In the Matter of Jane Doe SE-487

JCCP5276: CDCR Women's Facilities Cases 06/26/2026 Hearing on Motion to be Relieved as Counsel as to JANE DOE SE-487 (Original Case No. 24CV07741) in Department 8B

Tentative Ruling

***NOTICE: EFFECTIVE APRIL 13, 2026, THIS DEPARTMENT HAS MOVED TO THE TANI G. CANTIL-SAKAUYE COURTHOUSE LOCATED AT 500 G ST. SACRAMENTO, CA. ALL MOTIONS NOTICED FOR DEPARTMENT 22 WILL BE HEARD IN DEPARTMENT 8B OF THE NEW COURTHOUSE. ALL PAPERS FOR THIS DEPARTMENT MUST BE FILED AT THIS NEW LOCATION. ALL HEARINGS WILL TAKE PLACE AT THIS NEW LOCATION.***

Counsel J. Kyle Gaines of Slater, Slater, Schulman, LLP seek to be relieved as counsel for Plaintiff Jane Doe SE-487 (“Plaintiff”). Counsel argues that “[t]here has been an irreconcilable breakdown in the attorney-client relationship such that continued representation is no longer possible” and that “[g]ood cause exists for withdrawal under California Professional Rules of Conduct, Rule 1.16(b).” (Gaines Decl., ¶ 2.) While Counsel fails to so indicate at paragraph 3(a)(2), Counsel attests that he has been unable to confirm whether Plaintiff’s last known address is current or locate a more current address despite mailing the motion papers to the client’s last known address, return receipt requested; calling the client’s last known telephone number; conducting a search through public records databases; and trying to communicate with Plaintiff by text messages, emails, and phone. (Id., ¶¶ 3(a)(2), 3(b)(2).)

Counsel further attests that even if he has been unable to serve Plaintiff, the Court should grant his motion because he has been unable to reach or communicate effectively with Plaintiff. (Id., ¶ 3(c).)

Counsel’s motion to be relieved is UNOPPOSED and tentatively GRANTED. However, the Court notes that Counsel’s motion and Proposed Order both reveal Plaintiff’s last known address, without regard to the fact that Plaintiff is proceeding under a pseudonym. The Court directs the Clerk to change the security clearance of these documents. Counsel shall file properly redacted versions.

The Court sets a Compliance Hearing for July 10, 2026 at 10:30 a.m. No later than July 2, 2026, Counsel shall file redacted versions.

The Court will sign the redacted Proposed Order.

To request oral argument on this matter, you must call Department 8B at (916) 874-5762 by 4:00 p.m., the court day before this hearing and notification of oral argument must be made to the opposing party/counsel. If no call is made, the tentative ruling becomes the order of the court. (Local Rule 1.06.)

Parties requesting services of a court reporter will need to arrange for private court reporter services at their own expense, pursuant to Government Code §68086 and California Rules of

JCCP5276: CDCR Women's Facilities Cases 06/26/2026 Hearing on Motion to be Relieved as Counsel as to JANE DOE SE-487 (Original Case No. 24CV07741) in Department 8B

Court, Rule 2.956. Requirements for requesting a court reporter are listed in the Policy for Official Reporter Pro Tempore available on the Sacramento Superior Court website. Parties may contact Court-Approved Official Reporters Pro Tempore by utilizing the list of Court Approved Official Reporters Pro Tempore.

If you are not using a reporter from the Court’s Approved Official Reporter Pro Tempore list, a Stipulation and Appointment of Official Reporter Pro Tempore (CV/E-206) must be signed by each party, the private court reporter, and the Judge. The signed form must be filed with the clerk prior to the hearing.

If a litigant has been granted a fee waiver and requests a court reporter, the party must submit a Request for Court Reporter by a Party with a Fee Waiver (CV/E-211). The form must be filed with the clerk at least 10 days prior to the hearing or at the time the hearing is scheduled if less than 10 days away. Once approved, the clerk will forward the form to the Court Reporter’s Office and an official reporter will be provided.

If oral argument is requested, the Parties are encouraged to appear via Zoom with the links below:

To join by Zoom link - https://saccourt-ca-gov.zoomgov.com/j/16184738886 To join by phone dial (833) 568-8864 ID 16184738886

Moving Counsel is directed to notice all parties of this order.

Please note that the Complex Civil Case Department now provides information to assist you in managing your complex case on the Court website at https://www.saccourt.ca.gov/divisions/civil/complex-civil-cases. The Court strongly encourages parties to review this website regularly to stay abreast of the most recent complex civil case procedures. Please refer to the website before directly contacting the Court Clerk for information.