COURTNEY BARZANDEH (CA CPS)

Defendant Courtney Barzandeh, Social Worker being hereby named in both her individual and official capacities, is an individual and is a Riverside County, California employee and was at all times material, pertinent and relevant hereto, employed by Riverside County Department of Public Social Services (RCDSS) in Riverside, California. Current mailing address is; c/o Riverside County Department of Public Social Services, 11070 Magnolia Ave., Suite B, Riverside, CA 92505. The Defendant was in fact, acting under the authority or color of state law at the time these claims occurred in that while in her official capacity as a social worker for RCDSS her execution of Riverside County Department of Public Social Services’ “customs” and/or “policies” were the moving force behind her unconstitutional acts, and that personally, her individual unconstitutional acts violated the clearly established constitutional rights of the Plaintiffs of which a reasonable official would have known, Davis v. Scherer (1984). In addition, acting personally and individually she did act under the authority or color of state law when she acted in concert with other local officials, including but not limited to, other RCDSS social workers, their supervisors, Wake County Human Services’ CPS Social Workers and others, causing harm to the Plaintiffs in effecting the deprivation of rights, Dennis v. Sparks (1980).