Andres Felix v. County of Ventura

I. BACKGROUND

4 Plaintiffs Andres Felix (“Felix”) and Federico Diaz (“Diaz”) (collectively, 5 “Plaintiffs”) are individuals residing in the City of Los Angeles. (Dkt. 10, First Amended 6 Complaint (“FAC”) ¶¶ 12-13.) Defendants are the County of Ventura, Sheriff Bill Ayub, 7 Detective Sergeant Jeremy Bramlette, District Attorney Gregory D. Totten, and Deputy 8 9 District Attorney David S. Russell. (Id. ¶¶ 14-20.)1 Plaintiffs allege that in approximately April 2016, Defendants Bramlette, Totten, Russell, and others, applied for “numerous wiretap search warrants for various interceptions” in connection with an ongoing investigation of a Ventura County Superior Court criminal case. The criminal case “alleged that Plaintiffs and others conspired to transport cocaine from Los Angeles, California to Denver, Colorado.” (Id. ¶ 35.) Plaintiffs allege that the warrants Defendants obtained were facially insufficient to operate a “Stingray cell site emulator device.” (Id. ¶¶ 41-50.) Plaintiffs allege that “the cumulative number and nature of the deficiencies in the Applications, Affidavits, and Orders for the Wiretaps . . . clearly indicate a…