-
12
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
1 [PROPOSED] PEREMPTORY WRIT OF MANDATE
SUPERIOR COURT OF THE STATE OF CALIFORNIA
IN AND FOR THE COUNTY OF SACRAMENTO
NATIONAL CONFERENCE OF BLACK MAYORS, a Georgia not-for-profit corporation; SACRAMENTO MAYOR KEVIN M. JOHNSON, in his official capacity as the former President of the National Conference of Black Mayors; and EDWIN K. PALMER, in his official capacity as Chapter 7 Trustee for the National Conference of Black Mayors,
Petitioners,
v. CITY OF SACRAMENTO; SACRAMENTO CITY ATTORNEYS OFFICE;CHICO COMMUNITY PUBLISHING, INC. a/k/a SACRAMENTO NEWS & REVIEW, a California corporation; and DOES 1 through 20 inclusive.
Respondents.
Case No. _________________ [PROPOSED] PEREMPTORY WRIT OF MANDATE
-
12
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
2 [PROPOSED] PEREMPTORY WRIT OF MANDATE
This matter is before the Court on Petitioners Verified Petition for Peremptory Writ
of Mandate filed on July 1, 2015 (the Petition). The Court, having fully considered the
Petition and all papers, evidence, and argument presented by counsel in connection therewith,
and being otherwise fully advised in the premises, hereby enters this Peremptory Writ of
Mandate and ORDERS as follows:
1. The City of Sacramento and its officers, agents, employees and all other persons
acting on its behalf, including the City Attorneys Office (collectively, the City), are hereby
commanded, with respect to records otherwise discoverable pursuant to a request made by the
Sacramento News & Review under the California Public Records Act (the City Records),
not to release or disclose to the Sacramento News & Review or to any other person or entity any
e-mails, correspondence, communications, records, or any other materials of any kind that are
protected from disclosure by the attorney-client and work product privileges and which have
been sent or received by: (i) the National Conference of Black Mayors (NCBM); (ii) the office
of Sacramento Mayor Kevin M. Johnson acting in his official capacity as the former President of
the NCBM (President Johnson); (iii) Edwin K. Palmer, in his official capacity as Chapter 7
Trustee for the NCBM (Trustee Palmer); and (iv) Ballard Spahr LLP, acting in its capacity as
counsel for the NCBM, President Johnson, and/or Trustee Palmer (the Privileged
Communications).
2. Prior to the release or disclosure of any City Records, the City shall make
available, on a confidential basis, all such City Records to Ballard Spahr LLP, who shall be
permitted to present its views to the City concerning such City Records so that no Privileged
Communications are inadvertently disclosed.
IT IS SO ORDERED
DATED: _____________ BY: _____________________________ Hon. Superior Court Judge
