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VERIFIED PETITION FOR DECLARATORY RELIEF AND WRIT OF MANDATE TO ENFORCE THE CALIFORNIA PUBLIC RECORDS ACT; EXHIBITS A – D
[Cal. Gov’t Code § 6250 et seq.; Code Civ. Proc. § 1085 et seq.]
SUPERIOR COURT OF THE STATE OF CALIFORNIA
FOR THE COUNTY OF VENTURA
FIRST AMENDMENT COALITION, a
California non-profit corporation,
Petitioner,
vs.
COUNTY OF VENTURA, AND DOES 1-10
inclusive,
Respondent.
PRAYER FOR RELIEF
WHEREFORE, Petitioner First Amendment Coalition respectfully prays that this Court:
A. Issue a writ of mandate directing the County to comply fully and without further
delay with the California Public Records Act to provide FAC with those public documents
responsive to the January Request and the March Request that are not subject to any exemption,
and to specifically identify and describe any documents allegedly exempt from disclosure;
B. Declare that the County has violated FAC’s rights under the CPRA, Gov. Code §
6250 et seq., and the California Constitution, Art. I § 3, by failing to substantively respond to
FAC’s requests;
C. Enter an injunction directing that because the County’s failure to comply with its
obligations under the CPRA was without substantial justification, the County must waive all fees
associated with FAC’s requests;
D. Award FAC reasonable attorney fees and costs as authorized by Government Code
§ 6259, Code of Civil Procedure § 1021.5 and any other applicable provisions of law; and
E. Grant FAC such additional relief as the Court may deem proper and just.
DATED: April 22, 2021
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