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Craig A. Sherman, Esq. (SBN 171224) CRAIG A. SHERMAN, A PROFESSIONAL LAW CORP. 1901 First A venue, Suite 219

wrn SEP 28 PM I: 33 f ' i

San Diego, CA 92101 Telephone: (619) 702-7892

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Email: [email protected]

Attorney for Plaintiffs PARENTS FOR QUALITY EDUCATION; MARGARET SANBORN; and RICARDO CASTILLO

SUPERIOR COURT OF THE STATE OF CALIFORNIA

COUNTY OF SAN DIEGO, CENTRAL DlVISION

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11 PARENTS FOR QUALITY EDUCATION; MARGARET SANBORN, an individual;

12 and RICARDO CASTILLO, an individual;

13 Plaintiffs,

14 v.

15 SAN DIEGO UNIFIED SCHOOL DISTRICT; KEVIN BEISER, in his official capacity as

16 Board President of the San Diego Unified School District; CITY OF SAN DIEGO;

17 MYRTLE COLE, in her official capacity as President of the San Diego City Council; L.

18 MICHAEL VU, in his official capacity as the Registrar of Voters of San Diego County; and

19 DOES ONE through TWENTY-FIVE, inclusive;

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Defendants I Respondents.

KEVIN BEISER and TOM KELIINOI, candidates in the general election for the District B seat on the San Diego Unified Board of Education; MICHAEL MCQUARY and MARCIA NORDSTROM, candidates in the general election for the District C seat on the San Diego Unified Board of Education; and DOES TWENTY-SIX through FIFTY, inclusive;

Real Parties in Interest.

- 1 -

Case NO . 37-201 s--00049253-eu-J R-CTL

COMPLAINT FOR DECLARATORY ANB INJ-BNCTIVE R-Ebl-EFi PEJil'ION FOR WRIT OF MANDATE

[Violation of The California Voting Rights Act of 2001]

COMPLAINT FOR DECLARATORY RELIEF AND INJUNCTIVE RELIEF; PETITION FOR WRIT OF MANDA TE

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3 1.

I.

INTRODUCTION AND PURPOSE OF LAWSUIT

This action challenges defendant SAN DIEGO UNIFIED SCHOOL DISTRICT's

4 ("SDUSD") imposition of a discriminatory at-large system to elect members of its governing board,

5 because this election system violates the California Voting Rights Act ("CVRA"), California

6 Elections Code, section 14025 et seq. But SDUSD is not wholly to blame because defendant CITY

7 OF SAN DIEGO's ("City"), as the charter city controlling the historic and now arcane election

8 methodology for the membership of the SDUSD school board ("SDUSD School Board"), has refused

9 to revise and correct said voting methodology.

10 2. Therefore, this action more directly challenges the CITY OF SAN DIEGO's ("City")

11 breach of its legal and ministerial duty to allow and provide an election system that complies with the

12 CVRA, because City's voting scheme for the SDUSD, as set forth in City Charter§ 66 - providing

13 for district-wide at-large voting to elect particular school district representatives for the SDUSD

14 board members - discriminates and prevents certain races or ethnic groups from electability to the

15 SDUSD school board.

16 3. Because City and SDUSD continue to allow, and refuse to take action to correct the

17 violative voting methodology, Plaintiffs name and sue defendant L. MICHAEL VU, as the

18 Registrar of Voters of San Diego County ("Registrar of Voters") to prevent him and his office

19 from certifying results of the November 6, 2018 election because it is known and can be proven

20 that said election and City's and SDUSD's election methodology violates the CVRA.

21 4. Because Plaintiffs' lawsuit seeks to invalidate the November 6, 2018 election for

22 the SDUSD School Board, Plaintiffs also name those running for election as real parties in

23 interest, KEVIN BEISER, TOM KELIINOI, MICHAEL MCQUARY, and MARCIA

24 NORDSTROM (hereafter "Real Parties"), because enjoining and disqualifying the election

25 results of the November 6, 2018 election stands to impair potential rights of said named Real

26 Parties.

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- 2 -COMPLAINT FOR DECLARATORY RELIEF AND INJUNCTIVE RELIEF; PETITION FOR WRIT OF MANDATE

II.

2 PARTIES, JURISDICTION AND VENUE

3 5. Plaintiff PARENTS FOR QUALITY EDUCATION ("PQE") is a public interest

4 group formed under California laws to improve public education through increased involvement

5 of parents and the community in the educational process. The ultimate goals are to strengthen

6 the capacity of communities to act as catalysts to transform and revitalize public education, so

7 every child receives a quality education and establish a grassroots presence in local, state, and

8 federal legislative bodies to positively influence K-12 education policy and secure adequate laws

9 to ensure quality education for children and youth.

10 6. On or before March of 2017, PQE initiated a local San Diego initiative and

11 project called "Community Voices for Education" (CVE) to bring accountability, transparency,

12 and real representation in San Diego's public education system so that every child receives a

13 quality education. PQE began advocating through CVE for the City reform the election

14 methodology for School Board Election. CVE objected and demanded that City revise the

15 election process for the SDSUD School Board to have Subdistrict only elections, following the

16 model of City Council elections.

17 7. Plaintiff MARGARET SANBORN is a registered City and SDUSD voter who

18 lives within one of the SDUSD school subdistricts and is of API race, descent, or ethnicity that is

19 both impaired in its ability to elect a SDSUD School Board member and who is a member of a

20 "protected class," as that term is defined in the CVRA.

21 8. Plaintiff RICARDO CASTILLO is a registered City and SDUSD voter who lives

22 within one of the SDUSD school subdistricts and is of Latino race, descent, or ethnicity that is

23 both impaired in ability to elect SDSUD School Board members who are members of a

24 "protected class," as that term is defined in the CVRA.

25 9. Defendant SAN DIEGO UNIFIED SCHOOL DISTRICT ("SDUSD") is a public

26 school district within the State of California, County of San Diego serving all public school

27 grades including K-12. SDUSD is required to follow the mandate, and prevent violations, of the

28 CVRA.


10. Defendant CITY OF SAN DIEGO ("City") is organized and existing under the

2 laws of the State of California, and its status as a Charter City, with its governing body as the

3 San Diego City Council. City is required to follow the mandate, and prevent violations, of the

4 CVRA.

5 11. Defendant L. MICHAEL VU is the Registrar of Voters for the County of San

6 Diego (hereafter "Registrar of Voters"), who is named and sued to prevent him and his office

7 from certifying results of the November 6, 2018 election because Plaintiffs and this Court need

8 to have jurisdiction and control to order the Registrar of Voters to take specific preventative and

9 prohibited action once it is proven that said election and election methodology was conducted in

10 violation of the CVRA.

11 12. Because Plaintiffs' lawsuit seeks to invalidate the November 6, 2018 election for

12 the SDUSD School Board, Plaintiffs also name those running for election as real parties in

13 interest, KEVIN BEISER, TOM KELIINOI, MICHAEL MCQUARY, and MARCIA

14 NORDSTROM (hereafter "Real Parties"), because enjoining and disqualifying the election

15 results of the November 6, 2018 election stands to impair the rights of said named Real Parties.

16 Specifically, Real Pa~ies KEVIN BEISER and TOM KELIINOI are candidates for election of

17 the seat for Subdistrict Bon the SDUSD School Board and Real Parties MICHAEL MCQUARY

18 and MARCIA NORDSTROM are candidates for the seat for Subdistrict C seat on the SDUSD

19 School Board.

20 13. The true names and capacities of defendants and respondents DOES ONE through

21 TWENTY-FIVE, inclusive, are unknown to Plaintiffs who therefore sue such unknown

22 defendants by fictitious names pursuant to California Code of Civil Procedure§ 474. The true

23 names and capacities of real parties in interest DOES TWENTY-SIX through FIFTY are also

24 unknown to Plaintiffs who therefore sue such unknown real parties by fictitious names pursuant

25 to California Code of Civil Procedure§ 474. Plaintiffs will amend this complaint to allege the

26 true names and capacities of any unknown or necessary defendants, respondents, or real parties

27 in interest sued herein as DOES ONE through FIFTY, inclusive, if and when ascertained.

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14. All parties hereto are within the unlimited jurisdiction of this Court. The unlawful

2 acts complained occurred in San Diego County. Venue in this Court is proper.

3 III.

4 ESSENTIAL FACTUAL ALLEGATIONS

5 15. SDUSD is located in San Diego County, California and mainly serves the area in

6 and around the City. The governing SDUSD School Board is made up of five members who are

7 elected district wide, with each of the SDUSD's five Subdistricts nominating the top two

8 candidates for their board representatives in the primary election, but the entire SDUSD school

9 district votes "at-large" for each Subdistrict representative in the general election. Each elected

10 member is purported to represent the entire school district. The at-large voting process, for the

11 SDUSD School Board, does not align with most every other publicly elected school board

12 official, including City Council offices for the City, and further does not align with any of the

13 other three largest school districts in the state.

14 16. The total emollment of students served by SDUSD, as of September 15, 2017,

15 was 127,112 students, of whom only 23% are white (as of January 25, 2017). This is in stark

16 contrast to members serving on the Board which is 60-80% white and potentially or

17 approximately 60% non-Hispanic white. This reflects the systematic unfairness of at-large

18 elections in which a district-wide white electorate majority elects predominantly white

19 candidates of their choice, even though the number of white students is a demographic minority

20 of actual students in the SDUSD school system.

21 17. The at-large method of SDUSD School Board elections disenfranchises African

22 Americans, Asians, Pacific Islanders, Latinos, Inda-Chinese, Native Americans, Filipinos, and

23 others, who together make up 77% of the SDUSD school district. Under the CVRA, the at-large

24 elections system must be replaced by a district-based system so that non-white groups, who are

25 electoral race and ethnic minorities, but represent a majority of the actual student population,

26 may have their chance and fair opportunities to elect candidates of their choice, rather than the

27 disparate and water-down election process that results from an at-large election.

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18. Elections conducted for the SDUSD School Board are characterized by racially

2 polarized voting. Racially polarized voting occurs when members of a protected class, as

3 defined by the CVRA and California Elections Code§ 14025, subdivision (d), vote for

4 candidates and electoral choices that are limited, different, or watered-down from the rest of the

5 electorate based on the manner of voting or the districts drawn for voting. Racially polarized

6 voting exists for the SDUSD School Board for Latino and API voters because their choice of

7 candidates, as compared with other non-Latino or API candidates, who are preferred as Latino or

8 API candidates, usually lose and have little or no chance of winning in an at-large election.

9 19. Racially polarized voting is legally significant in SDUSD School Board elections

Io because it dilutes the opportunity of Latino and API voters to elect candidates of their choice.

11 Patterns of racially polarized voting has the effect of impeding the opportunity for Latino and

12 API voters to elect candidates of their choice via an at-large election where Latino and API

13 populations have their votes diluted, as opposed to Subdistrict elections wherein Latino and API

14 voters, either as individual groups or as a coalition, have the opportunity to elect candidates of

15 their choice. For several years now, Latino and API voters have been harmed by racially

16 polarized voting and the City's and SDUSD's voting methodology.

17 20. The at-large method of election and repeated racially polarized voting has caused

18 Latino and API voting dissolution within the SDUSD School Board. When Latinos or API and

19 the rest of the electorate express different preferences for candidates and other electoral choices,

20 non-Latino and API voters, by virtue of overall numerical majority among voters in the at-large

21 district level dilute the preferences of Latino and API voters.

22 21. The obstacles posed by City's and SDUSD's at-large method of election, together

23 with racially polarized voting, impairs the ability of people of certain races, color, language, or

24 minority groups, such as Latino and API voters, to elect candidates of their choice or to influence

25 the outcome of elections conducted for the SDUSD School Board.

26 22. An alternative and more regularly accepted method of elections exists, by way of

27 district-based elections, that will provide an opportunity for the members of the protected classes

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(as defined by the CVRA) to elect candidates of their choice and be able to have a more regular

2 and fair manner to influence and have a say in the outcome of SDUSD School Board elections.

3 IV.

4 FIRST CAUSE OF ACTION -DECLARATORY AND INJUNCTIVE RELIEF

5 Violation of California Voting Rights Act of 2001

6 (As Against Defendant City)

7 23. Plaintiffs reallege and incorporate by reference all paragraphs above and below as

8 if set forth fully herein.

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24.

25.

City is a political subdivision within the state of California and is a charter city.

Pursuant to California Elections Code § 14026, subdivision ( c ), the CVRA applies

11 to charter cities.

12 26. City, through its governing body of the City Council, has the inherent power to

13 enact laws or new ordinances to comply with State Law including the CVRA.

14 27. City is aware of the racial polarization and vote dilution arising from at-large

15 elections for members of the SDUSD School Board.

16 28. Racially polarized voting has occurred, and continues to occur, in elections for the

17 members of the SDSUD School Board. As a result, City's at-large method of election for the

18 SDUSD School Board is imposed in a manner that impairs the ability of protected classes, as

19 defined by the CVRA, to elect candidates of their choice or influence the outcome of elections.

20 29. An alternative method of elections, such as district-based elections, exists that

21 will provide an opportunity for the members of a protected class (as defined by the CVRA) to

22 elect candidates of their choice or influence the outcome of the SDUSD School Board elections.

23 30. An actual controversy has arisen and now exists between Plaintiffs and

24 Defendants, relating to the legal rights and duties of Plaintiffs and CITY.

25 31. Specifically, City has a duty under the CVRA to use its inherent legislative

26 powers to stop racial polarization and vote dilution under the CVRA as currently present in the

27 City Charter.

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32. Plaintiffs have a clear, present and beneficial right to the proper performance by

2 City in its duties and compliance with the laws and legal principles as set forth herein.

3 33. The declaratory and injunctive relief requested herein is proper to delineate and

4 clarify the parties' rights and liabilities and resolve, quiet, or stabilize an uncertain or disputed

5 jural relation and to prevent further violations of the CVRA. Without the grant of declaratory

6 relief and the granting of an injunction, City will continue to proceed in a manner not allowed by

7 law and will continue to take action outside of the law and their authority resulting in harm to

8 Plaintiffs, its members, supporters, and the citizenry of the City of San Diego and State of

9 California for whom this litigation is equally brought. In order to vindicate the legislative intent

10 of the CVRA and to enforce their respective provisions, Plaintiffs have no choice but to obtain

11 the relief sought herein.

12 34. Plaintiffs seek a judicial determination that Charter § 66 violates the CVRA in its

13 current form and manner of implementation and therefore is null, void, and unenforceable.

14 35. Plaintiffs seek a judicial determination regarding City's compliance with the

15 CVRA for a remedy and vindication of the rights of all voters within the school district,

16 including Plaintiffs. A declaratory judgment should be granted in favor of Plaintiffs as alleged

17 and requested herein.

18 V.

19 SECOND CAUSE OF ACTION -PETITION FOR WRIT OF MANDATE

20 (As Against Defendant City)



23 37. Plaintiffs do not have any plain, speedy, or adequate remedy in the ordinary

24 course of law. Plaintiffs' only recourse is the relief provided by the CVRA which provides for

25 judicial review.

26 38. If the City's actions are allowed to stand and continue, Plaintiffs' rights will be

27 impaired and will suffer irreparable harm, including racially polarized voting, in elections for the

28 members of the SDUSD School Board, and in elections incorporating other electoral choices by


voters residing within the geographical districts of the SDUSD. No money damages or other

2 legal remedy could adequately compensate Plaintiffs for the harm from violation of their rights

3 under the CVRA that City has caused and will continue to cause by acting in contravention and

4 refusing to comply with the CVRA.

5 39. Plaintiffs request that this Court issue a peremptory writ of mandamus directing

6 City to comply wit_h its duties, and correct the at-large election method that violates the CVRA.

7 VI.

s THIRD CAUSE OF ACTION -DECLARATORY AND INJUNCTIVE RELIEF


10 (Against Defendant SDUSD)



13 41. SDUSD is a political subdivision within the state of California and is a school

14 district.

15 42. SDUSD accepts that City (through its laws and City Charter) employs a modified

16 at-large method of election, whereby each of SDUSD' s five Subdistricts holds a primary vote,

17 with the top two vote-getters competing in an at-large general election in which the entire

18 jurisdiction votes to elect SDUSD School Board members.

19 43. Racially polarized voting has occurred, and continues to occur, in elections for the

20 members of the SDUSD School Board. As a result, SDUSD has accepted, not challenged, nor

21 requested that City amend the City's at-large method of election that impairs the ability of

22 protected classes, as defined by the CVRA, to elect candidates of their choice or influence the

23 outcome of elections.

24 44. Alternative methods of elections, such as district-based elections, exist that will

25 provide an opportunity for the members of a protected class (as defined by the CVRA) to elect

26 candidates of their choice or influence the outcome of the SDUSD School Board elections.

27 45. An actual controversy has arisen and now exists between the parties relating to

28 the legal rights and duties of Plaintiffs and SDUSD and City regarding the manner of voting for

- 9 -COMPLAINT FOR DECLARATORY RELIEf AND INJUNCTIVE RELIEF; PETITION FOR WRIT OF MANDATE

SDUSD School Board elections.

2 46. Plaintiffs have a clear, present and beneficial right to the proper performance by

3 SDUSD and City in their duties and compliance with the laws and legal principles as set forth

4 herein.

5 47. The declaratory and injunctive relief requested herein is proper to delineate and

6 clarify the parties' rights and liabilities and resolve, quiet, or stabilize an uncertain or disputed

7 jural relation and to prevent further violations of the CVRA. Without the grant of declaratory

8 relief and the granting of an injunction, SDUSD will continue to allow and/or promote that City

9 will proceed in a manner not allowed by law and will continue to take action outside of the law

10 and their authority resulting in harm to Plaintiffs, its members, supporters, and the citizemy of

11 the SDUSD and City of San Diego and State of California for whom this litigation is equally

12 brought. In order to vindicate the legislative intent of the CVRA and to enforce their respective

13 provisions, Plaintiffs have no choice but to obtain the relief sought herein.

14 48. Plaintiffs seek a judicial determination of SDUSD' s lack of compliance with the

15 CVRA and a vindication of the rights of all voters within the district. A declaratory judgment

16 should be granted in favor of Plaintiffs as alleged and requested herein.

17 49. Plaintiffs seek an injunction to prohibit the future election of board members of

18 the SDUSD School Board through at-large district voting, and a preliminary and permanent

19 injunction that no SDUSD School Board member, elected as a result of the November 6, 2018,

20 be seated on the SDUSD School Board and may not make any vote, fake any action, or perform

21 any duty of a duly elected SDUSD School Board member until compliance with the CVRA is

22 obtained as alleged herein.

23 VII.

24 FOURTH CAUSE OF ACTION - PETITION FOR WRIT OF MANDATE

25 (As Against Defendant SDUSD)



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51. Plaintiffs do not have any plain, speedy, or adequate remedy in the ordinary

2 course of law. Plaintiffs' only recourse is the relief provided by the CVRA which provides for

3 judicial review.

4 52. If the SDUSD's actions are allowed to stand and continue, Plaintiffs' rights will

s be impaired and will suffer irreparable harm, including racially polarized voting, in elections for

6 the five members of the Board, and in elections incorporating other electoral choices by voters

7 residing within the SDUSD. No money damages or other legal remedy could adequately

8 compensate Plaintiffs for the harm from violation of their rights under the CVRA that SDUSD

9 has caused, allowed to continue and/or endorse, and will continue to cause by continuing at-large

Io elections.

11 53. Plaintiffs request that this Court issue a peremptory writ of mandamus directing

12 SDUSD to take all reasonable and necessary actions to move to a district-based election system

13 (rather than at-large method), and ordering that SDUSD not seat any Board member elected in

14 the November 6, 2018 election, or any subsequent election, unless and until such elections are

15 held in a member that complies with the CVRA.

16 VIII.

11 FIFTH CAUSE OF ACTION -DECLARATORY AND INJUNCTIVE RELIEF


19 (As Against Defendant Registrar of Voters)

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54. Plaintiffs reallege and incorporate by reference all paragraphs above and below as

if set forth fully herein.

55. Defendant Registrar of Voters certifies elections in San Diego County, including

23 elections for the SDUSD School Board.

24 55. The Registrar of Voters shall not certify an election which has been alleged, is

25 known, and/or has been proven to be in violation of the CVRA.

26 56. Based on allegations in this Complaint that are to be proven in this lawsuit, the

27 method of at-large elections for seats on the SDUSD School Board violates the CVRA and thus

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an appropriate court order to the Registrar of Voters may be made to prevent, suspend and cure

2 any such violations.

3 57. Plaintiffs seek preliminary and permanent injunctive relief that the results of the

4 November 6, 2018 election for seats on the SDUSD School Board not be certified by the

5 Registrar of Voters and, henceforth, the Registrar of Voters may only certify voting results in

6 subsequent elections to the SDUSD School Board once a remedial and an alternate system (such

7 as a district-based voting methodology), that is compliant with the CVRA, is put into place.

8 IX.

9 PRAYER FOR RELIEF

10 WHEREFORE, Plaintiffs pray for judgment against defendants SDUSD, City and

11 Registrar of Voters, and each of them, as follows:

12 1. For a declaration of law and judgment in favor of Plaintiffs that City's and

13 SDUSD's current, at-large method of election for the SDUSD School Board violates the

14 California Voting Rights Act of 2001.

15 2. For a preliminary and permanent injunction to prohibit defendant SDUSD from

16 seating board members from the results of the November 6, 2018 election for all board member

17 positions voted upon during said election, and not seat any board members from subsequent

18 elections until an alternative to the at-large system of electing SDUSD School Board members is

19 replaced with a method compliant with the CVRA.

20 3. For a writ of mandate commanding and compelling City and SDUSD to

21 implement district-based elections, as defined by the California Voting Rights Act of 2001, or

22 other alternative relief tailored to remedy City's and SDUSD's violation of the California Voting

23 Rights Act of 2001 before it may seat any new members of the SDUSD School Board.

24 4. For a preliminary and permanent injunction prohibiting that the Registrar of

25 Voters may not certify the election or election results of the November 6, 2018 election for the

26 SDUSD School Board candidates that was known, and/or has been proven, to violate the CVRA,

27 and that the Registrar of Voters may not certify voting election results for SDUSD School Board

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in subsequent elections until an alternate system is put into place that is compliant with the

2 CVRA.

3 5. For a declaration of law and judgment that City Charter § 66, in its current form

4 and content, violates the CVRA and is null and void, to the extent it is not compliant with

5 existing state law under as enacted by the State Legislature under the CVRA.

6 6. That Plaintiffs have a right to preliminary and injunctive relief, and/or a writ of

7 mandate to prevent implementation of City Charter § 66 and compel nullification and court-

s ordered amendment of City Charter § 66 in its current form, including but not limited to

9 mandated implementation of district-based elections (as defined, required, or contemplated by

10 the California Voting Rights Act of 2001), or other alternative relief tailored by this Court to

11 remedy City's and SDUSD's violation of the CVRA.

12 7. For reasonable attorney's fees and costs of suit pursuant to the CVRA, California

13 Elections Code § 14030, California Code of Civil Procedure § 1021.5, and any other relevant

14 statutes.

15 8. For such other and further relief as this Court deems just and proper, or otherwise

16 is allowed and naturally flowing from such claims and requested remedies, as a matter of law or

17 based on equities and necessity for appropriate remedial relief.

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Dated: September 27, 2018

CRAIG A. SHERMAN Attorney for Plaintiffs PARENTS FOR QUALITY EDUCATION, MARGARET SANBORN, and RICARDO CASTILLO


1 X

2 VERIFICATIONS

3 I, Bret Caslavaka, as a duly authorized officer and president of the Plaintiff organization

4 PARENTS FOR QUALITY EDUCATION, hereby verifies this COMPLAINT FOR

5 DECLARATORY RELIEF AND INJUNCTIVE RELIEF; PETITION FOR WRIT OF MANDATE

6 pursuant to Civil Procedure Section 446. The facts herein alleged are true of my own and my

7 organization's knowledge, except as to the matters which are based on information and belief,

8 which I believe to be true. I declare under the penalty of perjury under the laws of California that

9 the above foregoing is true and correct and that this verification was executed on the below stated

10 date in San Diego County, California.

11 Dated: September 27, 2018

12

13

14

By~~ ~slavaka

15 We, Margaret Sanborn and Ricardo Castillo are individuals who verify this COMPLAINT

16 FOR DECLARATORY RELIEF AND INJUNCTIVE RELIEF; PETITION FOR WRIT OF

17 MANDATE pursuant to Civil Procedure Section 446. The facts herein alleged are true of our own

18 knowledge, except as to the matters which are based on information and belief, which we believe to

19 be true. We declare under the penalty of perjury under the laws of California that the above

20 foregoing is true and correct and that this verification was executed on the below stated date in San

21 Diego County, California.

22 Dated: September 27, 2018

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Dated: September 28, 2018

By:---...~~="',F---~==::...._---Ricardo Castillo

COMPLAINT FOR DECLARATORY RELIEF AND INJUNCTIVE RELIEF; PETITION FOR WRIT OF MANDATE

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wrn pm · city is a political subdivision within the state of california and is a charter city....

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