PUGA

I. BACKGROUND

1 This case arises from juvenile dependency proceedings in California state court. On 2 November 28, 2023, the Monterey County Department of Social and Employment Services 3 (“Department”) received an allegation of general neglect in connection with the conduct of 4 Plaintiff Kris Puga, the father of four minor children (collectively, the “Minor Plaintiffs”). ECF 5 No. 18 (“FAC”) ¶ 43. 6 This referral arose after minor N.P. attempted to overdose because of a “gender crisis.” Id. 7 ¶ 44. After recovering, N.P. did not want to return home. Id. Instead, N.P. allegedly “falsely 8 claimed” that the family’s home was “dirty” and “infested with cockroaches,” that the parents 9 fought, that the parents “physically disciplined” one of their other children, and that Mr. Puga 10 “used substances.” Id. ¶ 45. 11 In response to the report, a county social worker, Defendant Anna Cerda, interviewed the 12 three oldest children “outside of the parents’ presence.” Id. ¶ 46. She also spoke to Kris Puga and 13 Megan Puga (collectively, the “Parents”). At that time, Mr. Puga was the primary caretaker of the 14 children because the mother had suffered a stroke and was deemed…