DocuSign Envelope ID: B1B7563A-F202-464B-9629-1A1E5ACA452A

Case 4:23-cv-02594-JST Document 40 Filed 06/15/23 Page 1 of 4

1 THOMAS L. GEIGER (SBN 199729)

County Counsel
2
SEAN M. RODRIQUEZ (SBN 286668)
3 JASON M. MAUCK (SBN 255133)
Deputies County Counsel
4 COUNTY OF CONTRA COSTA
5 1025 Escobar Street, Third Floor
Martinez, California 94553
6 Telephone: (925) 655-2280
Facsimile: (925) 655-2266
7
Electronic Mail: sean.rodriquez@cc.cccounty.us
8 jason.mauck@cc.cccounty.us
9 Attorneys for Defendant
10 COUNTY OF CONTRA COSTA

11 UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA
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DAWN SAMANIEGO, et al., No. 4:23-cv-02594 JST
14

15 Plaintiffs, DECLARATION OF JENNY ROBBINS IN

SUPPORT OF DEFENDANT COUNTY
16 v. OF CONTRA COSTA’S OPPOSITION TO
PLAINTIFFS’ MOTION FOR
17
COUNTY OF CONTRA COSTA, et al. TEMPORARY RESTRAINING ORDER
18
Defendants.
19 Date: June 29, 2023
20 Time: 9:30 a.m.
Crtrm: 6, 2nd Floor
21 Judge: Hon Jon S. Tigar, Presiding
Date Action Filed: May 25, 2023
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Trial Date: None Assigned
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25 I, Jenny Robbins, declare:

26 1. If called to testify in this matter, I could and would competently testify to the

27 following matters, which are of my own personal knowledge.

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DECLARATION OF JENNY ROBBINS IN SUPPORT OF DEFENDANT COUNTY OF CONTRA
COSTA’S OPPOSITION TO PLAINTIFF’S MOTION FOR TEMPORARY RESTRAINING ORDER
- Case No. 4:23-cv-02594 JST 1
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1 2. I am the Chief of Programs for the Contra Costa County Health Services
2 Department’s Health, Housing and Homeless Services Division (the “H3 Division”). I have
3 been employed in my current role since June 2018, and by the County since December 2008.
4 3. The H3 Division integrates and coordinates housing and homeless services
5 across the County health system, the County government, and in the community. The H3
6 Division is the administrative entity for the local homeless continuum of care which provides
7 a complete system of care that includes crisis response services and long-term permanent
8 solutions to homelessness for adults, youth, and families. My duties as the Chief of Programs
9 include administering and directing all housing programs under the H3 Division, including the
10 Coordinated Outreach Referral Engagement (“CORE”) street outreach program, adult and
11 youth shelters, transitional housing, California Advancing and Innovating Medi-Cal
12 (“CalAIM”) Community Supports, and permanent supportive housing.
13 4. The H3 Division has been offering services to persons living at 1970 Taylor
14 Road, Bethel Island (the “subject property”) since January 2022. The H3 Division’s CORE
15 Program initially contacted persons at the subject property because the encampment at the
16 property had grown during the COVID-19 pandemic and housing and other outreach services
17 were needed.
18 5. On February 24, 2023, H3 Division staff was contacted by Jason Crapo,
19 Director of Building Inspection, with respect to persons occupying recreational vehicles,
20 trailers, and boats on the subject property. Mr. Crapo informed staff that County Code
21 Enforcement had observed code violations at the subject property posing significant health
22 and safety risks to the persons occupying the property and to the surrounding neighborhood.
23 Mr. Crapo informed staff that if the violations were not corrected, that County Code
24 Enforcement may issue a Notice and Order to Abate to remove code violations from the
25 subject property, and that abatement of the property may result in the displacement of persons
26 currently living at the subject property.
27 6. I participated in a multi-departmental coordination effort including staff from
28 the H3 Division, County Code Enforcement, the Sheriff’s Office, healthcare services, and
DECLARATION OF JENNY ROBBINS IN SUPPORT OF DEFENDANT COUNTY OF CONTRA
COSTA’S OPPOSITION TO PLAINTIFF’S MOTION FOR TEMPORARY RESTRAINING ORDER
- Case No. 4:23-cv-02594 JST 2
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Case 4:23-cv-02594-JST Document 40 Filed 06/15/23 Page 3 of 4

1 Contra Costa County Fire Protection District with respect to the significant health and safety
2 risks at the subject property. The H3 Division was tasked with contacting each individual
3 residing at the subject property and offering appropriate housing and other services.
4 7. I coordinated H3 Division staff to make site visits to the subject property on
5 March 2, 2023; March 3, 2023; March 6, 2023; March 8, 2023; March 13, 2023; March 16,
6 2023; March 21, 2023; March 27, 2023; April 6, 2023; April 11, 2023; April 14, 2023; April
7 18, 2023; April 20, 2023; April 25, 2023; April 27, 2023; May 2, 2023; May 4, 2023; May 9,
8 2023. Over the course of the site visits, 22 individuals received some form of assistance from
9 the CORE Program team, including emergency supplies and meals, shelter placement, mobile
10 health care services, housing referrals, and substance abuse treatment referrals. 11 individuals
11 accepted shelter alternatives that were offered. By May 9, 2023, there remained
12 approximately 20 individuals residing at the subject property.
13 8. At the May 9, 2023, Board of Supervisors hearing on the appeal of the Notice
14 and Order to Abate, H3 Division staff informed the Board of the outreach efforts and the
15 results to date. Staff also informed the Board that the County had sufficient capacity to
16 provide housing alternatives to each individual that was still residing at the subject property.
17 9. Following the Board of Supervisors’ decision to order abatement of the subject
18 property, I increased the frequency of H3 Division staff visits to the property. Staff conducted
19 site visits on May 11, 2023; May 12, 2023; May 15, 2023; May 17, 2023; May 18, 2023; May
20 22, 2023; May 23, 2023; May 26, 2023; May 30, 2023; May 31, 2023; June 1, 2023; June 2,
21 2023; June 5, 2023; June 6, 2023; June 9, 2023. An additional six individuals accepted shelter
22 alternatives during these visits. H3 Division staff continue to work with the remaining 14
23 individuals residing at the subject property. In total, staff has assisted 17 individuals to
24 relocate from the subject property into alternative shelter placements or other stable housing.
25 10. H3 Division staff will continue to schedule site visits to the subject property
26 until the ordered abatement occurs for the purpose of offering housing services to persons
27 remaining at the property. As of the date of this declaration, there are available beds at
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DECLARATION OF JENNY ROBBINS IN SUPPORT OF DEFENDANT COUNTY OF CONTRA
COSTA’S OPPOSITION TO PLAINTIFF’S MOTION FOR TEMPORARY RESTRAINING ORDER
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1 alternative housing locations sufficient to provide temporary housing for all persons still
2 residing at the subject property.
3

4 I declare under penalty of perjury under the laws of the United States of America that
6/15/2023
5 the foregoing is true and correct. Executed at Martinez, California on ______________.
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6/15/2023
DATE: __________________ By:
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JENNY ROBBINS
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DECLARATION OF JENNY ROBBINS IN SUPPORT OF DEFENDANT COUNTY OF CONTRA
COSTA’S OPPOSITION TO PLAINTIFF’S MOTION FOR TEMPORARY RESTRAINING ORDER
- Case No. 4:23-cv-02594 JST 4