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Published by jeff_wilson

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Published by: jeff_wilson on Oct 13, 2010
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DONALD W. RICKETTS (CSBN 39825)28855 Kenroy AvenueSanta Clarita, CA 91387Telephone: (661) 250-3091 FILEDFacsimile: (661) 250-176710/12/10E-mail: SOL@socal.rr.comAttorney for PlaintiffSAVE OUR LIBRARY, INC.SUPERIOR COURT OF THE STATE OF CALIFORNIAFOR THE COUNTY OF LOS ANGELESNORTH VALLEY DISTRICTSAVE OUR LIBRARY, INC., a California)non-profit corporation, individually, )on behalf of its members, and in the public)No. PC 049312interest, ))Plaintiff, )VERIFIED FIRST AMENDEDvs.)COMPLAINT/PETITION FOR)INJUNCTIVE ANDCITY OF SANTA CLARITA,}DECLARATORY RELIEF, ANa political subdivision of the State)OSC, AND FOR MANDAMUSof California; KENNETH R. )PULSKAMP, City Manager of the )Assigned for all purposes to HonCity of Santa Clarita, in his official )Barbara M. Scheper, Dept. F49capacity and not as an individual; )DARREN HERNANDEZ, Deputy)
Immediate Relief Requested
City Manager & Director of )(Govt.C. §§6258, 6259Administrative Services of the City)of Santa Clarita, in his official )capacity and not as an individual;)COUNTY OF LOS ANGELES, a )political subdivision of the State of )California; and DOES 1-50,))Defendants)_____________________________________ ) Complaint Filed: 10/4/10COMES NOW Plaintiff and complains of Defendants, and each of them, andalleges as follows:1.Plaintiff SAVE OUR LIBRARY, INC. (“SOL”), is a California non-profitcorporation with a principal place of business in the City of Santa Clarita, County of Los
Angeles, State of California.2.Plaintiff brings this action individually, on behalf of its members, and inthe public interest.3.Plaintiff’s members are residents of defendants CITY OF SANTA CLARITA(“CITY”) and COUNTY OF LOS ANGELES (“COUNTY’), hold library privileges to theLos Angeles County Public Library (“County Library”) and are beneficially interestedherein.4.Defendant CITY is a California general-law city and a political subdivisionof the State of California.5.Defendant KENNETH R. PULSKAMP (“PULSKAMP”) is City Manager ofDefendant CITY and is sued herein in his official capacity and not individually.6.Defendant DARREN HERNANDEZ (“HERNANDEZ”) is Deputy CityManager and Director of Administrative Services of Defendant CITY and is sued hereinin his official capacity and not individually.7.Defendant COUNTY is a political subdivision of the State of California.8.Plaintiff does not know the true names and identities of the Defendantssued herein by the fictitious names DOES 1-50, and will amend its complaint at the timethey become known to it. Said fictitiously named Defendants participated in and/orperformed the acts hereinafter alleged.9.In 1912, under authority of California’s County Free Library Act(California Education Code section 19100,
et seq
.), the County established the CountyLibrary.10.The County Library provides library service to over 3.5 million residents ,including residents in 51 of the 88 incorporated cities located within the COUNTY. It hasa 7.5 million books which is available to all of the patrons of the various libraries itoperates. It also offers magazines, newspapers, government publications and manyspecialized materials and access to the World Wide Web through computer terminals in
the libraries.10.Plaintiff’s members and all patrons of the County Library obtained libraryprivileges by submitting an application to the County Library. The application requireda patron to provide his or her full name, mailing address, residence address, telephonenumber, birth date, California driver’s license or I.D. number, and the last four numbersof the patron’s Social Security number. A true and correct copy of the application isattached hereto as Exhibit A.11.Once a patron obtains library privileges, the patron’s usage of thefacilities–books borrowed, websites visited on library-provided computer terminals–istracked.12.The information provided in the application and the patron’s usage historyis recorded in databases which are in the possession of defendant COUNTY and itsCounty Library.13.By 1999 local government was faced with diminishing revenues and severecutbacks in library funding were occurring. In that year, defendant CITY commissionedPublic Management Associates and Arroyo Associates to survey public opinion andevaluate options available to the CITY for funding library services.14Three options were evaluated:a Continue with the County Library and negotiate with the COUNTYfor improved service levels at the existing facilities and the new Canyon Countrylibrary. b.Withdraw from the County Library system and provideindependent library services through the CITY.c.Withdraw from the County system and contract with a private firmto provide library services.15.Arroyo Associates reviewed the operation and financing and found that theCOUNTY “spent $649,271 more to operate the Santa Clarita libraries than it received in

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