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B.P., A Minor, By and Through His Guardian Ad Litem, Quincella v. the County of Sacramento

July 7, 2011

B.P., A MINOR, BY AND THROUGH HIS GUARDIAN AD LITEM, QUINCELLA PAGE; BRANDON FLORES; T.J., A MINOR, BY AND THROUGH HER GUARDIAN AD LITEM, MICHELLE BELTON;
BRANDON POWELL; JONATHAN WHISENANT; AND ALL OTHERS SIMILARLY SITUATED,
PLAINTIFFS,
v.
THE COUNTY OF SACRAMENTO; DON MEYERS, CHIEF PROBATION OFFICER OF SACRAMENTO COUNTY, IN HIS OFFICIAL AND INDIVIDUAL CAPACITIES; PROBATION OFFICER SUPERVISOR RODNEY DORSEY, IN HIS OFFICIAL AND INDIVIDUAL CAPACITIES; PROBATION OFFICER EARP, IN HIS OFFICIAL AND INDIVIDUAL CAPACITIES; PROBATION OFFICER MABINS, IN HIS OFFICIAL AND INDIVIDUAL CAPACITIES; PROBATION OFFICER NUNEZ, IN HIS OFFICIAL AND INDIVIDUAL CAPACITIES; PROBATION OFFICER SAHOTA, IN HIS OFFICIAL AND INDIVIDUAL CAPACITIES; PROBATION OFFICER VO, IN HIS OFFICIAL AND INDIVIDUAL CAPACITIES; DEPUTY PROBATION OFFICER ANDREW YOUNG, IN HIS OFFICIAL AND INDIVIDUAL CAPACITIES; PROBATION ASSISSTANT GARY BERTUCCELLI, IN HIS OFFICIAL AND INDIVIDUAL CAPACITIES; PROBATION ASSISSTANT JOSE CERVANTES, IN HIS OFFICIAL AND INDIVIDUAL CAPACITIES; PROBATION ASSISTANT MARCOS DIAZ, IN HIS OFFICIAL AND INDIVIDUAL CAPACITIES; PROBATION ASSISTANT TOMASA KIZER, IN HIS OFFICIAL AND INDIVIDUAL CAPACITIES;
AIMEE LESCALLET, IN HIS OFFICIAL AND INDIVIDUAL CAPACITIES; PROBATION ASSISTANT MICHAEL OCAMPO, IN HIS OFFICIAL AND INDIVIDUAL CAPACITIES,
DEFENDANTS.



A PROFESSIONAL CORPORATION Terence J. Cassidy, SBN 99180 Michael W. Pott, SBN 186156 Derek J. Haynes, SBN 264621 350 University Ave., Suite 200 Sacramento, California 95825 TEL: 916.929.1481 FAX: 916.927.3706 Attorneys for Defendants COUNTY OF SACRAMENTO and DON MEYERS MORENO & RIVERA, LLP Jesse M. Rivera, SBN 84259 Kelly Yokley, SBN 192015 1451 River Park, Dr. Suite 145 Sacramento, CA 95815 Telephone: (916) 922-1200 Facsimile: (916) 922-1301 Attorneys for Defendants MABINS, NUNEZ, VO, YOUNG, OCAMPO, LESCALLET, DORSEY and EARP Mark E. Merin, SBN 43849 LAW OFFICE OF MARK E. MERIN 2001 P Street, Suite 100 Sacramento, CA 95814 Telephone: (916) 443-6911 Facsimile: (916) 447-8336 Dan Siegel, SBN 56400 Jose Luis Fuentes, SBN 192236 Michael Siegel, SBN 269439 SIEGEL & YEE 499 14th Street, Suite 220 Oakland, CA 94612 Telephone: (510) 839-1200 Facsimile: (510) 444-6698 Attorneys for Plaintiffs B.P., a minor, by his Guardian Ad Litem, Quincella Page, et al.

PROBATION ASSISTANT STIPULATION AND PROTECTIVE ORDER REGARDING DOCUMENTS, THINGS AND INFORMATION TO BE PRODUCED FOR INSPECTION, COPYING AND USE IN THIS LITIGATION FPTC

Date: August 8, 2013 Trial

Date: October 7, 2013 FAC

Filed: February 2, 2010 Complaint

Filed: October 9, 2009

Defendants COUNTY OF SACRAMENTO, DON MEYERS, MABINS, NUNEZ, VO, YOUNG, OCAMPO, LESCALLET, DORSEY and EARP and Plaintiffs B.P., BRANDON FLORES, T.J., BRANDON POWELL and JONATHAN WHISENANT, in good faith, believe that the following documents contain information that is (a) confidential, sensitive, or potentially invasive of privacy interests; (b) not generally known; and, (c) not normally revealed to the public or third parties or, if disclosed to third parties, would require such third parties to maintain the information in confidence:

1. Juvenile Records of B.P., including, but not limited to, medical and mental health records, juvenile court records, grievances filed by him or on his behalf while he was in the care and custody of the Sacramento County Probation Department, any and all "Chrono Records" created or maintained by the Sacramento County Probation Department that pertain to him, any and all Incident Reports, use of force reports, Reports of Physical Force, Internal Affair Records, After Incident Review Supervisor Reports that pertain to him while he was in the care and custody of Sacramento County, and any and all Report Logs, including safety room logs, created or maintained by the Sacramento County Probation Department that pertain to him.

2. Juvenile Records of BRANDON FLORES, including, but not limited to, medical and mental health records, juvenile court records, grievances filed by him or on his behalf while he was in the care and custody of the Sacramento County Probation Department, any and all "Chrono Records" created or maintained by the Sacramento County Probation Department that pertain to him, any and all Incident Reports, use of force reports, Reports of Physical Force, Internal Affair Records, After Incident Review Supervisor Reports that pertain to him while he was in the care and custody of Sacramento County, and any and all Report Logs, including safety room logs, created or maintained by the Sacramento County Probation Department that pertain to him.

3. Juvenile Records of BRANDON POWELL, including, but not limited to, medical and mental health records, juvenile court records, grievances filed by him or on his behalf while he was in the care and custody of the Sacramento County Probation Department, any and all "Chrono Records" created or maintained by the Sacramento County Probation Department that pertain to him, any and all Incident Reports, use of force reports, Reports of Physical Force, Internal Affair Records, After Incident Review Supervisor Reports that pertain to him while he was in the care and custody of Sacramento County, and any and all Report Logs, including safety room logs, created or maintained by the Sacramento County Probation Department that pertain to him.

4. Juvenile Records of JONATHAN WHISENANT, including, but not limited to, medical and mental health records, juvenile court records, grievances filed by him or on his behalf while he was in the care and custody of the Sacramento County Probation Department, any and all "Chrono Records" created or maintained by the Sacramento County Probation Department that pertain to him, any and all Incident Reports, use of force reports, Reports of Physical Force, Internal Affair Records, After Incident Review Supervisor Reports that pertain to him while he was in the care and custody of Sacramento County, and any and all Report Logs, including safety room logs, created or maintained by the Sacramento County Probation Department that pertain to him.

5. Juvenile Records of T.J., including, but not limited to, medical and mental health records, juvenile court records, grievances filed by her or on her behalf while she was in the care and custody of the Sacramento County Probation Department, any and all "Chrono Records" created or maintained by the Sacramento County Probation Department that pertain to her, any and all Incident Reports, use of force reports, Reports of Physical Force, Internal Affair Records, After Incident Review Supervisor Reports that pertain to her while she was in the care and custody of Sacramento County, and any and all Report Logs, including safety room logs, created or maintained by the Sacramento County Probation Department that pertain to her.

6. Juvenile Records of Putative Class Members, who submit a signed consent form for disclosure from either (1) the person who was the subject of a Juvenile Court petition, but is now eighteen (18) years of age or older; or (2) from the parent or legal guardian of a person who is or was the subject of a Juvenile Court petition, whether that person is currently under or over the age of eighteen, including, but not limited to, medical and mental health records, juvenile court records, grievances filed by her or on her behalf while she was in the care and custody of the Sacramento County Probation Department, any and all "Chrono Records" created or maintained by the Sacramento County Probation Department that pertain to her, any and all Incident Reports, use of force reports, Reports of Physical Force, Internal Affair Records, After Incident Review Supervisor Reports that pertain to her while she was in the care and custody of Sacramento County, and any and all Report Logs, including safety room logs, created or maintained by the Sacramento County Probation Department that pertain to her.

IT IS HEREBY STIPULATED by, among and between the parties through their counsels of record that the documents described herein may be designated as "Confidential" by the COUNTY and produced subject to the following Protective Order:

1. The disclosed documents shall be used solely in connection with the above-captioned civil matter and proceedings. The parties do not waive any objections to the admissibility of the documents or portions thereof in future proceedings in this case, including trial. Any documents submitted in ...


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