Defendants Ignored Court Order Dkt 305 and Distracted the Court with Hearsay

Morris Patrick III
Sep 5
2 min read

Updated: Sep 7

On August 14, 2025, the Court issued Dkt 305 (Click Dkt 305), ordering Los Angeles County and San Bernardino County to respond by September 5, 2025.

The Court’s order was very clear:

Defendants’ Duty: They were required to respond and address issue:
1. Whether any online materials still violated the Protective Order.
Plaintiff’s Duty (My Responsibility): I was ordered to review, redact, and refile exhibits that contained confidential material.

My Compliance

I did exactly what the Court required of me:

I properly re-redacted and refiled exhibits.
I confirmed that no protected documents were online.
The Court itself verified that I was in full compliance.

In other words, I did my part — and the Court confirmed it.

Defendants’ Non-Compliance

Los Angeles County and San Bernardino County? They did not comply.

They failed to respond by the Court’s September 5 deadline.
They failed to address the Protective Order issue.
They failed to demonstrate compliance with sealed and redacted filings.

The record is now clear:

I complied.
The Court verified my compliance.
The defendants disobeyed.

What the Defendants Did Instead

Instead of following Dkt 305, the defendants filed:

Dkt 324 – Los Angeles County’s Reply Brief (Click Dkt 324)
Dkt 325 – Defendants’ Notice of Non-Response (Click Dkt 325)
Dkt 326 – San Bernardino County’s Reply Brief (Click Dkt 326)
Dkt 326-1 – Defendants’ Joint Objections to My Evidence (Click Dkt 326-1)
Dkt 326-2 – Defendants’ Joint Response to My Statement of Genuine Disputes (Click Dkt 326-2)

But none of these filings addressed what the Court actually ordered in Dkt 305.

Instead, the defendants:

Shifted focus to irrelevant hearsay arguments.
Claimed my evidence was “unauthenticated, irrelevant, or self-serving.”
Ignored deadlines and disclosure issues.
Submitted incomplete records, omitting attachments from my April 17, 2018 email to social worker Amy Sando.

Why This Matters

The Judge gave them instructions. They ignored those instructions. Instead, they tried to bury the Court in hearsay objections while hiding critical attachments that prove my innocence.

The Ninth Circuit has been crystal clear:

Scanlon v. Cnty. of Los Angeles (2023)
Costanich v. DSHS (2010)
Beltran v. Santa Clara Cnty. (2008)
Devereaux v. Abbey (2001, en banc)

These cases hold that there is no excuse for lies, concealment, or fabrication by social workers or counties.

By ignoring Dkt 305 and distracting the Court with hearsay arguments, defendants not only disrespected the Court, they also exposed their own credibility problem. Once credibility is broken, every single claim they make is in doubt.

The Truth Is Public

I preserved over 2,000 emails from 2017–2020, and I filed the complete set of important attachments. San Bernardino County only gave the Court partial records. The difference is now on the docket for everyone to see.

The truth is preserved.

The truth is public.

And the truth is what hurts the defendants the most.