1 MARK D. ROSENBAUM (BAR NO. 59940)
CATHERINE E. LHAMON (BAR NO. 192751)
2 PETER J. ELIASBERG (BAR NO. 189110)
ROCIO L. CORDOBA (BAR NO. 196680)
3 ACLU Foundation of Southern California
1616 Beverly Boulevard
4 Los Angeles, California 90026
Telephone: (213) 977-9500
5 JACK W. LONDEN (BAR NO. 85776)
6 MICHAEL A. JACOBS (BAR NO. 111664)
MATHEW I. KREEGER (BAR NO. 153793)
7 LOIS K. PERRIN (BAR NO. 185242)
Morrison & Foerster LLP
8 425 Market Street
San Francisco, California 94105-2482
9 Telephone: (415) 268-7000
10 ALAN SCHLOSSER (BAR NO. 49957)
MICHELLE ALEXANDER (BAR NO. 177089)
11 ACLU Foundation of Northern California
12 1663 Mission Street, Suite 460
San Francisco, California 94103
13 Telephone: (415) 621-2493
14 Attorneys for Plaintiffs
15 [See Following Page for Names and Addresses
of Additional Counsel for Plaintiffs]
16
17
18 SUPERIOR COURT OF THE STATE OF CALIFORNIA
19 COUNTY OF SAN FRANCISCO
20
21 ELIEZER WILLIAMS, a minor, by Sweetie No.
Williams, his guardian ad litem; OLIVIA
22 SAUNDERS, a minor, by Karen Por'chet, her [CLASS ACTION]
guardian ad litem; SILAS MOULTRIE, a minor,
23 by Theresa Manning, his guardian ad litem; COMPLAINT FOR INJUNCTIVE
MONIQUE MABUTAS, a minor, by Monica AND DECLARATORY RELIEF
24 Real, her guardian ad litem; BIANCA ARRIOLA,
a minor, by Luz Arriola, her guardian ad litem;
25 BIBIANA ARRIOLA, a minor, by Luz Arriola,
her guardian ad litem; CARLOS RAMIREZ, a
26 minor, by Leticia Ramirez, his guardian ad litem;
RICHARD RAMIREZ, a minor, by Leticia
27 Ramirez, his guardian ad litem; IVANNA
ROMERO, a minor, by Ana Romero, her
28 guardian ad litem; MOISES CANEL, a minor, by
SNIPPETS:
MARK D. ROSENBAUM (BAR NO. 59940) CATHERINE E. LHAMON
ACLU Foundation of Southern California
425 Market Street San Francisco,
his guardian ad litem;
16 Imperatrice, her guardian ad litem; CATHERINE FIPPS, a minor, by Patricia Fipps, her
18 State Superintendent of Public Instruction;
STATE DEPARTMENT OF EDUCATION;
Los Angeles,
Loyola Law School
Additional Attorneys for Plaintiffs
State law requires students to attend
Yet all too many California school children must go to school without trained teachers,
necessary educational supplies, classrooms, or seats in classrooms.
State, and not local districts, has taken the primary role in governance of the public school
students lack textbooks of any kind.
20 are compelled to try to learn in slum conditions or without classrooms, books, or teachers.
24 whom are still learning the English language.
The equal protection clauses of the California Constitution,
District and Luther Burbank Middle School in San Francisco.
Saunders, Silas Moultrie, and Monique Mabutas are children attending school at Luther Burbank
10 Ivanna Romero reside in the County of San Francisco within the boundaries of the San
11 Unified School District and Bryant Elementary School in San Francisco.
15 Ivanna Romero have filed simultaneously with this complaint petitions with the Court to
28 John F. Kennedy High School and Plaintiff Romana Clemons is legally required to attend
either at Cahuenga Elementary School or at another school to which he
When the bathrooms are not
nonemergency teaching credentials, and 17 of the 35 teachers only began teaching at Luther
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