UPDATE: ROYAL CALKINS Petitioner, v. CITY OF CARMEL-BY-THE-SEA, and Does 1 through 10, inclusive, Respondents. Case No.: 18CV002532 SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF MONTEREY

SEPTEMBER 6, 2018
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OPINION | 

By Royal Calkins

CARMEL GOES TO COURT

ABSTRACT: Document copies of REPLY MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF PETITION FOR WRIT OF MANDATE, DECLARATION OF NEIL L. SHAPIRO IN SUPPORT OF PETITION FOR WRIT OF MANDATE, OBJECTIONS TO DECLARATION OF GERARD A. ROSE IN OPPOSITION TO PETITION FOR WRIT OF MANDATE and DECLARATION OF ROYAL CALKINS IN SUPPORT OF PETITION FOR WRIT OF MANDATE are embedded with selected excerpts reproduced.

REPLY MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF PETITION FOR WRIT OF MANDATE

ROYAL CALKINS Petitioner, v. CITY OF CARMEL-BY-THE-SEA, and Does 1 through 10, inclusive, Respondents.

Case No.: 18CV002532

SUPERIOR COURT OF THE STATE OF CALIFORNIA

COUNTY OF MONTEREY

CONCLUSION

"'Sunlight is said to be the best of disinfectants; electric light the most efficient policeman.' Brandeis, Other People's Money p. 62" quoted in Buckley v. Valeo (1976) 424 U.S. 1, 67. Fair Political Practices Com. v. Suitt (l979) 90 Cal.App.3d 125, 132. The California Legislature enacted both the Brown Act and the Public Records Act in recognition of the reality that government works best for those it governs when it operates openly. Respondent City asks this Court to allow it to shove government back into the dark shadows, away from public inquiry. Instead, this court should grant the requested writ and allow the public to see its records.

DECLARATION OF NEIL L. SHAPIRO IN SUPPORT OF PETITION FOR WRIT OF MANDATE
ROYAL CALKINS Petitioner, v. CITY OF CARMEL-BY-THE-SEA, and Does 1 through 10, inclusive, Respondents.
Case No.: 18CV002532
SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF MONTEREY

DEPOSITION OF GLEN MOZINGO, CITY ATTORNEY
DATE: Wednesday, August 22, 2018
TIME 10 : 04 A.M . - 10 : 52 A .M.
LOCATION: Absolute Court Reporters
80 Garden Court , Suite 270
Monterey, California
REPORTED BY: Jenna Osborn, Certified Shorthand Reporter No. 8681

OBJECTIONS TO DECLARATION OF GERARD A. ROSE IN OPPOSITION TO PETITION FOR WRIT OF MANDATE
ROYAL CALKINS Petitioner, v. CITY OF CARMEL-BY-THE-SEA, and Does 1 through 10, inclusive, Respondents.
Case No.: 18CV002532
SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF MONTEREY

PRELIMINARY STATEMENT
The Rose Declaration in its entirety stands in sharp contrast to the proper standards of behavior expected by this Court. Rather than illuminating the record with facts relevant to this Court's inquiry, it offers nothing more than a vicious and unfounded personal attack on Calkins. As such, it speaks more to the character of the declarant than it does the character of Calkins. Moreover, it ignores this Court's standards of civility, is offensive to any reasonable practitioner, and accomplishes nothing. To the contrary, it appears to be a sad attempt to deflect this Court's attention from the reality that respondent City of Carrnel-by-the-Sea lacks legal or logical support for its refusal to disclose public records.

DECLARATION OF ROYAL CALKINS IN SUPPORT OF PETITION FOR WRIT OF MANDATE
ROYAL CALKINS Petitioner, v. CITY OF CARMEL-BY-THE-SEA, and Does 1 through 10, inclusive, Respondents.
Case No.: 18CV002532
SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF MONTEREY

REFERENCE: 18CV002532

Calkins, Royal vs. City of Carmel-by-the-Sea

HEARINGS

Department 14 9/7/2018 9:00AM Hearing: Writ
Department 14 11/6/2018 9:00AM Conference: Case Management

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SUPERIOR COURT OF CALIFORNIA, COUNTY OF MONTEREY