No. S226645 IN THE SUPREME COURT OF CALIFORNIA COUNTY OF LOS ANGELES BOARD OF SUPERVISORS, et al., Petitioners, v. THE SUPERIOR COURT OF LOS ANGELES COUNTY, Respondent, ACLU OF SOUTHERN CALIFORNIA, et al., Real Parties in Interest. After a Judgment of the Court of Appeal of the State of California, Second Appellate District Court of Appeal Case No. B257230 REQUEST FOR PERMISSION TO FILE AMICI CURIAE BRIEF OF LOS ANGELES TIMES COMMUNICATIONS LLC; MCCLATCHY NEWSPAPERS, INC.; GANNETT; FIRST AMENDMENT COALITION; CALIFORNIA BROADCASTERS ASSOCIATION; AND CALIFORNIA NEWSPAPER PUBLISHERS ASSOCIATION IN SUPPORT OF REAL PARTIES IN INTEREST ACLU OF SOUTHERN CALIFORNIA AND ERIC PREVEN; BRIEF OF AMICI CURIAE Karl Olson (SBN 104760) RAM, OLSON, CEREGHINO & KOPCZYNSKI LLP 101 Montgomery Street, Suite 1800 San Francisco, CA 94104 Tel: 415-433-4949 Fax: 415-433-7311 Email: [email protected]Attorneys for Amici
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County of Los Angeles Board of Supervisors v. Superior Court (ACLU of Southern California)
Friend of the court brief filed by Californians Aware and others supporting the ACLU of Southern California's effort under the California Public Records Act to obtain copies of private law firms' legal billings to Los Angeles County, which the county contends are privileged and confidential attorney-client communications and thus exempt from disclosure under the CPRA.
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No. S226645
IN THE SUPREME COURT OF CALIFORNIA
COUNTY OF LOS ANGELES BOARD OF SUPERVISORS, et al.,
Petitioners,
v.
THE SUPERIOR COURT OF LOS ANGELES COUNTY,
Respondent,
ACLU OF SOUTHERN CALIFORNIA, et al.,
Real Parties in Interest.
After a Judgment of the Court of Appeal of the State of California, Second Appellate District
Court of Appeal Case No. B257230
REQUEST FOR PERMISSION TO FILE AMICI CURIAE BRIEF
OF LOS ANGELES TIMES COMMUNICATIONS LLC; MCCLATCHY NEWSPAPERS, INC.; GANNETT; FIRST
AMENDMENT COALITION; CALIFORNIA BROADCASTERS ASSOCIATION; AND CALIFORNIA NEWSPAPER PUBLISHERS ASSOCIATION IN SUPPORT OF REAL PARTIES IN INTEREST
ACLU OF SOUTHERN CALIFORNIA AND ERIC PREVEN; BRIEF OF AMICI CURIAE
Karl Olson (SBN 104760) RAM, OLSON, CEREGHINO & KOPCZYNSKI LLP
101 Montgomery Street, Suite 1800 San Francisco, CA 94104
20120418. The County would block the public from access to this vital
information, even though agencies easily can protect client confidences on
attorney invoices through redactions – as occurs every day in the federal and state
court systems when litigants submit redacted invoices in statutory or contractual
fee-shifting cases.
For these reasons, and those set forth below, amici curiae – a coalition of
media and non-profit organizations who care about the spending of public money,
and the ability to monitor government operations1 – respectfully urge this Court to
grant permission to file the accompanying amicus brief on the merits in support of
real parties in interest.2
Dated: February 11, 2016 By: /s/ Karl Olson________________ Karl Olson RAM, OLSON, CEREGHINO & KOPCZYNSKI LLP Attorneys for Amici Curiae
1 The amici include Los Angeles Times Communications LLC;
McClatchy Newspapers, Inc.; Gannett; First Amendment Coalition; California Broadcasters Association; and California Newspaper Publishers Association.
2 Pursuant to California Rule of Court 8.520(f)(4), amici state that no party
or counsel for any party authored the proposed amicus brief in whole or in part, and no party or counsel for any party made a monetary contribution intended to fund the preparation or submission of the brief. No person or entity made a monetary contribution intended to fund the preparation or submission of the brief other than the amici, their members and the undersigned counsel.
TABLE OF CONTENTS I. INTRODUCTION .......................................................................................1
II. INTEREST OF AMICI CURIAE .................................................................2
III. THE COURT OF APPEAL’S DECISION DISREGARDS THE CALIFORNIA CONSTITUTION, CONFLICTS WITH EARLIER PRECEDENT, AND WOULD PREVENT THE PUBLIC FROM MONITORING PUBLIC SPENDING. .......................................................4
A. The Court of Appeal Disregarded the Constitutional Mandate to Narrowly Construe Statutes Limiting Access and Broadly Construe Statutes Promoting Access...........................4
B. Consistent Precedent Has Held That Invoices Are Not Privileged. ......................................................................................11
C. Access to Invoices Allows the Public to Monitor Public Spending ........................................................................................13
IV. IT WOULD NOT BE “ABSURD,” AS THE COUNTY CONTENDS, FOR THIS COURT TO ADHERE TO THE NARROW CONSTRUCTION OF EXEMPTIONS FROM DISCLOSURE SET FORTH IN ARTICLE I, SECTION 3(b)(2) OF THE CALIFORNIA CONSTITUTION. .............................................16
V. THE COUNTY ADVOCATES FOR A LIMITLESS PRIVILEGE. ........18
VI. INVOICES ARE THE BEST INFORMATION ABOUT SPENDING ON OUTSIDE COUNSEL. ..................................................19
VII. THE COUNTY’S POSITION WOULD HAVE UNDESIRABLE CONSEQUENCES IN FEE LITIGATION. ..............................................20
CERTIFICATE OF WORD COUNT ....................................................................22
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TABLE OF AUTHORITIES
Cases
Bighorn- Desert View Water Agency v. Verjil 39 Cal.4
th 205, 214 (2006).…………………………………………………… 17
CBS, Inc. v. Block 42 Cal. 3d 646, 653 (1986)…………………………………………………….. 7
City of New Haven v. FOIC 205 Conn. 767, 535 A.2d 1297 (1988)……………………………………….. 13
City Pages v. State of Minnesota 655 N.W.2d 839, 844-847 (Minn. App. 2003)……………………………….. 13
Clarke v. American Commerce Nat’l Bank 974 F.2d 127, 129-130 (9th Cir. 1992)…………………………………… 13, 17
Commission on Peace Officers Standards and Training v. Superior Court (“CPOST”) 42 Cal. 4
th 278, 291(2007)…………………………………………6
Costco Wholesale Corp. v. Superior Court 47 Cal. 4
th 725, 743(2009)………………………………………………... 11, 13
County of Los Angeles v. Superior Court (Anderson-Barker) 211 Cal. App. 4
th 57(2012)…………………………………………… 12, 17, 21
Cypress Media, Inc. v. City of Overland Park 997 P.2d 681, 692-93 (Kan. 2000)…………………………………………….13
Doe 2 v. Superior Court 132 Cal. App. 4
th 1504, 1522 (2005)…………………………………………... 4
Hotel Employees and Restaurant Employees v. Davis (1999) 21 Cal.4
th 585, 602 17
International Federation of Professional and Technical Engineers Local 21 v. Superior Court 42 Cal. 4
th 319, 333 passim
Mitchell v. Superior Court 37 Cal. 3d 591, 599 (1984)…………………………………………………….. 9
Montebello Rose Co. v. Agricultural Labor Relations Board 119 Cal. App. 3d 1, 32 (1981)…………………………………………………. 9
Northern California Police Practices Project v. Craig 90 Cal. App. 3d 116, 123-124 (1979)………………………………………….. 9
Pasadena Police Officers Association v. Superior Court 240 Cal. App. 4
th 268, 291(2015)……………………………………………… 8
iii
People v. Arias 45 Cal. 4
th 169, 180 (2008)…………………………………………………… 10
People v. Sinohui 28 Cal. 4
th 205, 215-216 (2002)………………………………………………. 17
Recorder v. Commission on Judicial Performance 72 Cal. App.4
th 258, 269-274 (1999)…………………………………………. 17
Sierra Club v. Superior Court 57 Cal. 4
th 157, 166-67 (2013)…………………………………………………. 4
Solin v. O’Melveny & Myers 89 Cal.App. 4
th 451, 457 (2001)……………………………………………….. 9
State Board of Equalization v. Superior Court 10 Cal. App. 4
th 1177, 1187 (1992)……………………………………………. 8
Wellpoint Health Networks, Inc. v. Superior Court 59 Cal. App. 4
Gannett Co., Inc. is an international news and information company that
publishes 93 daily newspapers in the United States and Guam, including The
Desert Sun in Palm Springs, The Salinas Californian, Visalia Times-Delta/Tulare
Advance-Register and USA TODAY. Each weekday, Gannett’s newspapers are
distributed to an audience of 9 million readers and the websites associated with
the company’s publications serve online content to 95 million unique visitors each
month.
California Broadcasters Association (“CBA”) is the trade
organization representing more than 1,000 radio and television broadcast
stations in the state. Founded in 1947, the CBA promotes the customs and
practices that allow licensed broadcasters to effectively serve the best
interests of their communities.
California Newspaper Publishers Association (“CNPA”) is a non-profit
organization with 907 member newspapers. CNPA has been a friend of this Court
in all of its recent cases involving the California Public Records Act.
The Reporters Committee for Freedom of the Press is a voluntary,
unincorporated association of reporters and editors that works to defend the First
Amendment rights and freedom of information interests of the news media. The
Reporters Committee has provided guidance and research in First Amendment
and Freedom of Information Act litigation since 1970.
Californians Aware, the Center for Public Forum Rights, is a non-profit
public benefit corporation organized under the laws of California, established in
2004 “to help journalists and others keep Californians aware of what they need to
know to hold government and other powerful institutions accountable for their
actions.” Its mission, rooted in the protections guaranteed by the First
Amendment as well as other state and federal laws, is “to support and defend
open government, an enquiring press and a citizenry free to exchange facts and
opinions on public issues.” Californians Aware has a diverse membership and
4
support base throughout the state, reflected in a board comprising equal numbers
of directors, including lawyers, from the fields of journalism, government service,
and community watchdog advocacy. Further information about its mission and
activities is available at https://www.calaware.org/calaware.
III. THE COURT OF APPEAL’S DECISION DISREGARDS THE CALIFORNIA CONSTITUTION, CONFLICTS WITH EARLIER PRECEDENT, AND WOULD PREVENT THE PUBLIC FROM MONITORING PUBLIC SPENDING.
A. The Court of Appeal Disregarded the Constitutional Mandate to Narrowly Construe Statutes Limiting Access and Broadly Construe Statutes Promoting Access.
Article I, section 3(b)(2) of the California Constitution requires that
statutes limiting the right of access be construed narrowly, and that statutes
furthering the right of access be broadly construed. Given this constitutional
mandate, and the strong public policy favoring access to information set forth in
Government Code section 6250, the preamble to the Public Records Act, “all
public records are subject to disclosure unless the Legislature has expressly
provided to the contrary.” Sierra Club v. Superior Court (2013) 57 Cal. 4th
157,
166-67.
The corollary of the rule that statutes promoting access must be broadly
construed is that, “The burden is on the agency maintaining the records to
demonstrate that the record in question is exempt.” (IFPTE, supra, 42 Cal. 4th
at
337.)
Similarly, a party claiming the attorney-client privilege has the burden of
showing that the communication sought to be suppressed falls within the
parameters of the privilege. Doe 2 v. Superior Court (2005) 132 Cal. App. 4th
1504, 1522; Wellpoint Health Networks, Inc. v. Superior Court (1997) 59 Cal.
App. 4th
110, 123 [burden of showing preliminary facts necessary to support the
privilege lies with the party claiming it]. Thus, the burden in this case rests upon
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the County both as the party resisting disclosure of public records and as the party
claiming an attorney-client privilege.
A consistent past practice of disclosure is relevant in determining whether
records should be disclosed. (IFPTE, supra, 42 Cal.4th
at 337 [citing past practice
of disclosing salaries in ruling that named public employees’ salaries must be
disclosed].
There is a long history of disclosure – including in Los Angeles County –
of attorney invoices. Going at least as far back as 1991, Los Angeles County was
producing the costs billed by private firms to the county to defend lawsuits. See
Los Angeles Times’ January 22, 1991 article entitled “$6 Million Spent by County
in Voting Case: Lawsuit: The legal bill in the losing battle will rise because
plaintiffs' costs must be paid. Supervisors defend the expense,”
individual’s salary may cause discomfort or embarrassment,” but strong public
policy supporting transparency justifies disclosure]. And public officials who
choose outside counsel aren’t spending their own money, so the incentives which
private parties have to ride herd on outside counsel aren’t present. Likewise,
outside counsel defending public agencies may have ample incentives to stroke
the egos of public officials and to encourage “millions for defense, not a penny
for tribute” attitudes which feed counsel’s bottom line but may not be in the best
interests of the taxpayers who are footing the bill.
This is by no means the only reason why the public should have access to
attorney invoices to public agencies. Lawyers have been known to be significant
contributors to politicians’ campaigns. The public has an overwhelming interest
in knowing whether a lawyer who contributed to a public official’s campaign was
rewarded with a plum piece of business and proceeded to unnecessarily “churn” a
case which could have been settled cheaply. Disclosure of attorney invoices will
thus, as this Court stated with respect to public employee salaries, make it
possible for members of the public to expose “corruption, incompetence,
inefficiency, prejudice and favoritism.” (IFPTE, supra, 42 Cal. 4th
at 333.)
Disclosure may also reveal “favoritism, or financial mismanagement in state and
local government.” (42 Cal. 4th
at 334.) If the County is allowed to do what it did
in this case – provide no descriptions of the work done by attorneys– there will be
no effective way to see whether tens of millions of dollars have been well spent.
IV. IT WOULD NOT BE “ABSURD,” AS THE COUNTY CONTENDS, FOR THIS COURT TO ADHERE TO THE NARROW CONSTRUCTION OF EXEMPTIONS FROM DISCLOSURE SET FORTH IN ARTICLE I, SECTION 3(b)(2) OF THE CALIFORNIA CONSTITUTION.
The County’s attempt to ignore the narrow construction of exemptions
mandated by article I, section 3(b)(2) of the California Constitution (Answer Brief
on the Merits at 41-47) fails.
17
As the ACLU observes, constitutional provisions prevail over statutes
where the two conflict. Hotel Employees and Restaurant Employees v. Davis
(1999) 21 Cal.4th
585, 602. Courts must give significance to every word in
constitutional enactments. Bighorn- Desert View Water Agency v. Verjil (2006)
39 Cal.4th
205, 214.
The County’s principal argument is that Evidence Code section 952 is
completely unambiguous in its exclusion of invoices from disclosure and that
there is accordingly no occasion to narrowly construe the statute.
The ACLU correctly points out that the phrase “in the course of” used in
Evidence Code section 952 is “inherently ambiguous.” (ACLU Reply at 9, citing
People v. Sinohui (2002) 28 Cal. 4th
205, 215-216.) The Court of Appeal, in a
similar context, held that the term “proceeding” was ambiguous, because it had
different possible meanings, and chose the meaning which best effectuated a
constitutional provision favoring openness in the proceedings of the Commission
on Judicial Performance. See Recorder v. Commission on Judicial Performance
(1999) 72 Cal. App.4th
258, 269-274. Here too, section 952 is ambiguous, and that
ambiguity should be resolved in favor of disclosure in accordance with article I,
section 3(b)(2) of the Constitution.
The County ignores the fact that many courts, both in California and
elsewhere, have concluded that invoices are not subject to the attorney-client
privilege. See cases cited in section III B supra including County of Los Angeles
v. Superior Court (Anderson Barker) (2012) 211 Cal. App. 4th
57, 61-62 [trial
court found invoices not entirely subject to attorney-client privilege, though
portions could be redacted; county did not challenge that portion of the ruling on
appeal]; Clarke v. American Commerce National Bank, 974 F.2d 127, 130 [under
federal common law, attorney billing statements were not privileged; the
statements contained information on the identity of the client, the case name for
18
which payment was made, the amount of the fee, and the general nature of the
services performed’ “[o]ur previous decisions have held that this type of
information is not privileged”; court found nothing in the statements “that reveals
specific research or litigation strategy which would be entitled to protection from
disclosure”] and out-of-state cases. If, as the County contends, the privileged
status of invoices is “crystal clear” and completely unambiguous (Answer Brief
on Merits at 44-46), and if acceptance of the ACLU’s narrow-construction
argument and the narrow-construction mandate of article I, section 3(b)(2) of the
Constitution would lead to “absurd results,” as the County heatedly contends, the
crystal clarity of the statute and the “absurdity” of making invoices subject to
disclosure seems to have escaped a number of courts.
Likewise, the County’s argument that it would be “absurd” for this Court
to make invoices subject to disclosure in the Public Records Act context but not in
other contexts assumes too much. The County has failed to establish that invoices
fall within the privilege even outside the Public Records Act context. Adherence
to the narrow construction mandate of article I, section 3(b)(2) to resolve a
question which may have previously escaped clear resolution both under the
Public Records Act and in other California cases would not be “absurd”, it would
be faithful to a constitutional enactment which came into being with an 83
percent vote of the people for Proposition 59 in 2004.
V. THE COUNTY ADVOCATES FOR A LIMITLESS PRIVILEGE.
The County attempts to downplay the sweeping nature of the ruling it
seeks by saying that “no one contends the privilege extends to every word or
writing exchanged between lawyer and client.” (Answer Brief on Merits at 48.)
But it’s far from clear what would not be privileged under the County’s definition.
The County argues that “any transmission of information” between a lawyer and a
19
client falls within the privilege, including but not limited to a legal opinion or
invoice. (Answer Brief at 49.) Under that definition, even giving directions to a
lawyer’s office or communications about the time of a meeting would fall within
the privilege, since such ministerial communications would involve the
“transmission of information” during the course of a lawyer-client relationship.
Such a broad construction of section 952 is neither compelled by that statute nor
consistent with the required narrow construction of exemptions.
VI. INVOICES ARE THE BEST INFORMATION ABOUT SPENDING ON OUTSIDE COUNSEL.
The county argues that even if invoices are deemed privileged, the
same information may be discoverable by other means. (Amicus Brief at
49-50.)
This argument bears some resemblance to an argument made by
public employee unions in the IFPTE case, which was rejected by this
court. There, the public employee unions argued that disclosure of salaries
alone – without names attached – would suffice to educate the public about
the spending of public money. This court rejected that contention, holding
that disclosure of names along with salaries was essential to enable the
public to monitor public spending, because it might reveal “corruption,
incompetence, inefficiency, prejudice and favoritism.” (42 Cal.4th
at 333.)
The court cited several newspaper articles to make that point. (Id. at 334.)
Here too, disclosure of invoices is essential to enable the public to
see whether money paid to outside counsel has been well spent. After all,
the purpose of an invoice is two-fold: to get the attorney paid, and to let the
client know what the attorney did to earn the fee. Gone are the days when
an attorney might send a corporate client an invoice reading simply “for
services rendered, $25,000.” Clients rightfully expect and demand an
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itemization of who did what when and how many hours it took to do it.
In the context of spending on counsel by public agencies, the real
client is the public, the people whose taxes foot the bill. If the County gets
its way and invoices are shielded, the real client will be deprived of the
ability to see invoices, and will essentially be writing blank checks. That
would no doubt be convenient for the bureaucrats who decide to hire
outside counsel, but that sort of taxation without representation has never
been the norm in this country and should not become the norm now.
VII. THE COUNTY’S POSITION WOULD HAVE UNDESIRABLE CONSEQUENCES IN FEE LITIGATION.
The County brushes aside the ACLU’s concern that recognition of
an absolute privilege would have undesirable consequences in fee litigation.
(Answer Brief at 50-58.)
The ACLU has the better of the argument. The County spends a lot
of time arguing that parties seeking fees won’t try to hide invoices (Answer
Brief at 52) and will suffer the consequences if they do. Maybe so. But the
County ignores the far more common situation where a party seeks fees
against a public agency and the agency contests the claim. If the County
gets its way, an agency would be free to claim that its adversary spent too
much time litigating a case or an issue, or that the rates were too high, and
at the same time, resist disclosure of its own invoices which might reveal
that the agency spent even more time at higher rates. This court should not
countenance such a “heads I win, tails you lose” argument.
CONCLUSION
The Court of Appeal’s decision here narrowly construed and ignored the
Public Records Act, and expanded the attorney client privilege to encompass
invoices whose self-evident purpose is not to communicate legal advice but
21
simply to “facilitate the payment of attorney fees on a regular basis.” (Anderson-
Barker, 211 Cal. App. 4th
at 67.) The Court of Appeal’s decision conflicted with
the result reached by another division of the Second District less than three years
ago. As this Court stated in the IFPTE case, 42 Cal. 4th
at 334, “‘It is difficult to
imagine a more critical time for public scrutiny of its governmental decision-
making process than when the latter is determining how it shall spend public
funds.’” This Court should reverse the Court of Appeal’s decision, to preserve
the efficacy of the Public Records Act.
Dated: February 11.2016 RAM, OLSON, CEREGHINO & KOPCZYNSKI LLP By: /s/ Karl Olson_______________ Karl Olson Attorneys for Amici Curiae N:\Docs\1422-01 County of LA Amicus\Amicus-FINAL County of LA Board of Supervisors.doc
22
CERTIFICATE OF WORD COUNT
(California Rules of Court, Rule 8.204(c)(1))
Pursuant to Rule 8.204(c)(1), and in reliance upon the word count
feature of the software used, I certify that the foregoing REQUEST FOR
PERMISSION TO FILE TO FILE AMICI CURIAE BRIEF OF LOS
ANGELES TIMES COMMUNICATIONS LLC; MCCLATCHY
NEWSPAPERS, INC.; GANNETT; FIRST AMENDMENT COALITION;
CALIFORNIA BROADCASTERS ASSOCIATION; AND CALIFORNIA
NEWSPAPER PUBLISHERS ASSOCIATION IN SUPPORT OF REAL
PARTIES IN INTEREST ACLU OF SOUTHERN CALIFORNIA AND
ERIC PREVEN; BRIEF OF AMICI CURIAE contains 6,801 words,
exclusive of those materials not required to be counted under Rule
8.204(c)(3).
Dated: February 11, 2016 RAM, OLSON, CEREGHINO & KOPCZYNSKI LLP By: /s/ Karl Olson_______________ Karl Olson Attorneys for Amici Curiae
PROOF OF SERVICE County of Los Angeles Board of Supervisors et aL y. The Superior Court
of Los Angeles County No. 5226645
I, David Blum, state:
I am a citizen of the United States. My business address is 101
Montgomery Street, Suite 1800, San Francisco, CA 94104. I am employed
in the City and County of San Francisco where this mailing occurs. I am
over the age of eighteen years and not a party to this action. On the date set
forth below, I served the foregoing documents described as:
REQUEST FOR PERMISSION TO FILE AMICI CURIAE BRIEF OF LOS ANGELES TIMES COMMUNICATIONS LLC; MCCLATCHY NEWSPAPERS, INC.; GANNETT; FIRST AMENDMENT COALITION; CALIFORNIA BROADCASTERS ASSOCIATION; AND CALLFORNL& NEWSPAPER PUBLISHERS ASSOCIATION IN SUPPORT OF REAL PARTIES IN INTEREST ACLU OF SOUTHERN CALIFORNIA AND ERIC PREVEN;BRIEF OF AMICI CURIAE
REQUEST FOR JUDICIAL NOTICE AND PROPOSED ORDER; DECLARATION OF KARL OLSON IN SUPPORT OF REQUEST FOR JUDICIAL NOTICE OF LOS ANGELES TIMES COMMUNICATIONS LLC; MCCLATCHY NEWSPAPERS, INC.; GANNETT; FIRST AMENDMENT COALITION; CALIFORNIA BROADCASTERS ASSOCIATION; AND CALIFORNIA NEWSPAPER PUBLISHERS ASSOCIATION IN SUPPORT OF REAL PARTIES lIN INTEREST ACLU OF SOUTHERN CALIFORNIA AND ERIC PRE VEN;
on the following person(s) in this action addressed as follows: SEE ATTACHED SERVICE LIST
X BY FIRST CLASS MAIL - I am readily familiar with my firm's practices for collection and processing of correspondence for mailing with the United States Postal Service, to-wit, I deposited with the United States Postal Sen'ice this same day in the ordinary course of business the said correspondence in a sealed envelope, postage prepaid.
I declare under penalty of perjury under the laws of the State of
California that the foregoing is true and correct and that this declaration
was executed on February 11, 2016, at Saikrancisco California.
David Blum
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County of Los Angeles Board of Supervisors et aL y. The Superior Court of Los Angeles County
Office of the Clerk (LASC No. BS145753) Honorable Luis A. Lavin Los Angeles Superior Court Case 111 North Hill Street Los Angeles, CA 90012
Frederick Bennett Los Angeles Superior Court 111 North Hill Street, Room 546 Los Angeles, CA 90012
Peter Eliasberg ACLU Foundation of Southern California 1313 West 8th Street Los Angeles, CA 90017 Attorneys for Real Parties in InterestACLu of Southern Cal jfornia and Eric Preven
Barbara Ravitz GREINES, MARTIN, STEIN & RICHLAND, LLP 5900 Wilshire Blvd., 12th Floor Los Angeles, CA 90036 Attorneys for County of Los Angeles Board of Supervisors and The Office of County Counsel Sally Suchil Los Angeles County Bar Association P.O. Box 55020 Los Angeles, CA Attorneys for Los Angeles County Bar Association: Amicus curiae
Stephen Louis Raucher Reuben Raucher & Blum 10940 Wilshire Boulevard, 18th floor Los Angeles, CA Attorneys for Beverly Hills Bar Association: Amicus curiae
Office of the Clerk California Court of Appeal Second Appellate District, Division Three 300 South Spring Street Second Floor, North Tower Los Angeles. CA 90013
CFAC 2701 Cottage Way#12 Sacramento, CA 95825 Attorneys for Cal jfornians Aware The Center for Publie Forum Rights : Pub/Depublication
Jennifer Brockett Rochelle L. Wilcox Colin Wells Diana Palacios DAVID WRIGHT TERMAINE LLP 865 S. Figueroa, Suite 2400 Los Angeles, CA 90017 Attorneys for Real Parties in InterestACLU of Southern California and Eric Preveis Mary Wickham Roger Granbo Jonathan McCaverty 648 Kenneth Hahn Hall of Administration 500 West Temple Street Los Angeles, CA 90012 Attorneys for County of Los Angeles Board of Supervisors and The Office of County Counsel
Steven Samuel Fleischman Lisa Perrochet Horvitz & Levy LLP 15760 Ventura Boulevard, 18th floor Encino, CA 91436 Attorneys for Association of Southern Cal jfornia Defense Counsel : Amicus curiae
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