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DONALD W. RICKETTS (CSBN 39825)28855 Kenroy AvenueSanta Clarita, CA 91387Phone (661) 250-3091Facsimile (661) 250-1767
FINAL DRAFT
Attorney for PlaintiffsSAVE OUR LIBRARY,andSUPERIOR COURT OF THE STATE OF CALIFORNIAFOR THE COUNTY OF LOS ANGELESNORTH VALLEY DISTRICTSAVE OUR LIBRARY, a California)unincorporated membership )association;)No. ____________)))))individuals; individually and in the )public interest, ))Plaintiffs, )VERIFIEDvs.)COMPLAINT FOR INJUNCTIVE)AND DECLARATORY RELIEFCITY OF SANTA CLARITA,}RELIEFa political subdivision of the State)of California; KENNETH R. )PULSKAMP, City Manager of the )City of Santa Clarita, in his official )capacity and not as an individual; )DARREN HERNANDEZ, Deputy)City Manager & Director of )Administrative Services of the City)of Santa Clarita, in his official )capacity and not as an individual;)and DOES1-50,))Defendants)________________________________ )COME NOW Plaintiffs and complain of Defendants, and each of them, andallege as follows:
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FINAL DRAFT COMPLAINT FOR INJUNCTIVE & DECLARATORY RELIEF
 
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1.Plaintiff SAVE OUR LIBRARY (“SOL”), is a Californiaunincorporated membership association with a principal place of business in theCity of Santa Clarita, County of Los Angeles, State of California.2.Plaintiffsare individuals residing in the City of Santa Clarita, County of Los Angeles, Stateof California, are members of SOL, and patrons of the Los Angeles County FreeLibrary System.3.Plaintiffs bring this action individually and in the public interest.4.Defendant CITY OF SANTA CLARITA (“SANTA CLARITA” or“CITY”) is a California charter city and a political subdivision of the State ofCalifornia.5.Defendant KENNETH R. PULSKAMP (“PULSKAMP”) is CityManager of Defendant SANTA CLARITA and is sued herein in his officialcapacity and not individually.6.Defendant DARREN HERNANDEZ (“HERNANDEZ”) is DeputyCity Manager and Director of Administrative Services of Defendant SANTACLARITA and is sued herein in his official capacity and not individually.7.Plaintiffs do not know the true names and identities of theDefendants sued herein by the fictitious names DOES 1-50, and will amend theircomplaint at the time they become known to them. Said fictitiously namedDefendants participated in and/or performed the acts hereinafter alleged.8.Pursuant to California Education Code section 19100,
et seq
., theCounty of Los Angeles (“County”) established and maintains a Free LibrarySystem within its boundaries.9.Defendant CITY elected to join the County’s Free Library System and
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FINAL DRAFT COMPLAINT FOR INJUNCTIVE & DECLARATORY RELIEF
 
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the County has established and maintains within the CITY, libraries located in theNewhall, Valencia and Canyon Country neighborhoods.10.Prior to the dates alleged herein, Defendant CITY resolved toconstruct a new library in Newhall to replace the present Newhall library. The building would be owned by defendant CITY and maintained and operated by theCounty as part of its Free Library System.11.In 2008 the CITY’s City Council established an
ad hoc
committee toexplore means of funding the construction of the new Newhall Library. Thecommittee was originally composed of Council Member s TimBen Boydston andMarsha McLean. Council Member Boydston was subsequently replaced byCouncil Member Laurie Ender.12.Plaintiffs are informed and believe, and thereon allege, that at a dateand time unknown to plaintiffs, the focus of the
ad hoc
committee changed toexplore the prospect of privatizing the CITY’s libraries.13.Prior to June 16, 2010, Defendant CITY and the County entered intonegotiations for a contract for the County to operate the new Newhall library.14.At the same time that defendant CITY was negotiating with theCounty regarding the terms and conditions for operation and maintenance of thenew Newhall Library, defendant HERNANDEZ met with representatives ofLibrary Systems & Services, LLC (“LSSI US”) to explore the possibility of havingLSSI operate and maintain the libraries, if the CITY withdrew from the County’sFree Library System.15.LSSI US, is a sister corporation of Library Systems & Services UK,Ltd., a British corporation. Both appear to be under common management.16.On or about June 16, 2010, the County submitted to the CITY a draftmemorandum of understanding for operation of the new Newhall library.17.Plaintiffs are informed and believe and thereon allege that no furtherdiscussions were held between the County and CITY regarding operation of the
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FINAL DRAFT COMPLAINT FOR INJUNCTIVE & DECLARATORY RELIEF
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