LA Times Lawsuit

1 SUMMARY OF ALLEGATIONS
2 1. Los Angeles Mayor Eric Garcetti spends a significant amount of time traveling
3 outside of California. In one recent 12-month period, he was out-of-state for 112 days (nearly a
4 third of the year), criss-crossing the country and the globe. More recently, he has been visiting
5 political battleground states like Iowa, New Hampshire, South Carolina, Nevada, Florida, and
6 Indiana, as he openly contemplates a presidential campaign. A Los Angeles Police Department
7 protective detail travels with him wherever he goes. Whether Mayor Garcetti’s travel is good or
8 bad for the City of Los Angeles is for the voters to decide. But citizens are entitled to know basic
9 information about how much these trips are costing taxpayers, so that they can make their own
10 informed judgment about the way City resources are spent.
11 2. To that end, The Times requested records pursuant to the CPRA and California
12 Constitution reflecting the amount of money spent for City police and security personnel to travel
13 with Mayor Garcetti, his family members, and/or his staff since 2015. Other public officials have
14 released this kind of information, including President Donald Trump and former EPA
15 Administrator Scott Pruitt, and state and local officials across the country. But notwithstanding
16 the public’s undeniably strong interest in knowing the extent to which City resources are being
17 used to support the Mayor’s travels – particularly where, as here, at least some of the trips
18 arguably involve the Mayor’s political ambitions – the City has refused to disclose these records.
19 Its refusal violates the CPRA and Article 1, § 3 of the California Constitution.
20 THE PARTIES
21 3. Petitioner Los Angeles Times Communications LLC is a limited liability
22 corporation organized under the laws of the State of Delaware, which is authorized to do business
23 and is doing business in the County of Los Angeles. Among other things, at all times relevant to
24 the Petition, The Times has been engaged in the business of gathering and disseminating
25 information to the public, including information about local government agencies, through its
26 publication of the Los Angeles Times, a newspaper of general circulation distributed throughout
27 the State of California, including in Los Angeles County, and the latimes.com website. As such,
28
2 DAVIS WRIGHT TREMAINE LLP

VERIFIED CPRA PETITION 865 S. FIGUEROA ST, SUITE 2400
LOS ANGELES, CALIFORNIA 90017-2566
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Fax: (213) 633-6899
1 The Times is within the class of persons beneficially interested in the City’s performance of its
2 legal duties under the CPRA.
3 4. Respondent City of Los Angeles is a government agency duly organized and
4 operating in Los Angeles County, California. The Los Angeles Police Department (“LAPD”) and
5 the Office of the Mayor are departments of the City, and Mayor Eric Garcetti is a public official
6 of the City. Therefore, the City – including the LAPD, the Mayor’s Office, and Mayor Garcetti –
7 is a local agency within the scope of the CPRA. See Government Code § 6252(a); City of San
8 Jose v. Superior Court, 2 Cal. 5th 608, 620-622 (2017).
9 FACTUAL BACKGROUND
10 5. Extensive public discussion and debate has taken place recently about the use of
11 public funds to pay for the travel of politicians and their families. Relying largely on records
12 obtained through the Freedom of Information Act, 5 U.S.C. § 552 et seq. (“FOIA”), national
13 media outlets and nonprofit watchdog organizations have closely scrutinized the cost of President
14 Donald Trump’s and former President Barack Obama’s frequent travel, as well as the cost of trips
15 taken by their respective family members while under the protection of taxpayer-funded Secret
16 Service details. For example:
17 a. The Department of Homeland Security released records in response to a FOIA
18 request showing that the government spent at least $330,000 in security costs to
19 accompany President Trump’s children on their annual Aspen ski vacation.
20 See Laura Strickler, Analisa Novak & Julianna Goldman, “Trump kids’ ski
21 vacation incurs over $300,000 in security costs,” CBS News (Sept. 29, 2017),
22 available at https://www.cbsnews.com/news/trump-kids-ski-vacation-incurs-
23 over-300000-in-security-costs/;
24 b. The Department of the Air Force and the Secret Service released security
25 expense records in November 2017 after the organization Judicial Watch filed
26 a FOIA lawsuit showing that President Obama’s family travels cost $114
27 million during his eight years in office, and President Trump’s travels during
28 the first year after he was elected cost taxpayers $10 million. The records

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1 included tallies for individual trips: For example, to celebrate his 100th day in
2 office, President Trump flew to a rally in Pennsylvania, costing $156,618. He
3 spent $224,765.80 to visit his golf club in Bedminster, New Jersey. He spent
4 more than $1.1 million traveling to Mar-a-Lago resort in Palm Beach, Florida.
5 See Melina Delkic, “Obama Administration Travel Cost $114 Million,
6 Trump’s So Far Is $10 Million,” Newsweek (Nov. 27, 2017), available at
7 http://www.newsweek.com/obama-administration-travel-costs-114-million-
8 trump-723883; Press Release, “Obama Family Vacations, Campaigning Cost
9 Taxpayers New Total over $114 Million,” Judicial Watch (Nov. 27, 2017),
10 available at https://www.judicialwatch.org/press-room/press-releases/obama-
11 family-vacations-campaigning-cost-taxpayers-new-total-114-million/; and
12 c. In response to a FOIA request, the Secret Service also released to CNN
13 expense records showing that the agency made $63,700 in payments for “hotel
14 costs” to President Trump’s Mar-a-Lago club between February and April
15 2017. See Cristina Alesci & Curt Devine, “Secret Service paid Mar-a-Lago at
16 least $63,000, documents show,” CNN (Oct. 12, 2017), available at
17 http://money.cnn.com/2017/10/12/news/secret-service-mar-a-lago/index.html.
18 6. On July 5, 2018, Scott Pruitt resigned as administrator of the United States
19 Environmental Protection Agency following a controversy over his travel and security costs.
20 Media and watchdog groups used public records obtained through FOIA to document Pruitt’s use
21 of taxpayer funds for these purposes. For example:
22 a. EPA records released under FOIA showed that in the first few months of
23 Pruitt’s tenure at the agency, travel costs for his security detail totaled
24 $215,168.69, an amount that was substantially higher than that of his
25 predecessors. See Kevin Bogardus, “Big spike in security spending for Pruitt,”
26 E&E News (July 5, 2017), available at
27 https://www.eenews.net/stories/1060056958;
28

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1 b. EPA travel documents showed that Pruitt’s 24-hour security detail incurred
2 $30,553.80 in expenses for a trip to Italy; the total cost to taxpayers of this trip
3 was more than $80,000. See Miranda Green & Timothy Cama, “Cost of
4 Pruitt’s Italy trip rises above $84,000,” The Hill (Mar. 20, 2018), available at
5 http://thehill.com/policy/energy-environment/379295-pruitts-security-detail-
6 cost-30000-for-italy-trip; and
7 c. Pursuant to FOIA, the EPA released a single postcard about climate change
8 that was deemed “potentially threatening,” which was used to justify the
9 former administrator’s around-the-clock security detail, at a cost of more than
10 $3 million in taxpayer funds. See Megan Cerullo, “This postcard about climate
11 change was used to justify Scott Pruitt’s around-the-clock security,” Los
12 Angeles Times (June 1, 2018), available at http://www.latimes.com/ny-news-
13 epa-postcard-threat-20180601-story.html.
14 7. Mayors in large cities throughout the country similarly have been the subjects of
15 public scrutiny for their travel expenses, based on information documented in public records. For
16 example:
17 a. Public records showed that Chicago Mayor Rahm Emanuel took at least 56
18 trips out of the city in his first two-and-a-half years in office at a cost of more
19 than $350,000. Mayor Emanuel subsequently reimbursed the city for more
20 than $14,000 in expenses, and instituted a new policy to ensure that taxpayer
21 funds were not used for “campaign-related business.” See Bill Ruthhart,
22 “Mayor reimburses city $14,000 for travel costs,” Chicago Tribune (Sept. 3,
23 2014), http://www.chicagotribune.com/news/local/politics/ct-rahm-emanuel-
24 travel-expenses-met-20140903-story.html#;
25 b. Baltimore city records showed that police protection for Mayor Stephanie
26 Rawlings-Blake’s out-of-state trips in 2013 cost taxpayers more than $25,000.
27 See Luke Broadwater, “Mayor’s political rise takes her out of state,” Baltimore
28

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1 Sun (Jan. 19, 2014), http://www.baltimoresun.com/news/maryland/baltimore-
2 city/bs-md-ci-srb-travel-20140109-story.html;
3 c. Public records showed that a 2015 trip to Israel by then-Seattle Mayor Ed
4 Murray and other officials cost taxpayers $36,000, including $20,000 to pay for
5 two police officers to guard the mayor. See Daniel Beekman, “SPD chief
6 beefed up Mayor Murray’s security for trips abroad,” Seattle Times (Aug. 26,
7 2015), https://www.seattletimes.com/seattle-news/politics/spd-chief-beefed-up-
8 mayor-murrays-security-for-trips/.
9 8. On a local level, The Times reported in 2009 that city expense reports showed that
10 the City had incurred $10,650 in costs for an LAPD security detail to accompany then-Mayor
11 Antonio Villaraigosa on a trip to Iceland and London. See Phil Willon, “Villaraigosa starts
12 vacation in South Africa a day after inauguration,” Los Angeles Times (July 3, 2009),
13 http://articles.latimes.com/2009/jul/03/local/me-villaraigosa3. The amount in The Times’ news
14 report was repeated in a piece about Mayor Villaraigosa’s travels while in office that was posted
15 on the website of the union representing LAPD officers. See Los Angeles Police Protective
16 League, “Villaraigosa Starts Vacation in South Africa a Day After Inauguration” (July 3, 2009),
17 https://www.lapd.com/article/villaraigosa-starts-vacation-south-africa-day-after-inauguration.
18 True and correct copies of these publications are attached as Exhibit A.
19 9. In 2017, The Times reported that Mayor Villaraigosa’s successor, current Los
20 Angeles Mayor Eric Garcetti, spent 112 days – or nearly a third of his time in the 12 months
21 between September of 2016 and 2017 – traveling outside of California. See Dakota Smith,
22 “Garcetti is increasingly traveling outside California, raising eyebrows back in L.A.,” Los
23 Angeles Times (Sept. 29, 2017), http://www.latimes.com/local/lanow/la-me-ln-garcetti-out-of-
24 town-20170912-story.html. While in office, Mayor Garcetti has traveled to Mexico, Peru,
25 Germany, France, Switzerland, China, South Korea, and Japan, among other international
26 destinations; his domestic travel has included Atlanta, Phoenix, Boston, Chicago, Las Vegas,
27 Miami, the Berkshires, the Hamptons, Washington DC, New Hampshire, and Wisconsin. See id.;
28 Soumya Karlamangla, “L.A. Mayor Eric Garcetti set to visit Asia on a trade mission,” Los

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1 Angeles Times (Nov. 13, 2014), http://www.latimes.com/local/cityhall/la-me-1114-asia-trip-
2 20141114-story.html. True and correct copies of these articles are attached as Exhibit B.
3 10. Mayor Garcetti has stated that he is “thinking about” running for president of the
4 United States, and he recently traveled to early primary states like New Hampshire, Iowa, and
5 South Carolina, as well as presidential-election swing states like Florida and Nevada. See Seema
6 Mehta & Jazmine Ulloa, “L.A. Mayor Eric Garcetti admits considering a 2020 bid: ‘I am thinking
7 about this,’” Los Angeles Times (Dec. 22, 2017), http://www.latimes.com/politics/essential/la-
8 pol-ca-essential-politics-updates-los-angeles-mayor-eric-garcetti-says-he-1513983870-
9 htmlstory.html; Cindy Chang, “Eric Garcetti, still weighing a presidential run, delivers
10 commencement address in New Hampshire,” Los Angeles Times (May 13, 2018),
11 http://www.latimes.com/local/lanow/la-me-ln-garcetti-new-hampshire-20180513-story.html. True
12 and correct copies of these articles are attached as Exhibit C.
13 11. Mayor Garcetti’s extensive travel has been the subject of reports in the national
14 media, in the context of reporting about his presidential ambitions. For example:
15 a. The New York Times reported in November 2017 that “over the last few
16 months, Mr. Garcetti’s sights have clearly been set beyond the Art Deco tower
17 that is Los Angeles City Hall. He has traveled to Florida, Louisiana, and New
18 Hampshire, and was in Las Vegas on Saturday, speaking to a convention of
19 carpenters [and he] went to Indiana, to announce the creation of a group of
20 mayors, business and labor leaders to promote infrastructure investments…”
21 Adam Nagourney, “From City Hall to the White House? Eric Garcetti May Try
22 to Defy the Odds,” New York Times (Nov. 20, 2017),
23 https://www.nytimes.com/2017/11/20/us/los-angeles-mayor-eric-garcetti-
24 president.html;
25 b. Politico reported in March 2018 on Mayor Garcetti’s “two-day swing through
26 Iowa,” while also noting his trips to New Hampshire, Nevada, and South
27 Carolina. See Edward-Isaac Dovere, “Garcetti edges toward presidential run
28

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1 with trip to Iowa,” Politico (Mar. 21, 2018),
2 https://www.politico.com/story/2018/03/21/eric-garcetti-iowa-477573; and
3 c. A Newsweek story from April 2018 reported on Mayor Garcetti’s Iowa visit,
4 and also discussed his travel to Wisconsin, New Hampshire, and Indiana. See
5 Tom Porter, “Who is Eric Garcetti? L.A. Mayor visits Iowa and may be
6 considering run for president in 2010,” Newsweek (Apr. 16, 2018),
7 http://www.newsweek.com/who-eric-garcetti-la-mayor-visits-iowa-and-may-
8 be-considering-run-president-887058.
9 12. On August 25, 2017, Times reporter Dakota Smith submitted a CPRA request by
10 email to the LAPD seeking “the travel costs, including all hotels, airline tickets, and more of
11 providing security for Mayor Garcetti and his family … spent by the LAPD (actually spent, not
12 budgeted)” for 2015, 2016, and 2017. The Times also requested “the total cost, including
13 salaries, overtime, travel, and more, of providing security for Mayor Garcetti and his family …
14 spent by the LAPD (actually spent, not budgeted)” for the same time period. That same day,
15 LAPD Public Information Officer Josh Rubenstein responded that he would forward the request
16 to the LAPD’s discovery unit. A true and correct copy of this correspondence is attached as
17 Exhibit D.
18 13. On September 21, 2017, LAPD Captain Brian Whitten told Ms. Smith by email
19 that the Department “will be providing the total costs for the Mayor’s security by year (2015,
20 2016, 2017 YTD).” However, four days later, the LAPD changed its position; on September 25,
21 2017, Captain Whitten sent a letter on behalf of the LAPD denying the request, stating that
22 “[d]isclosure of the requested records to the public, including those who may attempt to
23 circumvent the law, would endanger the operation of the security detail, the safety of the public,
24 Department employees, the Mayor, and the Mayor’s family. Therefore, I am denying your
25 request.” The letter cited Government Code §§ 6254(b), (c), (f), and (k) and 6255, and Evidence
26 Code § 1040. A true and correct copy of this correspondence is attached as Exhibit E.
27 14. On April 25, 2018, Ms. Smith submitted a second CPRA request on behalf of The
28 Times by email to Mr. Rubenstein at the LAPD, and submitted the same request to Alex Comisar,

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1 press secretary for Mayor Garcetti. This request asked for records showing “the overall costs
2 incurred by the mayor’s security detail, as well as the cost of the detail accompanying his family
3 members or staff, if they were present, during out of state travels for the time frame of:
4 04/25/2016 to 04/25/18.” The request also asked for a breakdown of (1) “The number of hours
5 each officer/guard worker worked on the trip”; (2) “The costs of all airline trips, hotels, cars,
6 meals and any other expenses incurred by the detail during the out of state travel”; and (3) “The
7 number of security officers that accompanied the mayor and or his family/staff on the trip.”
8 Finally, Ms. Smith asked for the cost of any reimbursements made by the City to any local
9 security detail(s) during those trips. Mr. Rubenstein responded by email that same day, stating
10 that “[u]nfortunately we are not able to give out this information, as it could potentially
11 undermine the Mayor’s safety and security.” A true and correct copy of this correspondence
12 (with personal information redacted) is attached as Exhibit F.
13 15. On April 25, 2018, Ms. Smith of The Times elaborated on the CPRA request in a
14 follow-up email to Mr. Comisar, in which she asked, “Did the mayor use city-funded security on
15 his recent trip to Iowa? If so, please detail the cost, including a breakdown of hotels, car rentals,
16 meals, airplane tickets and other costs incurred through the security/LAPD detail. Please also
17 provide the number of hours that the detail worked and the number of officers that accompanied
18 both the mayor and his family, if they came along. If external security was used for the mayor’s
19 trip and the city was charged, please provide those expenses.” Mr. Comisar did not respond to
20 this email. On April 27, 2018, Ms. Smith sent an email to Mr. Comisar and asked, “Can you give
21 me a timeline of when you expect an answer on the mayor’s security and whether he used city-
22 funded security on his recent Iowa trip?” In an email response that same day, Mr. Comisar stated,
23 “For his security, the Mayor’s protective detail travels with him wherever he goes.” Mr. Comisar
24 did not otherwise respond to the CPRA request. A true and correct copy of this correspondence
25 (with personal information redacted) is attached as Exhibit G.
26 16. On June 4, 2018, The Times’ Vice President–Legal, Jeff Glasser, sent a letter to
27 Mayor Garcetti and then-LAPD Chief Charlie Beck concerning the City’s refusal to provide
28 information requested by The Times under the CPRA. Mr. Glasser asked the City “to reconsider

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1 its refusal to provide The Times with records reflecting the amounts of money spent for police
2 and security personnel to travel with Mayor Garcetti, family members and/or staff on his travels
3 around the world since 2015.” Mr. Glasser described The Times’ CPRA requests of August 25,
4 2017, and April 25, 2018, and provided a detailed discussion of legal authorities supporting The
5 Times’ position that the records were subject to disclosure. Among other points, Mr. Glasser
6 explained that the exemptions previously cited by the City (Government Code §§ 6254(c) and
7 6255 and Evidence Code § 1040) were inapplicable because they all employ the same balancing
8 test, under which records must be disclosed unless the agency’s interest in secrecy clearly
9 outweighs the public interest in disclosure; numerous California Supreme Court decisions have
10 established that vague and speculative safety concerns cannot overcome the extremely strong
11 public interest in transparency regarding the expenditure of public funds and use of public
12 resources. E.g., American Civil Liberties Union Foundation v. Superior Court, 3 Cal. 5th 1032,
13 1046 (2017); Long Beach Police Officers Assn. v. City of Long Beach, 59 Cal. 4th 59, 74-75
14 (2014); International Federation of Professional & Technical Engineers, Local 21, AFL-CIO v.
15 Superior Court, 42 Cal. 4th 319, 333, 337 (2007); CBS, Inc. v. Block, 42 Cal. 3d 646, 652-53
16 (1986). Mr. Glasser also explained why Government Code §§ 6254(b) and (f) were inapplicable
17 to The Times’ requests. A true and correct copy of this letter is attached as Exhibit H.
18 17. On June 11, 2018, Captain Whitten sent a letter on behalf of the LAPD to The
19 Times stating that the “Department has reconsidered its response to the request, and is in the
20 process of identifying responsive records thereto.” The letter further stated that “[t]o the extent
21 responsive and not otherwise exempt public records depicting costs are identified, they will be
22 made available,” however, “records which either expressly identify the specific number of LAPD
23 or other security personnel assigned to the Mayor’s Security Detail or information concerning the
24 specific work shifts of said members, or from which that information could be extrapolated will
25 continue to be withheld.” The LAPD’s letter cited Government Code §§ 6254(k) and 6255, and
26 Evidence Code § 6255(a). The letter did not mention Government Code §§ 6254(b), (c), or (f).
27 The letter stated that responsive, nonexempt records would be available by Friday, June 22, 2018.
28 A true and correct copy of this letter is attached as Exhibit I.

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1 18. But once again, the LAPD abruptly changed its position. On June 22, 2018,
2 instead of providing the promised records, Captain Whitten of the LAPD sent a letter stating that
3 “after careful re-consideration” the LAPD was denying both CPRA requests in their entirety.
4 The LAPD’s June 22 letter stated that “[i]dentification of records or information which expressly
5 identifies the specific number of LAPD or other security personnel assigned to the Mayor’s
6 Security Detail, or information concerning the specific work shifts of said members, exposes the
7 Mayor and his family to threats arising from vulnerabilities in the provision of security.
8 Similarly, disclosure of records/information from which that information could be extrapolated
9 creates the same danger.” The LAPD cited Government Code §§ 6254(k) and 6255(a) and
10 Evidence Code §1040 in denying the requests. A true and correct copy of this letter is attached as
11 Exhibit J.
12 19. Since June 22, 2018, The Times has received no further communication from the
13 City. The City has not produced any records in response to The Times’ CPRA requests of August
14 25, 2017, and April 25, 2018. The City has denied The Times’ requests in their entirety based on
15 the vague and speculative assertion that disclosure “could potentially undermine the Mayor’s
16 safety and security,” but it has not identified any specific threat, or explained how the requested
17 information about the cost of taxpayer-funded security for the Mayor’s travels to-date would pose
18 any actual danger. Nor has the City provided any explanation for how its purported interest in
19 secrecy clearly outweighs the extremely strong public interest in these records that reflect how
20 City funds have been spent on travel – including political trips – by the City’s top-ranking elected
21 official.
22 CAUSE OF ACTION
23 20. The Times hereby realleges and incorporates by reference Paragraphs 1 through 19
24 of this Petition.
25 21. Pursuant to Government Code § 6258, any persons, such as The Times, may
26 “institute proceedings for injunctive or declarative relief or writ of mandate in any court of
27 competent jurisdiction to enforce his or her right to inspect or to receive a copy of any public
28 record or class of public records under this chapter.”

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1 22. The records requested by The Times in its CPRA requests of August 25, 2017
2 (described in Paragraph 12 and Exhibit D) and April 25, 2018 (described in Paragraphs 14 and 15
3 and Exhibits F and G), are public records that must be disclosed under the CPRA and Article I, §
4 3 of the California Constitution. They are not subject to any exemption.
5 23. The City’s improper withholding of these records violates Gov’t Code § 6253(b),
6 which provides, in pertinent part, that “[e]xcept with respect to public records exempt from
7 disclosure by express provisions of law, each state or local agency, upon a request for a copy of
8 records that reasonably describes an identifiable record or records, shall make the records
9 promptly available to any person[.]” The City also has violated Gov’t Code § 6253(a), which
10 provides, in pertinent part, that “[a]ny reasonably segregable portion of a record shall be available
11 for inspection by any person requesting the record after deletion of the portions that are exempted
12 by law.”
13 24. The Times notified the City of its CPRA violations in its correspondence of June 4,
14 2018. See Ex. H. The City’s continued refusal to disclose these non-exempt public records gives
15 The Times reason to believe that the City will continue to refuse to permit members of the public,
16 including The Times, to inspect or obtain copies of the requested public records in violation of the
17 CPRA.
18 25. The Times alleges in accordance with Government Code § 6259(a) that the
19 information it seeks from the City is maintained in Los Angeles County.
20 26. Government Code §§ 6259(a), (b) authorize the Court to compel the City to release
21 the requested records.
22 THEREFORE, The Times requests that:
23 1. This Court issue a peremptory writ of mandate immediately directing the City to
24 disclose to The Times all non-exempt public records requested by The Times in its CPRA
25 requests of August 25, 2017 (described in Paragraph 12 and Exhibit D) and April 25, 2018
26 (described in Paragraphs 14 and 15 and Exhibits F and G), including, without limitation, all
27 records reflecting the amount of money spent by the City for police and other security personnel
28 to travel with Mayor Garcetti, his family members, and/or his staff members on his out-of-state

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1 trips since 2015, or any reasonably segregable portion of the records that the Court determines
2 should have been disclosed; or, in the alternative, this Court issue an order to show cause why
3 these public records should not be disclosed;
4 2. This Court enter a declaratory judgment that the City violated the CPRA and Article 1,
5 § 3 of the California Constitution by unlawfully withholding the public records requested by The
6 Times in its CPRA requests of August 25, 2017 (described in Paragraph 12 and Exhibit D) and
7 April 25, 2018 (described in Paragraphs 14 and 15 and Exhibits F and G), including, without
8 limitation, all records reflecting the amount of money spent by the City for police and other
9 security personnel to travel with Mayor Garcetti, his family members, and/or his staff members on
10 his out-of-state trips since 2015, or any reasonably segregable portion of the records that the Court
11 determines should have been disclosed.
12 3. The Court set “times for responsive pleadings and for hearings in these proceedings …
13 with the object of securing a decision as to these matters at the earliest possible time,” as provided
14 in Government Code § 6258.
15 4. The Court enter an order awarding The Times its reasonable attorneys’ fees and costs
16 incurred in bringing this action, pursuant to Government Code § 6259 or as authorized by any
17 other law.
18 5. The Court award such further relief as is just and proper.
19 DATED: September 6, 2018 DAVIS WRIGHT TREMAINE LLP
KELLI L. SAGER
20 DAN LAIDMAN
21 LOS ANGELES TIMES COMMUNICATIONS LLC
JEFF GLASSER
22
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By:
24 Kelli L. Sager
25 Attorneys for Petitioner
LOS ANGELES TIMES COMMUNICATIONS LLC
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1 VERIFICATION
2 I, Shelby Grad, declare:
3 1. I am an Assistant Managing Editor for the Los Angeles Times, which is published
4 by Los Angeles Times Communications LLC (“The Times”), the Petitioner in this action, and I
5 am authorized to make this Verification on The Times’ behalf.
6 2. I have read the VERIFIED PETITION FOR DECLARATORY RELIEF AND
7 WRIT OF MANDATE DIRECTED TO THE CITY OF LOS ANGELES ORDERING
8 COMPLIANCE WITH THE CALIFORNIA PUBLIC RECORDS ACT. The facts stated in the
9 Petition are either true and correct of my own personal knowledge, or I am informed and believe
10 that such facts are true and correct, and on that basis I allege them to be true and correct.
11 I declare under penalty of perjury that the foregoing is true and correct and that this
12 verification was executed this 12th day of July 2018, at Los Angeles, California.
13
14 ___________________________
Shelby Grad
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LA Times Lawsuit

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1 SUMMARY OF ALLEGATIONS

2 DAVIS WRIGHT TREMAINE LLP

3 DAVIS WRIGHT TREMAINE LLP

4 DAVIS WRIGHT TREMAINE LLP

5 DAVIS WRIGHT TREMAINE LLP

6 DAVIS WRIGHT TREMAINE LLP

7 DAVIS WRIGHT TREMAINE LLP

8 DAVIS WRIGHT TREMAINE LLP

9 DAVIS WRIGHT TREMAINE LLP

10 DAVIS WRIGHT TREMAINE LLP

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