1 STEPHEN C. GREBING, State Bar No. 178046
[email protected] 2 IAN R. FRIEDMAN, State Bar No. 292390 3
[email protected] WINGERT GREBING BRUBAKER & JUSKIE LLP 4 One America Plaza, Suite 1200 600 West Broadway 5 San Diego, CA 92101 (619) 232-8151; Fax (619) 232-4665 6 7 Attorneys for Plaintiffs NICHOLAS GARDINERA and CAMERON WOOLSEY 8 SUPERIOR COURT OF THE STATE OF CALIFORNIA 9 FOR THE COUNTY OF SAN DIEGO – NORTH COUNTY DIVISION 10 NICHOLAS GARDINERA, by and through his Case No.: 11 Guardian Ad Litem MARLON GARDINERA, and CAMERON WOOLSEY, by and through his IMAGED FILE 12 Guardian Ad Litem RICHARD WOOLSEY, COMPLAINT FOR: 13 Plaintiffs/Petitioners, (1) VIOLATION OF THE EQUAL 14 vs. PROTECTION CLAUSE OF THE FOURTEENTH AMENDMENT TO THE 15 COUNTY OF SAN DIEGO, a governmental UNITED STATES CONSTITUTION agency; WILMA J. WOOTEN, in her official AND VIOLATION OF ARTICLE 1, 16 capacity as Public Health Officer, County of San SECTION 7 OF THE CALIFORNIA Diego; GOVERNOR GAVIN NEWSOM, in his CONSTITUTION; AND 17 official capacity as the Governor of the State of California; the CALIFORNIA DEPARTMENT (2) WRIT OF MANDAMUS (CCP §1085) 18 OF PUBLIC HEALTH, a department of the State of California; and DOES 1 through 100, Dept: 19 inclusive, Judge: WINGERT GREBING BRUBAKER & JUSKIE LLP 20 Defendants/Respondents. Action Filed: Trial Date: 21 22 COMES NOW Plaintiffs/Petitioners NICHOLAS GARDINERA and CAMERON WOOLSEY 23 and allege as follows: 24 INTRODUCTION 25 In March 2020, California Governor Newsom issued a series of disaster declarations, executive 26 orders, rules, and regulations responding to an outbreak of a novel coronavirus (COVID-19) which the 27 World Health Organization (“WHO”) and the Center for Disease Control (“CDC”) declared a 28 pandemic.