Professional Documents
Culture Documents
1
Mohrbacher v. Alameda County Sheriff’s Office 3:18-cv-00050, Request for Judicial Notice in Support
Motion for Preliminary Injunction
Case 3:18-cv-00050-JD Document 17-15 Filed 01/31/18 Page 2 of 3
1. Alameda County Sheriff’s Office, Detentions & Corrections Policy and Procedure No.
1
13.04; Titled: OB-GYN Clinic and Pregnant or Postpartum Inmates, Issued July 1, 1989;
2
Reviewed and Revised September 7 2016, the Alameda County Sheriff’s Office Policy and
3
Procedure §13.04, attached as Exhibit C to the Declaration of Yolanda Huang in Support of
4
Plaintiffs’ Motion for Provisional Relief.
5 2. Complaint in Vernita Jones, Darlene McKeever, Patricia Ailsworth, and others similarly
6 situated, v. Glenn Dyer, Sheriff, Alameda County, Donald White, Treasurer of Alameda
7 County; William Vogel, Director, Alameda County Health Care Services Agency; Alameda
8 County Health Care Services Agency, County of Alameda; Case No: H-114154-0, filed
9 February 25, 1986; attached as Exhibit A to the Declaration of Ellen Barry in Support of
20 court is supplied with the necessary information.” Fed. R. Evid. 201(c)(2). The Court can judicially
notice any “fact that is not subject to reasonable dispute because it: . . . can be accurately and readily
21
determined from sources whose accuracy cannot reasonably be questioned.” Fed. R. Evid. 201(b)(2).
22
Item 1 is the Sheriff’s Jail policy. Item 2 and 3 are judicial documents and documents to which
23
the Sheriff and Santa Rita Jail’s memoranda. See Lee v. City of Los Angeles, 250 F.3d 668, 689- 90
24
(9th Cir. 2001) (a court may take judicial notice of undisputed matters of public record). Item 4 is a
25 public statement and admission by a designated representative of the Sheriff’s Office. See Cnty. of
26 Santa Clara, 250 F. Supp. 3d at nn. 4, 6, 7, 10 (taking judicial notice of government officials’ press
27 conference statements, press briefings, and interview statements).
28 Because the above documents satisfy the criteria of Rule 201(b) of the Federal Rules of
2
Mohrbacher v. Alameda County Sheriff’s Office 3:18-cv-00050, Request for Judicial Notice in Support
Motion for Preliminary Injunction
Case 3:18-cv-00050-JD Document 17-15 Filed 01/31/18 Page 3 of 3
Evidence, the Court must take judicial notice of them pursuant to Rule 201(c)(2) of the Federal Rules
1
of Evidence.
2
January 29, 2018
3
Respectfully submitted,
4
ATTORNEYS FOR PLAINTIFFS
5
6 LAW OFFICE OF YOLANDA HUANG
3
Mohrbacher v. Alameda County Sheriff’s Office 3:18-cv-00050, Request for Judicial Notice in Support
Motion for Preliminary Injunction