COUNCILMEMBER MIKE BONIN, · 2016. 2. 25. · COUNCILMEMBER MIKE BONIN, COUNCILMEMBER MITCHELL ENG- LANDER, COUNCILMEMBER MITCH O'FARRELL, COUNCILMEMBER JOSE, HUIZAR COUNCILMEMBER

COUNCILMEMBER MIKE BONIN, COUNCILMEMBER MITCHELL ENG- LANDER, COUNCILMEMBER MITCH O'FARRELL, COUNCILMEMBER JOSE, HUIZAR COUNCILMEMBER JOE BUSCAINO, DOES THROUGH 50, INCLU- SIVE,

) Respondents-Defendants. ) )

GENERAL ALLEGATIONS

1. For all times herein relevant, Petitioner-Plaintiff SaveValleyVillage

SVV (also known as The Neighbors & Community of Valley Village) was and

is an unincorporated association ofcitizens and residents ofLos Angeles County

who are concerned about the quality of life in the City of Los Angeles and in

particular with the quality of life in the area ofthe City known as Valley Village.

They bring this action due to the on-going Unconstitutional, Unlawful, and

Unjustifiable Voting Practices [hereinafter UVP] for injunctive relief and

attorney fees under Code of Civil Procedure, §§ 525, 526(a), 1085-1087„ 18

U.S.C. § 242, 42 U.S.C., § 1983, United States Constitution Article IV, 14th

Amendment, and Code of Civil Procedure, § 1021.5. State courts have

concurrent jurisdiction with federal courts for 42 USC § 1983 claims.

2. SVV is composed of various residents, citizens and tax payers ofthe

City of Los Angeles State of California and as such SVV and its members have

an interest in the laws of their City being enforced including that the City

Council follow the laws when conducting its business. Respondent-Defendant

City of Los Angeles acting through Respondent-Defendant City Council of the

City of Los Angeles has a record extending over many years not to follow the

Brown Act's requirement to have public deliberation and it has a record starting

Citizens Petition re Unlawful Voting Practices Page 2 of 21

in 2006 of using a voting agreement to conduct business which violates not only

the Brown Act, but also Penal Code, § 86, the California and the United States

Constitutions and public policy. SVV has a real controversy due to

Respondents City's years of adhering to these voting practices despite SVV's

attempts to have The City, the City Council, and the individual City Council-

members cease and desist from the UVP as more fully explained below.

3. For all times herein relevant, Respondent City of Los Angeles was

and is a charter city within the State of California with City Hall located at 200

North Spring Street, Los Angeles, California 90012 [hereinafter The City].

4. For all times herein relevant, Respondent City Council of City of

Los Angeles was and is the legislative body, the governing board and the

highest administrative body of The City with its City Hall located at 200 North

Spring Street, Los Angeles, California 90012 [hereinafter the City Council].

5. Each and every councilmember who is named herein as Respondent

is sued herein in his/her representative capacity only as the duly elected official

for his/her council district and none is sued herein in his/her personal capacity.

Each councilmember is a proper Respondent in this Citizen Complaint with

respect to each's participation UVP. The City, The City Council and the

Respondent Councilmembers are sometimes collectively referred to as

Respondents City.

6. SVV is unaware of the true names and identities of those

Respondents sued under the fictitious names DOES 1 through 50, inclusive.

7. Each Respondent was and is the agent, servant and employee of

each remaining Respondent was and is acting within the scope of that agency in


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doing all the acts wherein alleged and in failing to perform all the omissions

herein alleged.

8. Jurisdiction ofthe Petition falls within the California Superior Court

for the County of Los Angeles under Code of Civil Procedure, §§ 525, 526,

1085-187 and Public Resources Code, §§ 21000, et seq., The Brown Act

(Government Code, §§ 54050 et seq.), the United States Constitution, 42 U.S.C.

§ 1983, 18 U.S.C. § 242, and venue is proper in central district (Code of Civil

Procedure, § 394).

9. SVV has no plain, speedy, adequate remedy in the ordinary course of law, since its members and other members of the public will suffer irreparable harm as a result of Respondents City engaging in UVP rather than following the law when approving Council Projects [The term "Council Project" refers to construction projects such as private condos and apartments which are located within one council district and the councilmember for that district has placed on the city council's agenda.] Respondents City have had and continue to have the capacity and ability to approve Council Projects within the limits of and in a manner consistent with those laws, but Respondents City have failed and refuse to do so and have acted

inconsistently with those laws.

10. SVV has a beneficial right and interest in The City's following the

substantive and procedural law.

11. Unless Respondents and Defendants, and each ofthem, are enjoined

from engaging in the UVP, SVV and other members of the community will

suffer irreparable harm from which there is no remedy at law.


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First Cause of Action Petition for Writ of Mandate

Code of Civil Procedure, § 1085, 1086, 525 et seq., And Injunctive Relief as to Voting Practices

for Violations of City Council Rules, The Brown Act, Penal Code 86, Against The City Council and the Fifteen (15) Members

of the Los Angeles City Council

12. SVV hereby realleges and incorporates by reference into this cause

of action, paragraphs 1 through 11, inclusive, of this Petition.

13. Each and every councilmember was and is the agent, servant and

employee of each remaining councilmember and was and is acting within the

scope of that agency in doing all the acts wherein alleged and in failing to

perform all the omissions herein alleged.

14. As an association of citizens and residents, SVV brings this cause

of action to enjoin and prohibit The City Council's use of the UVP including but

not limited to violations of The Brown Act (Government Code, § 54950 et seq.,)

Penal Code, § 86 and City Council Rule 48a whose provisions are unlawful as

written and as implemented. SVV has standing in that it is composed of citizens

of the State of California and residents of the City of Los Angeles who have

Citizen Standing to prevent illegal actions of a governmental entity when the

actions injure a citizen's interest in the laws being observed, and that this

interest forms the basis of an action by way of Writ of Mandate seeking to

correct and enjoin the wrongful behavior. SVV seeks to enforce a public right

and to compel the public duties that each councilmember of the Los Angeles

City Council deliberate in public (except when Brown Act authorized closed

sessions) and that each councilmember exercise his/her own vote independent

of any type of vote trading or voting agreement, which is unlawful per Penal


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Code, § 86,whether or not said agreement is express, implied or by custom and

practice. SVV and its members and all other citizens ofthe City of Los Angeles

have a strong public interest that the City Council's not behave in an

unconstitutional, unlawful or unjustifiable manner. All City Councilmembers

have the public duty to follow the law and SVV may apply for a writ of mandate

to compel the City Councilmembers to follow the law when voting or in the

alternative that the City Councilmembers refrain from violating the law when

voting on an council item.

15. While the City Council's UVP apply to more measures than

construction projects, this cause of action addresses the situation where a

councilmember seeks approval of a construction project in his/her council

district as distinguished from a measure which has construction throughout the

entire city, such as Mobility Plan 2035, the Transportation Element of the

General Plan. The term "Council Project" refers to construction projects such

as private condos and apartments which are located within one council district

and the councilmember for that district has placed on the city council's agenda.

16. The City Council's voting practices are unconstitutional, unlawful

and unjustified for the following reasons.

(1) City Council Rule 48a states:

a. When the Presiding Officer directs the roll call, it shall be taken by means of the Council's computerized record keeping system, except where said officer directs that it be taken orally. If an oral roll call is taken, it shall be taken in alphabetical order, beginning at the left of the President's chair. When voting with the Council's computerized record keeping system, each Council-member shall activate his or her own assigned voting circuit.


Upon direction of the Presiding Officer, the Clerk shall tabulate the vote in such a manner that the mechanical tabulation of results occurs simultaneously with the visual display of those results.

Every member present when a question is put shall vote for or against the same.

Whether the roll call has been mechanically tabulated or oral, it shall be supplemented by the Clerk by counting one "aye" vote for each member present who did not vote. The Clerk shall announce the vote.

The Presiding Officer shall then announce the disposition of the item.

(2) Under the UVP and under City Council Rule 48a, one vote for a

Council Project results in unanimous approval even when no other

councilmember votes for the item. In fact, as Council Rule 48a is written and

is implemented it is possible for Council Project for which no council-member

votes will receive unanimous approval. As a result, each council-member

knows that any and all violations of rules, ordinances, specific plans, statutes

and procedure can be approved by placing the Council Project on the City

Council agenda. As a result, the City Council of Los Angeles unanimously

approves Council Projects over 99% of the time.

(3) The actual procedure in City Council departs significantly from the

procedure set forth in Council Rule 48a in that the council clerk does not first

tabulate the actual votes and then supplement the actual votes with the non-

votes. Instead, all Yes Votes and all Non-Votes are automatically tabulated and

reported together so that no member of the public knows who voted for a Project

or whether no councilmember voted for a project. The members of the public


have a right to know how their elected representatives actually voted. Keeping

the identity of who voted and who did not vote secret is contrary to The Brown

Act and public policy. The voting public has a right to know whether its elected

representatives are performing their legislative function or whether they are not

voting on issues which affect their constituents.

(4) Another unlawful feature of the City Council's UVP is that items

which require the City Council's independent review and certification, such as

CEQA projects including those for whom a Mitigated Negative Declaration has

issued, may be placed on the "consent calendar," which is also known as the

Special Calendar and sometimes referred to a calendar where public comment

has already been held. All matters on the "consent calendar" are approved en

masse without the City Council's providing any independent review of any item.

The existence of prior public comment does not vitiate the City Council's duty

to hold its own public deliberations when its review and certification are

required. The City Council conflates prior public comment under The Brown

Act (Govt Code, § 54954.3) with the CEQA requirement that it independently

review administrative CEQA determinations and based upon its independent

review, the City Council provide its CEQA certification. CEQA Guidelines, §§

15025, 15085, 15090, 15091, 15093, 15195

(5) When an CEQA item is placed on the "consent calendar," the

consideration tends to follow this format. "Okay. Now let's prepare to vote, Mr.

Clerk, on the remaining items, Let's open the roll. Close the roll, and let's

tabulate the vote."

(6) The City Council's full deliberations on Council Projects are not

conducted in public. Failure to hold public deliberations violates the Brown

Act. Due to the UV P which does not allow councilmembers to vote NO on any


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Council Project, any public discussion of any Council Project is a sham as the

decision to approve the Council Project was made before the City Council

meeting in accordance with the UVP.

(7) The UVP disenfranchise the voters and exclude their participation

in the process of governing by their elected representatives's practice to remain-

ing silent about The City's actions which harm them. For example, the members

of the public in one district lose their right to vote on Council Projects in other

districts when those projects may adversely impact them. The adverse traffic

impacts of a Council Project do not stop at the council's borders. The financial

costs to the City of one Council Project can significantly impact the finances of

the entire City and harm the infrastructure upon which everyone depends. The

destruction of rent control housing in one district can reduce the supply of

affordable housing available for the entire City. Under the UVP, 93% (14/15

th) of the City is disenfranchised for each Council Project even when the Project

serious impacts their lives.

(8) The UVP allow City Councilmembers to systematically violate

various zoning codes, various specific plans, CEQA and other statutes, rules,

regulations, ordinances. The UVP not only permits but also encourages

wrongdoing as each City Councilmember knows that he/she has the power to

compel the City Council to ignore, overlook, sanction, and disregard any and all

violations and approve whatever Council Project the councilmember wants for

his/her district.

(9) As set forth in the Second Cause of Action, the UVP violate the

United States Constitution and 42 U.S.C. § 1983, 18 U.S.C. § 242. The UVP

operate so as to disenfranchise the voters for a variety of reasons.


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(10) The UVP are unjustifiable as a matter of public policy. When

people vote for representatives to protect and promote the voters' interests, they

do not expect the representatives to participate in any voting practice whereby

the elected representative abdicates his/her responsibility to consider and vote

upon council items which are extremely important to the lives and quality of life

of Angelenos. When running for office, no councilmember announced that

he/she intended not to consider 14/15th of all construction projects but instead

to defer to whatever one other councilmember wanted. The councilmembers

receive a salary in excess of One Hundred Eighty-Seven Thousand Dollars

[$187,000.00) per year plus additional health and welfare benefits including

pensions. In addition, each councilmember has a large staff to assist him/her in

his duties. It is contrary to the public's expectations and contrary to sound

public policy for such highly paid public servants to remain silent on 14/15th of

council projects which come before them. It is also contrary to public policy for

the City Council to tabulate its council votes so that the public cannot see who

did not even bother to vote as is the situation when all council votes and non-

votes are simultaneously and automatically tallied and reported. It is also

contrary to public policy for the City Council to certify that it has considered

CEQA projects when in fact the City Council did not independently review and

approve the CEQA Project.

17. The UVP have harmed, continue to harm and will continue to harm

the City of Los Angeles and its people in additional ways:

(1) SVV is informed, believes and thereupon alleges that the UVP,

which have been employed thousands of times since 2006, have resulted in great

harm to the City of Los Angeles and its citizens. The case of Citizens Coalition

Los Angeles v City of Los Angeles, Los Angeles Superior Court # BS140930

resulted from the same UVP. In that case City Councilmember Eric Garcetti


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used the UVP to have the City Council unanimously approve the Target Store

at the corner of Sunset Boulevard and Western Avenue in Hollywood despite

the fact that it violated the Specific Plan, SNAP. As the actual and proximate

result of the UVP, The Target Project was approved, resulting in protracted

litigation. The construction of the Target Store has been halted by the courts

due to the City's disregard for the law. SVV is informed believes and thereupon

alleges that but for the UVP, no council-member would insist that the developer

construct a Council Project which materially violated the law and no council-

member would encourage developers to undertake substantial construction

during litigation. SVV is informed, believes and thereupon alleges that the near

99% certainty that all councilmembers have that any Council Project which they

desire for their district, no matter how much it violates the law, will be

unanimously approved, is the actual and proximate reason CEQA, Specific

Plans, zoning regulations and rules are violated. In 2006, Director of Planning

Gail Goldberg warned that the City Council's allowing developers to set the

zoning parameters would result in disaster. The procedure by which developers

are allowed to set the zoning for their projects is the UVP.

(2) SVV also alleges that the UVP were the actual and proximate cause

of the numerous violations in the Hollywood Community Plan Update (see

Hollywoodians Encouraging Logical Planning v City of Los Angeles, Los

Angeles Superior Court # BS 138370), which Councilmember Eric Garcetti had

unanimously passed on June 19, 2012. Litigation ensued, and on January 15,

2014, The Honorable Allan Goodman, Los Angeles Superior Court Judge,

rejected the Hollywood Community Plan Update, noting that The City knew in

2011 that its data was fatally flawed and was wishful thinking, but the City

chose not to rectify the EIR. The Hollywood Community Plan update was

passed unanimously due to the existence of the UVP. The harm to City of Los

Angeles in general and to Hollywood has been devastating. Over two (2) years


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have passed since Judge Goodman rejected the Update and reinstated the 1988

Hollywood Community Plan, whose Commerce Section expired in 2010, and

no new EIR has issued from the City. Meanwhile the City Councilmembers are

using the UVP to approve multi-million dollar project after multi-million dollar

project.

(3) On June 26, 2012, City Watch LA ran an article, LA City Hall: A

Temple to Crimogenics, which revealed the irreparably harmful impact the

UVP were having upon the City of Los Angeles. The warning about the harm

which the UVP were having upon Hollywood in particular was clear:

The crimogenic mechanism of LA City Council is this: There's a corrupt deal amongst the councilmembers not to vote against what another council member wants in his/her district. When a councilmember sees the Hollywood Community Plan is based on frauds, he keeps his mouth shut and votes for it. LA City Hall: A Temple to Crimogenics

(4) The irreparable harm, which flows from the UVP, was identified by

community leaders in December 2013 in The 2020 Commission's report, A Time

for Truth. The Time for Truth's opening described the state of the City of Los

Angeles after a decade of the UVP:

Los Angeles is barely treading water while the rest of the world is moving forward. We risk falling further behind in adapting to the realities of the 21st century and becoming a City in decline. For too many years we have failed to cultivate and build on our human and economic strengths, while evading the hard choices concerning local government and municipal finance presented by this new century. Like the hapless Mr. Micawber in Dickens' "David Copperfield," our wishful response to continued economic decline and impending fiscal crisis has become a habitual: "Something, my dear Copperfield, will turn up."


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The City where the future once came to happen has been living in the past and leaving tomorrow to sort itself out. As a consequence, Los Angeles is sinking into a future in which it no longer can provide the public services to which our people's taxes entitle them and where the promises made to public employees about a decent and secure retirement simply cannot be kept. City revenues are in long-term stagnation and expenses are climbing. Year by year, our City—which once was a beacon of innovation and opportunity to the world—is becoming less livable. A Time for Truth, page 1

18. Under California law, Non-votes may not be required to be Yes

Votes. Under the law of the proper way to count non-votes, they may be added

to the majority. When non-votes are always treated as Yes Votes, the Non-Votes

can override a majority of No Votes and result in the approval of a Council

Project which the majority had rejected. Under California law, Non-votes may

be counted only after the other councilmembers have physically voted so that

the public knows how the majority of the actually voted. After that, the Non

votes maybe added to the majority. Under the UVP, however, the Non-votes are

tallied at the same time as the actual votes are tallied so that no one knows what

the majority voted.

19. SVV is informed, believes and thereupon alleges that there is an

agreement among councilmembers not to vote No on any Council Project in

another councilmember's district. City Council Rule 48a implements UVP and

allows Council Projects to be unanimously approved, not based on the merits of

the Council Project, but instead based on the UVP.

20. Penal Code, § 86 makes all vote trading among City Council-

members illegal. A fifteen (15) member City Council cannot unanimously agree

over 99% of the time without there being a voting pact among the council-

members. This agreement among councilmembers reflects the "You Scratch My


Back and I'll Scratch Your Back" agreement where one councilmember agrees

not to vote "No" on Council Projects in another council district in return for

other Councilmembers' not voting No for Council Projects in his/her district.

The existence of the UVP may be established by the City Council's custom and

practice without the need for a written policy or the need of an admission by

councilmembers.

21. An ancillary feature of the UVP is that measures before the City

Council are phrased so as to obtain a Yes Vote because the entire voting system

is set to automatically record Yes votes.

22. While a councilmember can manually vote No, almost no council-

member ever votes No.

23. SVV seeks to compel members of the Los Angeles City Council to

exercise his/her discretion without influence of any type of voting agreement.

24. There is no requirement of Exhaustion of Administrative Remedies

separate and distinct from SVV's participation of the administrative process in

which it partook and was then subjected it to the unlawful behavior by the City

Council as a custom and practice of the City Council in this case and in

thousands of prior cases. The UVP occur at the every end of the administrative

process of each Council Project, leaving citizens no administrative procedure

after the City Council votes.

25. SVV is entitled to injunctive relief in that The City Council's voting

behavior was and is unlawful and that each and every councilmember should

cease and desist from participation in the voting agreement.


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26. SVV and members of the general public seek an injunctive relief

restraining the City Council of the City of Los Angeles and its individual

members from engaging in any voting agreement and from conducting non-

public deliberations, except as authorized by The Brown Act.

27. The present voting procedure and mechanism should be enjoined.

The Court may enjoin the current system or any portion of it, and the Court may

order that The City and The City Council devise a new voting system without

directing The City and The City Council how to devise a new voting system.

This Court may issue a Preliminary Injunction to prohibit selected aspects of

this unlawful voting system, while considering a wider permanent injunction on

the objectionable behavior. This Court should set a series of Returns so that it

may closely monitor The City's and the City Council's development of a new

voting system.

28. SVV is entitled to reasonable attorney fees and costs under Code of

Civil Procedure, § 1021.5 to the extent their action protects a public right or

confers a benefit on the public over and above Petitioners' personal interests.

Second Cause of Action Violations of United States Constitution

42 U.S.C. § 1983, 18 U.S.C. § 242


of action, paragraphs 1 through 28, inclusive, of this Petition-Complaint.

30. The UVP are unconstitutional. They violate the United States

Constitution privileges and immunity clause, they violate the United States

Constitution Article IV which guarantees a Republican form of government.

They disenfranchise 93% of the voters on each Council Project in the City of

Los Angeles by their elected representatives refusal to exercise their public


duties with respect to any Council Project which is not in their council district.

31. As described above, the UVP violate the United States Constitution

Article IV guarantee of a Republican form of government, and the privileges

and immunities clause as well as the 14th Amendment, especially when property

is taken by the City. Such conduct also violates 18 U.S.C. § 242 and 42 U.S.C.

§ 1983. Under 18 U.S.C. § 242, "acts under cover of law" expressly include

actions by mayors and city councilmembers, making the federal statute

applicable to cities.

32. The City has failed to adequately train its personnel and its elected

officials so that they do not engage in practices which violate the US

Constitution or which violates federal statutes.

33. SVV and all other citizens are harmed and have been harmed by

municipal policies and municipal conduct which is contrary to the US

Constitution and federal statutes. As alleged herein, the UVP are actionable

municipal policies and conduct.

34. SVV is entitled to equitable remedies to prevent the continued use

of the UVP.



confers a benefit on the public over and above Petitioners' personal interests

under Civil Rights Attorney's Fees Awards Act of 1976 (42 U.S.C.A. §

1988[b]).

Ill


Third Cause of Action

Declaratory Relief

Code of Civil Procedure § 1060

Request for Jury Trial on Factual Questions


ofaction, paragraphs 1 through 35, inclusive, ofthis Petition-Complaint. Where

the prior allegations do not form required elements of this cause of action, they

are informational to provide context to this cause of action.

37. SVV has an actual controversy with The City and The City Council

in that the City Council has been engaging in the UVP and despite SVV's

efforts to have City Council cease and desist, the City Council will not change

its behavior. As there are many Council Projects which will come before the

City Council in the near and far future, SVV is entitled to a declaration whether

or not all or some of the voting practices are unconstitutional, unlawful, or

unjustifiable.

38. All citizens have a vested right that their elected representatives not

violate the law in the manner in which they vote. All citizens have a vested right

that their elected representatives, i.e. the councilmembers, not disenfranchise

voters by a voting agreement whereby each councilmember does not participate

in considering and voting on 93% of the Council Projects which come before

the City Council.

39. SVV is entitled to declaration as to the various unconstitutional,

unlawful and unjustifiable voting practices employed by the City ofLos Angeles

and its City Councilmembers.




confers a benefit on the public over and above Petitioners' personal interests.

WHEREFORE SVV prays for relief as follows:

First Cause of Action Cause of Action for Writ and Injunctive

Due to the UVP

1. SVV requests that This Court enjoin The City Council's voting

procedure and mechanism; that this Court order The City and The City Council

to devise a new voting system which guarantees that each councilmember uses

his/her own discretion and that no voting agreement exists.

2. SVV seeks a preliminary injunction and permanent injunction as to

that part of the unlawful voting which permits the clerk to count non-votes as

Yes votes.

3. SVV seeks a preliminary injunction and permanent injunction as to

that part of the unlawful voting which places CEQA items on the "consent

calendar."

4. SVV further prays for a preliminary injunctions and permanent

injunction of the UVP in all its variations as will be set forth in more detail in

an application for permanent injunction.

5. SVV further requests that This Court order that voting pact is

unlawful as in violation of The Brown Act and contrary to Penal Code, § 86.


6. SVV further requests that This Court order that The City and the

City Council present a series of Returns to the Court and to the Petitioner,

setting forth the proposed new voting process for City Hall and that the first

Return be due (30) days from the date of the Judgment herein.

7. That pursuant to Code of Civil Procedure, § 1021.5, this Court

award Petitioner reasonable attorney fees and costs due to their conferring a

substantial benefit on the community.

8. That this Court provide such other and further relief as it deems just

and proper.

Second Cause of Action 42 U.S.C. § 1983 Violations

1. For equitable remedies which will prevent the continued use of the

UVP.



confers a benefit on the public over and above Petitioners' personal interests

under Civil Rights Attorney's Fees Awards Act of 1976 (42 U.S.C.A. §

1988 [b]) .

3. That this Court provide such other and further relief as it deems just

and proper.

Third Cause of Action Declaratory Relief

4. That this court identify and declare which provisions of the UVP are

lawful and which are unlawful.


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By c

5. That pursuant to Code of Civil Procedure, § 1021.5, this Court

award Petitioners reasonable attorney fees and costs due to their conferring a

substantial benefit on the community.

6. For such other and additional relief as this court deems just and

proper.

DATED: Wednesday, February 17, 2016

Edward W. Pilot, A Professional Corp., and Richard S. MacNaughton, Esq. Co-counsel for Petitioner Save

Richard S. MacNaughton, Esq. I 9 16:VV:VV2-P-ver#2


Verification of Petition

Verification of Petition

VERIFICATION of PETITION

STATE OF CALIFORNIA

COUNTY OF LOS ANGELES

I have read the foregoing Petition for Writ of Mandate, Injunction, and

complaint for Declaratory Relief under Code of Civil Procedure § 1060 and I know

there contents thereof. I am the person authorized to sign verifications by Petitioner-

Plaintiff SaveValleyVillage SVV in the foregoing action. The matters stated therein

are true and correct from my personal knowledge except for those matters of which

I am informed and as to those matters, I believe the pleading to be true and accurate.

I declare under penalty of perjury of the laws of the State of California this

declaration is true and correct.

Executed on .11(r t_ S at Valley Village, Los Angeles,

California.

it) 0 /V vt.) 600

authorized agent of SVV to sign

on behalf of Petitioner SaveValleyVillage [SVV]

Citizens Petition re Unlawful Voting Practices

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Documents

COUNCILMEMBER MIKE BONIN, · 2016. 2. 25. · COUNCILMEMBER MIKE BONIN, COUNCILMEMBER MITCHELL ENG- LANDER, COUNCILMEMBER MITCH O'FARRELL, COUNCILMEMBER JOSE, HUIZAR COUNCILMEMBER