)
37 MINUTES OF Settlement Conference held before Magistrate Judge Carla Woehrle: Telephonic conference held regarding settlement status between plaintiffs and defendants City of Glendale/Glendale Unified School District. Parties are to confer further regarding documentation. A continued telephonic status conference is set for May 18, 2012, at 3:00 p.m. (dt) (Entered: 05/07/2012)
38 MINUTE ORDER (IN CHAMBERS) by Magistrate Judge Carla Woehrle. Counsel are notified that the call−in information for the conference call scheduled for Friday, May 18, 2012 at 3:00 p.m. is listed below:Call−in Number: 213/894−0800; Meeting ID: 7002# ; User Password: 1336# ; If you have any problems connecting to this call, please contact Donna Thomas at 213/894−6825. (gr) (Entered: 05/11/2012)
39 MINUTES OF Settlement Status Conference held before Magistrate Judge Carla Woehrle. Telephonic conference held regarding status of settlement between Plaintiffs and defendants City of Glendale/Glendale Unified School District. Parties are to confer further regarding completion of documentation. A continued telephonic status conference is set for June 15, at 2:00 p.m. The court clerk will provide a call−in number for the conference. (gr) (Entered: 05/21/2012)
40 Joint STIPULATION for Extension of Time to File to serve complaint filed by Plaintiffs Alejandro Barajas, A. F., K. L., C. M., L. P., Giovanni Pablo, Anthony Parker. (Attachments: # 1 Proposed Order)(Bibring, Peter) (Entered: 05/30/2012)

Case: 2:11-cv-8484 As of: 05/28/2014 06:56 AM PDT 9 of 14

05/30/2012 06/12/2012 06/15/2012
07/09/2012 07/09/2012
07/18/2012 07/23/2012
07/25/2012 08/17/2012 08/20/2012 08/22/2012

41 ORDER Extending Time to Serve Complaint 40 by Judge Otis D Wright II. It is hereby ordered that the time for service of the First Amended Complaint under Federal Rule of Civil Procedure 4(m) on the named defendants be extended to allow service within 90 days from the date of entry of this order. (sch) (Entered: 05/30/2012)
42 MINUTE ORDER IN CHAMBERS by Magistrate Judge Carla Woehrle: The call−in information for the telephonic conference scheduled to take place on Friday, June 15, 2012 at 2:00 p.m. is listed.**SEE ORDER FOR FURTHER DETAILS** (dt) (Entered: 06/12/2012)
43 MINUTES OF Settlement Conference held before Magistrate Judge Carla Woehrle. Telephonic conference held regarding status of settlement between Plaintiffs and Defendant City of Glendale/Glendale Unified School District. Court is advised that agreement has been reached regarding all substantive terms of agreement and that documentation is in progress. A continued telephonic status conference regarding completion of documentation is scheduled for July 9, 2012, at 2:00 p.m. The court clerk will provide a call−in number for the conference. (gr) (Entered: 06/18/2012)
44 MINUTE ORDER IN CHAMBERS by Magistrate Judge Carla Woehrle: The call−in information for the telephonic conference scheduled for Monday, July 9, 2012 is listed. **SEE ORDER FOR FURTHER DETAILS** (dt) (Entered: 07/09/2012)
45 MINUTES OF Settlement Status Conference held before Magistrate Judge Carla Woehrle. Telephonic conference held regarding status of settlement documentation between Plaintiffs and Defendant City of Glendale/Glendale Unified School District. Court is advised that documentation is nearing completion. A further telephonic settlement status conference is scheduled for July 23, 2012, at 2:00 p.m. The court clerk will provide a call−in number for the conference. (gr) (Entered: 07/10/2012)
46 MINUTE ORDER (IN CHAMBERS) by Magistrate Judge Carla Woehrle. The call−in information for the telephonic conference regarding settlement status, scheduled to take place on Monday, July 23, 2012 at 2:00 p.m. is listed below: Call−in Number: 213/894−0800 Meeting ID: 7002# User Password: 7333# If you have any problems connecting to this call, please contact Donna Thomas at 213/894−6825. 45 (gr) (Entered: 07/18/2012)
47 MINUTES OF Telephone Conference held before Magistrate Judge Carla Woehrle: Telephonic conference held regarding status of settlement between plaintiffs and defendants city of Glendale/Glendale Unified School District. Court is advised that documentation of settlement agreements is anticipated within approximately two to three weeks. A further telephonic status conference is scheduled for August 22, 2012, at 3:00 p.m. The clerk will provide a call−in number for the conference. **SEE ORDER FOR FURTHER DETAILS** (dt) (Entered: 07/24/2012)
48 MINUTE ORDER (IN CHAMBERS) by Magistrate Judge Carla Woehrle. The call−in information for the telephonic conference regarding settlement status, scheduled to take place on Wednesday, August 22, 2012 at 3:00 p.m. is listed below: Call−in Number: 213/894−0800 Meeting ID: 7002# User Password: 0724#; If you have any problems connecting to this call, please contact Donna Thomas at 213/894−6825. 47 (gr) (Entered: 07/25/2012)
49 Joint STIPULATION for Extension of Time to File Serve Complaint filed by Plaintiff Alejandro Barajas, A. F., K. L., C. M., L. P., Giovanni Pablo, Anthony Parker. (Attachments: # 1 Proposed Order)(Bibring, Peter) (Entered: 08/17/2012)
50 ORDER by Judge Otis D Wright, II: the Joint STIPULATION for Extension of Time to Serve Complaint 49 is DENIED. (lc) (Entered: 08/21/2012)
67 MINUTES OF Telephonic Settlement Conference held before Magistrate Judge Carla Woehrle:Documentation is substantially completed. Counsel intend to submit a stipulation for referral of motions for determination of good faith settlement and for approval of minors' compromise to the settlement magistrate judge, and to promptly file said motions. **SEE ORDER FOR FURTHER DETAILS** (dt)

Case: 2:11-cv-8484 As of: 05/28/2014 06:56 AM PDT 10 of 14

08/23/2012 08/23/2012 08/23/2012 08/23/2012 08/23/2012 08/23/2012 08/23/2012 08/23/2012 08/23/2012 08/23/2012 08/23/2012 08/23/2012 08/23/2012

(Entered: 08/28/2012)
51 WAIVER OF SERVICE Returned Executed filed by Plaintiff A. F., Giovanni Pablo, K. L., C. M., Alejandro Barajas, L. P., Anthony Parker. upon Bickells waiver sent by Plaintiff on 8/22/2012, answer due 10/21/2012. Waiver of Service signed by Ann Maurer. (Bibring, Peter) (Entered: 08/23/2012)
52 WAIVER OF SERVICE Returned Executed filed by Plaintiff A. F., Giovanni Pablo, K. L., C. M., Alejandro Barajas, Anthony Parker. upon City of Glendale waiver sent by Plaintiff on 8/22/2012, answer due 10/21/2012. Waiver of Service signed by Ann Maurer. (Bibring, Peter) (Entered: 08/23/2012)
53 WAIVER OF SERVICE Returned Executed filed by Plaintiff A. F., Giovanni Pablo, K. L., C. M., Alejandro Barajas, L. P., Anthony Parker. upon Riley waiver sent by Plaintiff on 8/22/2012, answer due 10/21/2012. Waiver of Service signed by Ann Maurer. (Bibring, Peter) (Entered: 08/23/2012)
54 WAIVER OF SERVICE Returned Executed filed by Plaintiff Michael Rock(in his official capacities). upon Michael Rock(individual) waiver sent by Plaintiff on 8/22/2012, answer due 10/21/2012. Waiver of Service signed by Ann Maurer. (Bibring, Peter) (Entered: 08/23/2012)
55 WAIVER OF SERVICE Returned Executed filed by Plaintiff A. F., Giovanni Pablo, K. L., C. M., Alejandro Barajas, L. P., Anthony Parker. upon Quintero waiver sent by Plaintiff on 8/22/2012, answer due 10/21/2012. Waiver of Service signed by Ann Maurer. (Bibring, Peter) (Entered: 08/23/2012)
56 WAIVER OF SERVICE Returned Executed filed by Plaintiff A. F., Giovanni Pablo, K. L., C. M., Alejandro Barajas, L. P., Anthony Parker. upon County of Los Angeles waiver sent by Plaintiff on 8/22/2012, answer due 10/21/2012. Waiver of Service signed by Jennifer Lehman. (Bibring, Peter) (Entered: 08/23/2012)
57 WAIVER OF SERVICE Returned Executed filed by Plaintiff A. F., Giovanni Pablo, K. L., C. M., Alejandro Barajas, L. P., Anthony Parker. upon Gilda Davis waiver sent by Plaintiff on 8/22/2012, answer due 10/21/2012. Waiver of Service signed by Jennifer Lehman. (Bibring, Peter) (Entered: 08/23/2012)
58 WAIVER OF SERVICE Returned Executed filed by Plaintiff A. F., Giovanni Pablo, K. L., C. M., Alejandro Barajas, L. P., Anthony Parker. upon Thomas Van Hoof(in his official capacity) waiver sent by Plaintiff on 8/22/2012, answer due 10/21/2012. Waiver of Service signed by Jennifer Lehman. (Bibring, Peter) (Entered: 08/23/2012)
59 WAIVER OF SERVICE Returned Executed filed by Plaintiff A. F., Giovanni Pablo, K. L., C. M., Alejandro Barajas, L. P., Anthony Parker. upon Jennifer Earl waiver sent by Plaintiff on 8/22/2012, answer due 10/21/2012. Waiver of Service signed by Howard Friedman. (Bibring, Peter) (Entered: 08/23/2012)
60 WAIVER OF SERVICE Returned Executed filed by Plaintiff A. F., Giovanni Pablo, K. L., C. M., Alejandro Barajas, L. P., Anthony Parker. upon Hagop Eulmessekian waiver sent by Plaintiff on 8/22/2012, answer due 10/21/2012. Waiver of Service signed by Howard Friedman. (Bibring, Peter) (Entered: 08/23/2012)
61 WAIVER OF SERVICE Returned Executed filed by Plaintiff Alex Garcia. upon Alex Garcia waiver sent by Plaintiff on 8/22/2012, answer due 10/21/2012. Waiver of Service signed by Howard Friedman. (Bibring, Peter) (Entered: 08/23/2012)
62 WAIVER OF SERVICE Returned Executed filed by Plaintiff A. F., Giovanni Pablo, K. L., C. M., Alejandro Barajas, L. P., Anthony Parker. upon Ara Mgrdichian waiver sent by Plaintiff on 8/22/2012, answer due 10/21/2012. Waiver of Service signed by Howard Friedman. (Bibring, Peter) (Entered: 08/23/2012)
63 WAIVER OF SERVICE Returned Executed filed by Plaintiff A. F., Giovanni Pablo, K. L., C. M., Alejandro Barajas, L. P., Anthony Parker. upon Caroline Sweeney waiver sent by Plaintiff on 8/22/2012, answer due 10/21/2012. Waiver of Service signed by Howard Friedman. (Bibring, Peter) (Entered: 08/23/2012)

Case: 2:11-cv-8484 As of: 05/28/2014 06:56 AM PDT 11 of 14

08/23/2012 08/23/2012 08/24/2012
08/29/2012 09/21/2012 10/19/2012 10/19/2012
10/23/2012 10/24/2012 12/19/2012 01/08/2013 01/09/2013 01/09/2013 01/09/2013 01/09/2013 01/09/2013

64 WAIVER OF SERVICE Returned Executed filed by Plaintiff A. F., Giovanni Pablo, K. L., C. M., Alejandro Barajas, L. P., Anthony Parker. Waiver of Service signed by Ann Maurer. (Bibring, Peter) (Entered: 08/23/2012)
65 NOTICE OF ERRATA filed by Plaintiffs Alejandro Barajas, A. F., K. L., C. M., L. P., Giovanni Pablo, Anthony Parker. correcting Waiver of Service Executed, 53 upon County of Los Angeles but docketed as Officer Riley (Bibring, Peter) (Entered: 08/23/2012)
66 WAIVER OF SERVICE Returned Executed filed by DEFENDANTS Park, City of Los Angeles. upon Park waiver sent by Plaintiff on 8/24/2012, answer due 10/23/2012; City of Los Angeles waiver sent by Plaintiff on 8/24/2012, answer due 10/23/2012. Waiver of Service signed by COLLEEN R. SMITH. (Brente, Cory) (Entered: 08/24/2012)
68 NOTICE of Related Case(s) filed by Defendant City of Glendale. Related Case(s): CV 12−2763 GAF (FMOx) (Maurer, Ann) (Entered: 08/29/2012)
69 NOTICE of Settlement filed by Defendant City of Glendale. (Maurer, Ann) (Entered: 09/21/2012)
70 ANSWER to Amended Complaint,, 19 JURY DEMAND. filed by Defendants County of Los Angeles, Gilda Davis, Thomas Van Hoof(in his official capacity), Thomas Van Hoof(individual).(Lehman, Jennifer) (Entered: 10/19/2012)
71 Notice of Interested Parties filed by Defendants County of Los Angeles, Gilda Davis, Thomas Van Hoof(in his official capacity), Thomas Van Hoof(individual), identifying David B. Sapp, Peter Bibring, ACLU Foundation of Southern California, County of Los Angeles, Thomas Van Hoof, Gilda Davis, City of Los Angeles, Michael Rock, Officer Riley, Officer Bickells, Officer Quintero, Officer Park, City of Glendale, Hagop Eulmessekian, Jennifer Earl, Caroline Sweeney, Ara Mgrdichian, Alex Garcia. (Lehman, Jennifer) (Entered: 10/19/2012)
72 ANSWER to Complaint − (Discovery), Complaint − (Discovery) 11 filed by DEFENDANTS City of Los Angeles, Park.(Smith, Colleen) (Entered: 10/23/2012)
73 Certification as of Interested Parties filed by Defendants City of Los Angeles, Park, (Smith, Colleen) (Entered: 10/24/2012)
74 ORDER that the Scheduling Conference is set for 3/4/13 1:30 PM ; compliance with FRCP 16, and 26(f) and filing of joint report; Counsel for plaintiff shall immediately serve this Order on all parties, including any new parties to the action by Judge Otis D Wright, II. (lc) (Entered: 12/19/2012)
75 STIPULATION for Settlement filed by Defendants Bickells, City of Glendale, Riley, Michael Rock(in his official capacities). (Attachments: # 1 Proposed Order Finding Settlement to be in Good Faith, etc.)(Maurer, Ann) (Entered: 01/08/2013)
76 NOTICE of Manual Filing filed by Plaintiffs Alejandro Barajas, A. F., K. L., C. M., L. P., Giovanni Pablo, Anthony Parker of Ex Parte Application to File Under Seal: Petitions for Approval of Minor's Compromises for Plaintiffs L.P. and A.F.. (Sapp, David) (Entered: 01/09/2013)
77 ORDER FINDING SETTLEMENTS TO BE IN GOOD FAITH AND REFERRING DETERMINATION OF MINORS COMPROMISES TO MAGISTRATE JUDGE CARLA WOEHRLE [75} by Judge Otis D Wright, II. (lc) (Entered: 01/09/2013)
78 EXPARTE APPLICATION to Seal Petitioner for Approval of Minor's Compromise. filed by plaintiffs.(dt) (Entered: 01/14/2013)
81 EX PARTE APPLICATION TO FILE UNDER SEAL PETITONS FOR APPROVAL OF MINORS COMPROMISE filed by plaintiffs Alejandro Barajas, K. L., C. M., Giovanni Pablo, Anthony Parker. Lodged order. (lc) (Entered: 01/14/2013)
82 DECLARATION of David B Sapp in support of EX PARTE APPLICATION TO FILE UNDER SEAL PETITONS FOR APPROVAL OF MINORS COMPROMISE 81 filed by Plaintiffs Alejandro Barajas, A. F., K. L., C. M., L. P.,

Case: 2:11-cv-8484 As of: 05/28/2014 06:56 AM PDT 12 of 14

01/10/2013 01/10/2013 01/10/2013 01/14/2013 01/14/2013 02/06/2013 02/15/2013 02/19/2013
02/19/2013 02/20/2013
02/21/2013 03/06/2013 04/10/2013

Giovanni Pablo, Anthony Parker. (lc) (Entered: 01/14/2013)
79 ORDER by Magistrate Judge Carla Woehrle: granting 78 Ex Parte Application to Seal (dt) (Entered: 01/14/2013)
83 SEALED DOCUMENT− PETITION for Approval of Minor's Compromise for Plaintiff A.F. (mat) (Entered: 01/15/2013)
84 SEALED DOCUMENT− PETITION for Approval of Minor's Compromise for Plaintiff L.P. (mat) (Entered: 01/15/2013)
80 NOTICE OF ERRATA filed by Plaintiffs Alejandro Barajas, A. F., K. L., C. M., Giovanni Pablo, Anthony Parker. correcting EXPARTE APPLICATION to Seal 78 Declaration of David B. Sapp (Sapp, David) (Entered: 01/14/2013)
85 SEALED DOCUMENT− ORDER granting Petitions for Approval of Minor's Comprises for Plaintiffs L.P. and A.F. (mat) (Entered: 01/16/2013)
86 NOTICE OF DISMISSAL filed by Plaintiff A. F., Giovanni Pablo, K. L., C. M., Alejandro Barajas, L. P., Anthony Parker pursuant to FRCP 41a(1) as to Bickells, City of Glendale, Quintero, Riley, Michael Rock(in his official capacities), Michael Rock(individual). (Sapp, David) (Entered: 02/06/2013)
87 STATUS REPORT filed by Plaintiffs Alejandro Barajas, A. F., K. L., C. M., L. P., Giovanni Pablo, Anthony Parker. (Sapp, David) Modified on 2/19/2013 (lc). (STRICKEN PER 2/19/13 ORDER). (Entered: 02/15/2013)
88 ORDER by Judge Otis D. Wright, II: the following document(s) be STRICKEN for failure to comply with the Local Rules, General Order and/or the Courts Case Management Order:, for the following reasons: Incorrect event selected. Correct event is Joint Rule 26(f) Discovery Plan. Use the correct event to satisfy the filing requirement, which will specifically prompt for required information, missing on the entry. (lc) (Entered: 02/19/2013)
89 JOINT REPORT Rule 26(f) Discovery Plan ; estimated length of trial 6 days, filed by Plaintiffs Alejandro Barajas, A. F., K. L., C. M., L. P., Giovanni Pablo, Anthony Parker.. (Sapp, David) (Entered: 02/19/2013)
90 SCHEDULING AND CASE MANAGEMENT ORDER by Judge Otis D Wright II: THE SCHEDULING CONFERENCE IS VACATED. SEE THE LAST PAGE OF THIS ORDER FOR THE SPECIFIED DATES. Jury trial: 9/17/13 9:00 AM; File final trial exhibit stipulation: 9/12/13; hearing on motions in limine: 9/9/13 2:30 PM; Final Pretrial Conference: 8/26/13 2:30 PM; motions in limine, proposed voir dire questions and proposed voir dire questions and agreed to statement of case: 8/26/13; lodged Pretrial conference order and pretrial exhibit stipulation, file contentions of fact and law, exhibit and witness lists, status report regarding settlement, agreed upon set of instructions and verdict forms, joint statement regarding disputed instructions verdicts etc: 8/19/13; last date to conduct settlement conference: 7/22/13; last day for hearing motions: 7/29/13; discovery cutoff: 6/17/13; last date to amend pleadings or add parties: 5/27/13. (lc) (Entered: 02/20/2013)
91 ORDER/REFERRAL to ADR Procedure No 1 by Judge Otis D. Wright, II. Case ordered to Magistrate Judge Stephen J. Hillman for Settlement Conference. (lc) (Entered: 02/21/2013)
92 NOTICE OF DISMISSAL filed by plaintiffs A. F., Giovanni Pablo, K. L., C. M., Alejandro Barajas, L. P., Anthony Parker pursuant to FRCP 41a(1) as to Jennifer Earl, Jennifer Earl, Hagop Eulmessekian, Alex Garcia, Ara Mgrdichian, Caroline Sweeney. (Sapp, David) (Entered: 03/06/2013)
93 MINUTE ORDER IN CHAMBERS by Magistrate Judge Stephen J. Hillman: This case has been referred to Magistrate Judge Hillman for settlement. This case has been referred to Magistrate Judge Hillman for settlement.IT IS ORDERED as follows: 1. Plaintiff(s) and defendant(s) shall confer immediately with each other and set a date and time for a settlementconference, after clearing the date with Magistrate JudgeHillman's clerk, Ms. Sandra L. Butler, (213)894−6487. Thedate selected must be soon enough to comply with anydeadlines imposed by rule or by

Case: 2:11-cv-8484 As of: 05/28/2014 06:56 AM PDT 13 of 14

04/10/2013 04/10/2013
04/22/2013 05/01/2013 05/13/2013 05/14/2013 07/03/2013 09/04/2013 09/05/2013
09/13/2013

the district judge. (sbu) (Entered: 04/10/2013)
94 MINUTE ORDER IN CHAMBERS by Magistrate Judge Stephen J. Hillman: Minute Order referring the case to Magistrate Judge Hillman for settlement is vacated. 93 . (sbu) (Entered: 04/10/2013)
95 MINUTE ORDER (IN CHAMBERS) by Magistrate Judge Carla Woehrle. This matter having been referred to U.S. Magistrate Judge Carla Woehrle for settlement conference by U.S. District Judge Otis d. Wright, ll. IT IS ORDERED that a settlement conference shall be held in the chambers of Judge Woehrle on Wednesday, April 17, 2013, at 3:00 p.m., Room 640, 6th Floor of the Roybal Courthouse, 255 E. Temple Street, Los Angeles, CA. The conference should be attended by persons with meaningful authority to negotiate and agree to a settlement of the case. The parties shall submit settlement conference statements directly to Judge Woehrle's chambers not later than three (3) court days before the conference. These statements are to be exchanged with opposing counsel. The statements shall not be filed in the court record. 91 [SEE ORDER FOR FURTHER DETAILS] (gr) (Entered: 04/10/2013)
96 MINUTES OF Settlement Conference held before Magistrate Judge Carla Woehrle. Settlement conference held. Counsel for Plaintiffs and City of Los Angeles reach tentative agreement regarding two of three primary settlement issues and agree to confer further regarding the third issue. A continued settlement conference is scheduled for May 3, 2013, at 10:00 a.m. Court Recorder: 04/22/2013. (gr) (Entered: 04/22/2013)
97 MINUTE ORDER IN CHAMBERS by Magistrate Judge Carla Woehrle: Parties are advised that the further Settlement Conference scheduled for Friday, May 3, 2013, is continued and now scheduled to take place on Tuesday, May 7, 2013 at 1:30 p.m. (dt) (Entered: 05/01/2013)
98 NOTICE of Settlement With Remaining Defendants filed by plaintiffs Alejandro Barajas, A. F., K. L., C. M., L. P., Giovanni Pablo, Anthony Parker. (Sapp, David) (Entered: 05/13/2013)
99 MINUTE ORDER IN CHAMBERS by Judge Otis D. Wright, II: The Court is in receipt of a Notice of Settlement 98 filed May 13, 2013. The Court orders the parties to show cause why settlement has not been finalized and sets a hearing on the matter for Monday, July 22, 2013 at 1:30 p.m. Accordingly, all otherdates are vacated and taken off calendar.The OSC hearing will be vacated upon the filing of a stipulation and proposed order of dismissal. (lc) (Entered: 05/14/2013)
100 Show Cause Hearing is CONTINUED TO 9/9/2013 at 1:30 PM before Judge Otis D. Wright II. THERE IS NO PDF DOCUMENT ASSOCIATED WITH THIS ENTRY.(sce) TEXT ONLY ENTRY (Entered: 07/03/2013)
101 STATUS REPORT RE: STATUS OF SETTLEMENT AND DISMISSAL OF THIS MATTER AND REQUEST TO CONTINUE OSC RE: SETTLEMENT TO OCTOBER 7, 2013 filed by Defendants City of Los Angeles, Park. (Attachments: # 1 Proposed Order)(Smith, Colleen) (Entered: 09/04/2013)
102 ORDER TO SHOW CAUSE RE APPROVAL OF MINORS' SETTLEMENT by Judge Otis D. Wright, II. For the parties settlement of the minors claims to be enforceable, the settlement requires court approval. The Court therefore orders the parties to show cause why they did not petition the Court to confirm the settlement in this case prior to executing the settlement documents and settlement check. The Court sets a hearing for this matter for Monday, September 23, 2013, at 1:30 p.m. This hearing will be vacated upon the filing of a petition to confirm the minors settlement in this case.The Court VACATES the Order to Show Cause Hearing set for September 9, 2013. 100 SEE ORDER FOR DETAILS. (cch) (Entered: 09/05/2013)
103 REQUEST to Dismiss Defendants County of Los Angeles, Gilda Davis, Thomas Van Hoof(in his official capacity), Thomas Van Hoof(individual) REQUEST FOR DISMISSAL, AFFIRMATION THAT PLAINTIFFS HAVE ALL REACHED MAJORITY, AND REQUEST TO VACATE THE ORDER TO SHOW CAUSE filed by Plaintiffs A. F., Giovanni Pablo, K. L., C. M., Alejandro Barajas, L. P., Anthony

Case: 2:11-cv-8484 As of: 05/28/2014 06:56 AM PDT 14 of 14

09/16/2013
09/26/2013 09/27/2013

Parker. (Attachments: # 1 Declaration of Peter Bibring, # 2 Proposed Order)(Bibring, Peter) (Entered: 09/13/2013)
104 ORDER In accordance with Plaintiffs request 103 , the Court DISMISSES WITH PREJUDICE the claims against Defendants the County of Los Angeles, Gilda Davis, and Thomas Van Hoof. Because all Plaintiffs have reached the age of majority, the case no longer involves any minor and no minors compromises are needed for its resolution. See Central District Local Rule 83−5.1. The Court,however, retains jurisdiction to enforce the terms of the settlement agreement for a period of one year from the date of this order by Judge Otis D. Wright. (MD JS−6. Case Terminated). (lc) Modified on 9/16/2013 (lc). (Entered: 09/16/2013)
105 REQUEST to Dismiss defendant City of Los Angeles filed by plaintiffs A. F., Giovanni Pablo, K. L., C. M., Alejandro Barajas, L. P., Anthony Parker. (Attachments: # 1 Proposed Order Granting Dismissal of Defendant City of Los Angeles)(Sapp, David) (Entered: 09/26/2013)
106 ORDER GRANTING REQUEST FOR DISMISSAL 105 by Judge Otis D. Wright, II: The Court DISMISSES WITH PREJUDICE the claims against Defendant the City of Los Angeles. The Court, however, retains jurisdiction to enforce the terms ofthe settlement agreement for a period of one year from the date of this order. This order dismisses all plaintiffs claims against the last remaining defendant in this action. The clerk of the Court shall close this case. (lc) (Entered: 09/27/2013)