Sanchez

I. BACKGROUND

20 Patrizia Sanchez brings this lawsuit on her own behalf and on the behalf of minor siblings 21 J.G.1 and J.G.2, (collectively, “Plaintiffs”) against Kim Johnson in her official capacity as the 22 Director of the California Department of Social Services and Angie Schwartz in her official 23 capacity as Deputy Director of the Children and Family Services Division of CDSS. (Doc. 1.) 24 Plaintiff Sanchez is the foster mother as well as the grandmother of J.G.1 and J.G.2 and hopes to 25 adopt them. (Id., ¶¶ 1–3.) Both children were removed from the custody of their birth parents 26 after suffering serious abuse and neglect. (Id., ¶¶ 15–18.) The abuse of the oldest child, J.G.1, was 27 so severe that he suffered anoxic brain injury and permanent brain damage due to severe 28 malnutrition. (Id., ¶ 15.) On March 17, 2021, Plaintiff Sanchez filed a civil complaint for damages in the Superior Court of Tulare County on behalf of J.G.1 against the County of Tulare, alleging a failure to discharge mandatory duties under California Government Code § 815.6. (Doc. 1, ¶ 17.) That litigation is still ongoing. (Id.) On June 23, 2022, the Tulare County Superior…