Preview
Electronically FILED by
KELLER ROHRBACK L.L.P. Superior Court of California,
Dean N. Kawamoto (SBN 232032) County of Los Angeles
2/13/2024 12:00
1201 Third Avenue, Suite 3200 David W. Slayton,
Seattle, WA 98101 Executive Officer/Clerk of Court,
By G. Carini, Deputy Clerk
Telephone: 206.623.1900
Facsimile: 206.623.3384
Email: dkawamoto@ kellerrohrback.com
Attorney for Plaintiffs
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11 SUPERIOR COURT OF THE STATE OF CALIFORNIA
12 FOR THE COUNTY OF LOS ANGELES
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COORDINATION PROCEEDING SPECIAL JUDICIAL COUNCIL COORDINATION
14 TITLE [RULE 3.400] PROCEEDING NO. 5255,
15 SOCIAL MEDIA CASES For Filing Purposes: 22STCV 21355
16 NOTICE OF PLAINTIFFS’
THIS DOCUMENT RELATES TO:
[PROPOSED] SCHOOL DISTRICT
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PLAINTIFF FACT SHEET
Government Entity Cases
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(Christina Arlington Smith, et al., v. TikTok
Judge: Hon. Carolyn B. Kuhl
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Inc., et al., Case No. 22STCV21355)
20 Complaint Filed: June 30, 2022
Cases Coordinated: December 22, 2022
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NOTICE OF PLAINTIFFS’ [PROPOSED] SCHOOL DISTRICT PLAINTIFF FACT SHEET
JCCP NO. 5255
TO THE COURT AND ALL PARTIES THROUGH THEIR ATTORNEYS OF RECORD:
Attached as Exhibit “A” is Plaintiffs’ [Proposed] School District Plaintiff Fact Sheet in the
above-referenced matter.
Dated: February 9, 2024 KELLER ROHRBACK LLP.
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p< Ly
By: aet
Dean N. Kawamoto (SBN 232032)
1201 Third Avenue, Suite 3200
10 Seattle, WA 98101
Telephone: 206.623.1900
11 Facsimile: 206.623.3384
Email: dkawamoto@ kellerrohrback.com
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Co-Chair of Government Entity Committee
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and Attorney For Plaintiffs
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NOTICE OF PLAINTIFFS’ [PROPOSED] SCHOOL DISTRICT PLAINTIFF FACT SHEET
JCCP NO. 5255
Exhibit A
E-Served: Feb 8 2024 6:24PM PST Via Case Anywhere
SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF LOS ANGELES, CENTRAL DISTRICT
COORDINATION PROCEEDING SPECIAL JUDICIAL COUNCIL COORDINATION
TITLE [RULE 3.400] SOCIAL MEDIA PROCEEDING NO. 5255
CASES
Lead Case No. For Filing Purposes:
22STCV21355
Judge: Hon. Carolyn B. Kuhl SSC-12
This document relates to:
ALL ACTIONS
Plaintiff Fact Sheet — School Districts
Instructions
Use of this fact sheet. Each school-district plaintiff that has filed a complaint in this
action must complete this Plaintiff Fact Sheet. This plaintiff fact sheet constitutes discovery
responses subject to the California Civil Rules. The information provided will only be used for
purposes related to this litigation and may be disclosed only as permitted by the Protective Order.
Terms used. “You” and “your” as used throughout this fact sheet refers to the school
district completing this form. “Social media” refers to Defendants’ social media platforms as
described in your complaint. Unless otherwise indicated, the requests seek information and
materials from 2018 to the present.
Certification. You must certify that the information is true and correct to the best of your
knowledge, information, and belief. Do not leave any questions unanswered or blank; insert
additional space where necessary to answer the questions completely. You should consult with
your attorney about completing this form. None of the requests are designed to require an expert
evaluation.
I CASE INFORMATION
Plaintiff:
Name of the court in which the complaint was initially filed:
Case number in court in which complaint was originally filed:
Filing date of the complaint:
Named defendants in the complaint:
Name, firm, and e-mail address of the principal attorney(s) representing
Plaintiff:
IL REPRESENTATIVE CAPACITY
For purposes of Section II (Representative Capacity) “you” refers to the person filling
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out this form. When you complete the rest of this form “you, ‘your,”” “Plaintiff,” and
“School District” refers to the School District Plaintiff named in this action, including
any departments, divisions, agents, and/or employees.
A Name of individual(s) completing this Fact Sheet:
B Role within Plaintiffs organization:
Til. SCHOOL DISTRICT DATA
Total number of schools in your district:
Number of high schools in your district:
Number of middle schools in your district:
Number of elementary schools in your district:
Number of K-8 schools in your district:
Number of other schools in your district (please explain):
Total number of students enrolled in your district in the current school year:
8 Over the last ten years, has the total number of students increased or decreased by over
20% of the figure reported in Question No. 7?
Yes No
If yes, state the total number of students within your district for each such year, or if that
information isn’t reasonably available, describe the approximate student population change over
the last 10 years.
9. Total number of high school students enrolled in your district in the current school year:
10. Total number of middle school students enrolled in your district in the current school
year:
11. Total number of elementary school students enrolled in your district in the current school
year:
12. How many students, by percentage of enrollment or number, qualify for free or reduced
lunch in the current school year?
13. What is Your district’s four-year high school graduation rate for the most recent school
year for which the data is available?
14. Total number of teachers employed by your district in the current school year:
15. Over the last ten years, has the total number of teachers increased or decreased by over
20% of the figure reported in Question No. 14?
Yes No
If yes, state the total number of teachers within your district for each such year, or if that
information isn’t reasonably available, describe the approximate teacher change over the last 10
years.
16. Total number of non-teacher staff in your district in the current school year:
17. Over the last ten years, has the total number of non-teacher staff increased or decreased
by over 20% of the figure reported in Question No. 16?
Yes No
If yes, state the total number of non-teacher staff within your district for each such year,
or if that information isn’t reasonably available, describe the approximate non-teacher staff
change over the last 10 years.
18. Was your district ever closed to in-person learning during the COVID-19 pandemic?
Yes No
If yes, please generally describe when schools were closed, when remote learning was
offered, and when students came back to in-person learning.
19. Have you or any schools in your district communicated with any of the Defendants
regarding impacts of social media and harms to your district and/or students?
Yes No
If yes, please describe the timeframe and general nature of the communications.
Iv. PEOPLE WITH KNOWLEDGE
20. Identify the superintendent(s),vice/assistant superintendent(s), and chief financial officer,
or the individuals in equivalent positions, in your district over the last five years:
21. Identify the person(s) in your district most knowledgeable about student use of social
media on school property and the impact of such use on your district over the last five years:
22. To the extent not listed above, identify the person(s) in your district most knowledgeable
about student mental health issues over the last five years:
23. Does Your district regularly maintain organizational charts depicting the district’s general
organizational structure?
If Yes, please provide a copy of the organizational chart for the most recent year it is
available.
Vv. DAMAGES
24. State generally in what way or how you claim you have been damaged by Defendants’
alleged acts at issue in this lawsuit.
25. Are you seeking any monetary damages?
Yes No
If yes, identify each category of damages or monetary relief that you allege.
26. Are you seeking damages or other monetary relief based in whole or in part on personal
injury to any individual(s)?
Yes No
If yes, identify each individual and the alleged personal injury.
27. Are you seeking injunctive relief other than abatement?
Yes No
If yes, provide a general description of the injunctive relief sought.
28. Are you seeking abatement?
Yes No
If yes, provide a general description of the abatement sought.
29. Have you been involved in litigation against a social media company in the past?
Yes No
If yes, for each lawsuit, state (1) the court in which the lawsuit was filed; (2) the case
name; (3) the civil action or docket number assigned to the lawsuit; and (4) your involvement or
claims in the lawsuit.
VI. SOCIAL-MEDIA-RELATED AND YOUTH MENTAL HEALTH SERVICES AND
PROGRAMS
30. Have you formed or participated in any task force, other program, or group to address
issues related to social media use or youth mental health among students?
Yes No
If yes, identify the name of any such program(s) and the date(s) of formation.
31. Have you provided classes, services or programs in your schools that address youth
mental health?
Yes No
If yes, identify the name of any such program(s) and the date(s) of formation.
32. Have you provided classes or programs in your schools or community to address the
harms of social media or help students or parents curtail or regulate their social media use?
Yes No
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If yes, identify the name of any such class(es) or program(s) and the date(s) of
formation.
33. Have you received any grant, donation, or other funding designated by its terms as
addressing issues relating to social media use or youth mental health among students?
Yes No
If yes, describe generally the grant/donation/funding.
VIL. MEASURES TO ADDRESS SOCIAL MEDIA USE
34. Generally describe your efforts, if any, to limit student use of social media while on
school property.
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35. Generally describe your efforts, if any, to address your students’ addiction to social
media.
36. Generally describe your efforts, if any, to address your students’ mental health.
37. Generally describe your efforts, if any, to address social media’s disruptive impact on
schools, the learning environment, and students in your district.
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38. Do you possess any disciplinary codes, policies, or codes of conduct that address
students’ use of social media or phones on school property?
Yes No
If yes, attach copies of the relevant codes or policies.
39. Do you currently use any programs or services to limit or monitor internet activity and/or
social media use by students in Your district while on school property?
Yes No
If yes, identify such programs or services and the date You started using them.
40. Does Your district have a program whereby students are issued tablets, laptops, or similar
devices for students’ use in the course of the school year for educational purposes?
Yes No
If Yes, please generally describe the program.
Al. Does your district have a policy governing use of school-issued tablets, laptops, or
similar devices?
Yes No
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If Yes, please provide a copy of the policy.
VIII. REPORTS RELATING TO SOCIAL MEDIA USE
Instructions for this section. For each of the requests in this section, indicate whether you
possess any existing report, survey, analysis, study, or other document that provides an overview
of, or describes, the indicated topic. Each of these requests only requires that you produce
information that has already been compiled. If information has not been compiled or summarized
on these topics, it does not need to be located, described or produced (i.e., You are not required
to locate, compile, sort, describe or produce underlying records that might show, for example,
the prevalence of student use of social media or expenses incurred to address problems arising
from student use of social media).
You should investigate whether you have compiled the information sought. This
investigation might involve a district employee asking the appropriate person at each school to
provide the district with a document/report that has previously compiled information. But you do
not need to produce underlying records that have not already been compiled or summarized and
you do not need to create any new documents.
If you do possess any such reports, surveys, analyses, studies, or other overview
documents, then provide copies as they are kept in the ordinary course of business, without
identifying any student-specific data.
A. Prevalence
42. Do you possess any existing report, survey, analysis, study or other document that
provides an overview of or describes the prevalence of student social media use in your district?
Yes No
If yes, provide a copy.
43. Do you possess any existing report, survey, analysis, study or other document that
provides an overview of or describes the prevalence of the harms associated with student social
media use in your district, including associated mental health issues and classroom disruption?
Yes No
If yes, provide a copy.
44. Do you possess any existing report, survey, analysis, study or other document that
provides an overview of or describes the prevalence of students with reported mental health
issues in your district?
Yes No
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If yes, provide a copy.
45. Do you possess any existing report, survey, analysis, study or other document that
provides an overview of or describes the prevalence of students’ use of social media platforms
other than Defendants’ in your district?
Yes No
If yes, provide a copy.
B. Discipline measures
46. Do you possess any existing report, survey, analysis, study or other document that
provides an overview of or describes interventions, discipline, or other consequences imposed on
students for using social media on school premises?
Yes No
If yes, provide a copy.
47. Do you possess any existing report, survey, analysis, study or other document that
provides an overview of or describes interventions, discipline, or other consequences imposed on
students related to the use of social media off school premises?
Yes No
If yes, provide a copy.
C. Expenditures
48. Do you possess any existing report, survey, analysis, study or other document that
provides an overview of or describes expenditures that you made to address student use of social
media in your district?
Yes No
If yes, provide a copy.
49. Do you possess any existing report, survey, analysis, study or other document that
provides an overview of or describes expenditures that you made to address students’ mental
health issues in your district?
Yes No
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If yes, provide a copy.
50. Do you possess any existing report, survey, analysis, study or other document that
provides an overview of or describes expenditures that you made to address classroom disruption
related to social media use in your district?
Yes No
If yes, provide a copy.
51. Do you possess any existing report, survey, analysis, study or other document that
provides an overview of or describes expenditures that you made to address property damages
related to students’ use of social media in your district?
Yes No
If yes, provide a copy.
Certification
I have made reasonable inquiries to answer the foregoing questions. Based on my
personal knowledge and the information provided by other district employees, I declare under
penalty of perjury that the information provided in this Plaintiff Fact Sheet is complete, true, and
correct to the best of my knowledge and information, and that I have provided all of the
requested documents that are reasonably accessible to me and/or my attorneys, to the best of my
knowledge.
Signature Date
Name (Printed) Title
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Preview
Electronically FILED by KELLER ROHRBACK L.L.P. Superior Court of California, Dean N. Kawamoto (SBN 232032) County of Los Angeles 2/13/2024 12:00 1201 Third Avenue, Suite 3200 David W. Slayton, Seattle, WA 98101 Executive Officer/Clerk of Court, By G. Carini, Deputy Clerk Telephone: 206.623.1900 Facsimile: 206.623.3384 Email: dkawamoto@ kellerrohrback.com Attorney for Plaintiffs 10 11 SUPERIOR COURT OF THE STATE OF CALIFORNIA 12 FOR THE COUNTY OF LOS ANGELES 13 COORDINATION PROCEEDING SPECIAL JUDICIAL COUNCIL COORDINATION 14 TITLE [RULE 3.400] PROCEEDING NO. 5255, 15 SOCIAL MEDIA CASES For Filing Purposes: 22STCV 21355 16 NOTICE OF PLAINTIFFS’ THIS DOCUMENT RELATES TO: [PROPOSED] SCHOOL DISTRICT 17 PLAINTIFF FACT SHEET Government Entity Cases 18 (Christina Arlington Smith, et al., v. TikTok Judge: Hon. Carolyn B. Kuhl 19 SSC-12 Inc., et al., Case No. 22STCV21355) 20 Complaint Filed: June 30, 2022 Cases Coordinated: December 22, 2022 21 22 23 24 25 26 27 28 1 NOTICE OF PLAINTIFFS’ [PROPOSED] SCHOOL DISTRICT PLAINTIFF FACT SHEET JCCP NO. 5255 TO THE COURT AND ALL PARTIES THROUGH THEIR ATTORNEYS OF RECORD: Attached as Exhibit “A” is Plaintiffs’ [Proposed] School District Plaintiff Fact Sheet in the above-referenced matter. Dated: February 9, 2024 KELLER ROHRBACK LLP. > _—— p< Ly By: aet Dean N. Kawamoto (SBN 232032) 1201 Third Avenue, Suite 3200 10 Seattle, WA 98101 Telephone: 206.623.1900 11 Facsimile: 206.623.3384 Email: dkawamoto@ kellerrohrback.com 12 Co-Chair of Government Entity Committee 13 and Attorney For Plaintiffs 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 2 NOTICE OF PLAINTIFFS’ [PROPOSED] SCHOOL DISTRICT PLAINTIFF FACT SHEET JCCP NO. 5255 Exhibit A E-Served: Feb 8 2024 6:24PM PST Via Case Anywhere SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF LOS ANGELES, CENTRAL DISTRICT COORDINATION PROCEEDING SPECIAL JUDICIAL COUNCIL COORDINATION TITLE [RULE 3.400] SOCIAL MEDIA PROCEEDING NO. 5255 CASES Lead Case No. For Filing Purposes: 22STCV21355 Judge: Hon. Carolyn B. Kuhl SSC-12 This document relates to: ALL ACTIONS Plaintiff Fact Sheet — School Districts Instructions Use of this fact sheet. Each school-district plaintiff that has filed a complaint in this action must complete this Plaintiff Fact Sheet. This plaintiff fact sheet constitutes discovery responses subject to the California Civil Rules. The information provided will only be used for purposes related to this litigation and may be disclosed only as permitted by the Protective Order. Terms used. “You” and “your” as used throughout this fact sheet refers to the school district completing this form. “Social media” refers to Defendants’ social media platforms as described in your complaint. Unless otherwise indicated, the requests seek information and materials from 2018 to the present. Certification. You must certify that the information is true and correct to the best of your knowledge, information, and belief. Do not leave any questions unanswered or blank; insert additional space where necessary to answer the questions completely. You should consult with your attorney about completing this form. None of the requests are designed to require an expert evaluation. I CASE INFORMATION Plaintiff: Name of the court in which the complaint was initially filed: Case number in court in which complaint was originally filed: Filing date of the complaint: Named defendants in the complaint: Name, firm, and e-mail address of the principal attorney(s) representing Plaintiff: IL REPRESENTATIVE CAPACITY For purposes of Section II (Representative Capacity) “you” refers to the person filling ree out this form. When you complete the rest of this form “you, ‘your,”” “Plaintiff,” and “School District” refers to the School District Plaintiff named in this action, including any departments, divisions, agents, and/or employees. A Name of individual(s) completing this Fact Sheet: B Role within Plaintiffs organization: Til. SCHOOL DISTRICT DATA Total number of schools in your district: Number of high schools in your district: Number of middle schools in your district: Number of elementary schools in your district: Number of K-8 schools in your district: Number of other schools in your district (please explain): Total number of students enrolled in your district in the current school year: 8 Over the last ten years, has the total number of students increased or decreased by over 20% of the figure reported in Question No. 7? Yes No If yes, state the total number of students within your district for each such year, or if that information isn’t reasonably available, describe the approximate student population change over the last 10 years. 9. Total number of high school students enrolled in your district in the current school year: 10. Total number of middle school students enrolled in your district in the current school year: 11. Total number of elementary school students enrolled in your district in the current school year: 12. How many students, by percentage of enrollment or number, qualify for free or reduced lunch in the current school year? 13. What is Your district’s four-year high school graduation rate for the most recent school year for which the data is available? 14. Total number of teachers employed by your district in the current school year: 15. Over the last ten years, has the total number of teachers increased or decreased by over 20% of the figure reported in Question No. 14? Yes No If yes, state the total number of teachers within your district for each such year, or if that information isn’t reasonably available, describe the approximate teacher change over the last 10 years. 16. Total number of non-teacher staff in your district in the current school year: 17. Over the last ten years, has the total number of non-teacher staff increased or decreased by over 20% of the figure reported in Question No. 16? Yes No If yes, state the total number of non-teacher staff within your district for each such year, or if that information isn’t reasonably available, describe the approximate non-teacher staff change over the last 10 years. 18. Was your district ever closed to in-person learning during the COVID-19 pandemic? Yes No If yes, please generally describe when schools were closed, when remote learning was offered, and when students came back to in-person learning. 19. Have you or any schools in your district communicated with any of the Defendants regarding impacts of social media and harms to your district and/or students? Yes No If yes, please describe the timeframe and general nature of the communications. Iv. PEOPLE WITH KNOWLEDGE 20. Identify the superintendent(s),vice/assistant superintendent(s), and chief financial officer, or the individuals in equivalent positions, in your district over the last five years: 21. Identify the person(s) in your district most knowledgeable about student use of social media on school property and the impact of such use on your district over the last five years: 22. To the extent not listed above, identify the person(s) in your district most knowledgeable about student mental health issues over the last five years: 23. Does Your district regularly maintain organizational charts depicting the district’s general organizational structure? If Yes, please provide a copy of the organizational chart for the most recent year it is available. Vv. DAMAGES 24. State generally in what way or how you claim you have been damaged by Defendants’ alleged acts at issue in this lawsuit. 25. Are you seeking any monetary damages? Yes No If yes, identify each category of damages or monetary relief that you allege. 26. Are you seeking damages or other monetary relief based in whole or in part on personal injury to any individual(s)? Yes No If yes, identify each individual and the alleged personal injury. 27. Are you seeking injunctive relief other than abatement? Yes No If yes, provide a general description of the injunctive relief sought. 28. Are you seeking abatement? Yes No If yes, provide a general description of the abatement sought. 29. Have you been involved in litigation against a social media company in the past? Yes No If yes, for each lawsuit, state (1) the court in which the lawsuit was filed; (2) the case name; (3) the civil action or docket number assigned to the lawsuit; and (4) your involvement or claims in the lawsuit. VI. SOCIAL-MEDIA-RELATED AND YOUTH MENTAL HEALTH SERVICES AND PROGRAMS 30. Have you formed or participated in any task force, other program, or group to address issues related to social media use or youth mental health among students? Yes No If yes, identify the name of any such program(s) and the date(s) of formation. 31. Have you provided classes, services or programs in your schools that address youth mental health? Yes No If yes, identify the name of any such program(s) and the date(s) of formation. 32. Have you provided classes or programs in your schools or community to address the harms of social media or help students or parents curtail or regulate their social media use? Yes No 10 If yes, identify the name of any such class(es) or program(s) and the date(s) of formation. 33. Have you received any grant, donation, or other funding designated by its terms as addressing issues relating to social media use or youth mental health among students? Yes No If yes, describe generally the grant/donation/funding. VIL. MEASURES TO ADDRESS SOCIAL MEDIA USE 34. Generally describe your efforts, if any, to limit student use of social media while on school property. 11 35. Generally describe your efforts, if any, to address your students’ addiction to social media. 36. Generally describe your efforts, if any, to address your students’ mental health. 37. Generally describe your efforts, if any, to address social media’s disruptive impact on schools, the learning environment, and students in your district. 12 38. Do you possess any disciplinary codes, policies, or codes of conduct that address students’ use of social media or phones on school property? Yes No If yes, attach copies of the relevant codes or policies. 39. Do you currently use any programs or services to limit or monitor internet activity and/or social media use by students in Your district while on school property? Yes No If yes, identify such programs or services and the date You started using them. 40. Does Your district have a program whereby students are issued tablets, laptops, or similar devices for students’ use in the course of the school year for educational purposes? Yes No If Yes, please generally describe the program. Al. Does your district have a policy governing use of school-issued tablets, laptops, or similar devices? Yes No 13 If Yes, please provide a copy of the policy. VIII. REPORTS RELATING TO SOCIAL MEDIA USE Instructions for this section. For each of the requests in this section, indicate whether you possess any existing report, survey, analysis, study, or other document that provides an overview of, or describes, the indicated topic. Each of these requests only requires that you produce information that has already been compiled. If information has not been compiled or summarized on these topics, it does not need to be located, described or produced (i.e., You are not required to locate, compile, sort, describe or produce underlying records that might show, for example, the prevalence of student use of social media or expenses incurred to address problems arising from student use of social media). You should investigate whether you have compiled the information sought. This investigation might involve a district employee asking the appropriate person at each school to provide the district with a document/report that has previously compiled information. But you do not need to produce underlying records that have not already been compiled or summarized and you do not need to create any new documents. If you do possess any such reports, surveys, analyses, studies, or other overview documents, then provide copies as they are kept in the ordinary course of business, without identifying any student-specific data. A. Prevalence 42. Do you possess any existing report, survey, analysis, study or other document that provides an overview of or describes the prevalence of student social media use in your district? Yes No If yes, provide a copy. 43. Do you possess any existing report, survey, analysis, study or other document that provides an overview of or describes the prevalence of the harms associated with student social media use in your district, including associated mental health issues and classroom disruption? Yes No If yes, provide a copy. 44. Do you possess any existing report, survey, analysis, study or other document that provides an overview of or describes the prevalence of students with reported mental health issues in your district? Yes No 14 If yes, provide a copy. 45. Do you possess any existing report, survey, analysis, study or other document that provides an overview of or describes the prevalence of students’ use of social media platforms other than Defendants’ in your district? Yes No If yes, provide a copy. B. Discipline measures 46. Do you possess any existing report, survey, analysis, study or other document that provides an overview of or describes interventions, discipline, or other consequences imposed on students for using social media on school premises? Yes No If yes, provide a copy. 47. Do you possess any existing report, survey, analysis, study or other document that provides an overview of or describes interventions, discipline, or other consequences imposed on students related to the use of social media off school premises? Yes No If yes, provide a copy. C. Expenditures 48. Do you possess any existing report, survey, analysis, study or other document that provides an overview of or describes expenditures that you made to address student use of social media in your district? Yes No If yes, provide a copy. 49. Do you possess any existing report, survey, analysis, study or other document that provides an overview of or describes expenditures that you made to address students’ mental health issues in your district? Yes No 15 If yes, provide a copy. 50. Do you possess any existing report, survey, analysis, study or other document that provides an overview of or describes expenditures that you made to address classroom disruption related to social media use in your district? Yes No If yes, provide a copy. 51. Do you possess any existing report, survey, analysis, study or other document that provides an overview of or describes expenditures that you made to address property damages related to students’ use of social media in your district? Yes No If yes, provide a copy. Certification I have made reasonable inquiries to answer the foregoing questions. Based on my personal knowledge and the information provided by other district employees, I declare under penalty of perjury that the information provided in this Plaintiff Fact Sheet is complete, true, and correct to the best of my knowledge and information, and that I have provided all of the requested documents that are reasonably accessible to me and/or my attorneys, to the best of my knowledge. Signature Date Name (Printed) Title 16