No.

S226645
IN THE SUPREME COURT OF CALIFORNIA

COUNTY OF LOS ANGELES BOARD OF SUPERVISORS, et al.,

Petitioners,
v.
THE SUPERIOR COURT OF LOS ANGELES COUNTY,
Respondent,
ACLU OF SOUTHERN CALIFORNIA, et al.,
Real Parties in Interest.

After a Judgment of the Court of Appeal of the State of California,

Second Appellate District
Court of Appeal Case No. B257230
REQUEST FOR PERMISSION TO FILE AMICI CURIAE BRIEF
OF LOS ANGELES TIMES COMMUNICATIONS LLC;
MCCLATCHY NEWSPAPERS, INC.; GANNETT; FIRST
AMENDMENT COALITION; CALIFORNIA BROADCASTERS
ASSOCIATION; AND CALIFORNIA NEWSPAPER PUBLISHERS
ASSOCIATION IN SUPPORT OF REAL PARTIES IN INTEREST
ACLU OF SOUTHERN CALIFORNIA AND ERIC PREVEN;
BRIEF OF AMICI CURIAE
Karl Olson (SBN 104760)
RAM, OLSON, CEREGHINO & KOPCZYNSKI LLP
101 Montgomery Street, Suite 1800
San Francisco, CA 94104
Tel: 415-433-4949
Fax: 415-433-7311
Email: kolson@rocklawcal.com
Attorneys for Amici

No. S226645
IN THE SUPREME COURT OF CALIFORNIA

COUNTY OF LOS ANGELES BOARD OF SUPERVISORS, et al.,

Petitioners,
v.
THE SUPERIOR COURT OF LOS ANGELES COUNTY,
Respondent,
ACLU OF SOUTHERN CALIFORNIA, et al.,
Real Parties in Interest.
After a Judgment of the Court of Appeal of the State of California,
Second Appellate District
Court of Appeal Case No. B257230
REQUEST FOR PERMISSION TO FILE AMICI CURIAE BRIEF
OF LOS ANGELES TIMES COMMUNICATIONS LLC;
MCCLATCHY NEWSPAPERS, INC.; GANNETT; FIRST
AMENDMENT COALITION; CALIFORNIA BROADCASTERS
ASSOCIATION; AND CALIFORNIA NEWSPAPER PUBLISHERS
ASSOCIATION IN SUPPORT OF REAL PARTIES IN INTEREST
ACLU OF SOUTHERN CALIFORNIA AND ERIC PREVEN
Karl Olson (SBN 104760)
RAM, OLSON, CEREGHINO & KOPCZYNSKI LLP
101 Montgomery Street, Suite 1800
San Francisco, CA 94104
Tel: 415-433-4949
Fax: 415-433-7311
Email: kolson@rocklawcal.com
Attorneys for Amici

To: THE HONORABLE CHIEF JUSTICE TANI G. CANTIL-SAKAUYE

AND THE HONORABLE ASSOCIATE JUSTICES OF THE
CALIFORNIA SUPREME COURT:
This case is a matter of vital importance to Californians, including the
media and non-profit amici identified below, who monitor government spending
and operations, and cover litigation involving public agencies. The County of Los
Angeles asks this Court to give it a blank check to spend millions of dollars of
taxpayer money secure in the knowledge that the taxpayers who foot the bill will
never see the invoices shedding light on how public money was spent. Amici
submit that the required narrow construction of statutes barring access to records
calls for rejection of the Countys position.
No prudent individual spending his or her own money would pay an
attorney invoice without having some description of the work done, but the
County of Los Angeles wants a blank check to be the law. The Countys position
taking an overly-expansive view of the attorney-client privilege in a case
involving none of the policies giving rise to the privilege, and ignoring the strong
public policies (and this Courts recent jurisprudence) allowing the public to
monitor public spending would deny the public access to redacted invoices
reflecting the amounts public agencies spent on litigation, reversing the prevailing
practice for decades of public agencies releasing redacted bills to the news media
and the public in response to CPRA requests.
The public release of redacted invoices has enabled news organizations to
do important watchdog reporting on the legal costs borne by taxpayers to fix the
damage wrought by scandals such as what occurred in the city of Bell. As the Los
Angeles Times reported, While municipal corruption and mismanagement cases
have led to millions of dollars being stolen from city coffers, the biggest toll is
often the enormous bills from attorneys who are paid by the hour to clean up the

mess, according to a Times analysis of municipal legal bills across California.

Unfortunately, thats the double-headed monster whenever you have
wrongdoing, said Jose Pulido, the new city manager of Temple City, where legal
costs roughly doubled after the mayor and other officials were convicted of
soliciting bribes from a developer. Sewell and Garrison, Corruption can leave
cities with enormous legal bills, Los Angeles Times, April 18, 2012,
http://articles.latimes.com/2012/apr/18/local/la-me-city-attorney-spending20120418. The County would block the public from access to this vital
information, even though agencies easily can protect client confidences on
attorney invoices through redactions as occurs every day in the federal and state
court systems when litigants submit redacted invoices in statutory or contractual
fee-shifting cases.
For these reasons, and those set forth below, amici curiae a coalition of
media and non-profit organizations who care about the spending of public money,
and the ability to monitor government operations1 respectfully urge this Court to
grant permission to file the accompanying amicus brief on the merits in support of
real parties in interest.2

Dated: February 11, 2016

By:

/s/ Karl Olson________________

Karl Olson
RAM, OLSON, CEREGHINO &
KOPCZYNSKI LLP
Attorneys for Amici Curiae

The amici include Los Angeles Times Communications LLC;

McClatchy Newspapers, Inc.; Gannett; First Amendment Coalition; California
Broadcasters Association; and California Newspaper Publishers Association.
2

Pursuant to California Rule of Court 8.520(f)(4), amici state that no party

or counsel for any party authored the proposed amicus brief in whole or in part,
and no party or counsel for any party made a monetary contribution intended to
fund the preparation or submission of the brief. No person or entity made a
monetary contribution intended to fund the preparation or submission of the brief
other than the amici, their members and the undersigned counsel.

No. S226645
IN THE SUPREME COURT OF CALIFORNIA

COUNTY OF LOS ANGELES BOARD OF SUPERVISORS, et al.,

Petitioners,
v.
THE SUPERIOR COURT OF LOS ANGELES COUNTY,
Respondent,
ACLU OF SOUTHERN CALIFORNIA, et al.,
Real Parties in Interest.
After a Judgment of the Court of Appeal of the State of California,
Second Appellate District
Court of Appeal Case No. B257230
AMICI CURIAE BRIEF OF LOS ANGELES TIMES
COMMUNICATIONS LLC; MCCLATCHY NEWSPAPERS, INC.;
GANNETT; FIRST AMENDMENT COALITION; CALIFORNIA
BROADCASTERS ASSOCIATION; AND CALIFORNIA
NEWSPAPER PUBLISHERS ASSOCIATION IN SUPPORT OF
REAL PARTIES IN INTEREST ACLU OF SOUTHERN
CALIFORNIA AND ERIC PREVEN
Karl Olson (SBN 104760)
RAM, OLSON, CEREGHINO & KOPCZYNSKI LLP
101 Montgomery Street, Suite 1800
San Francisco, CA 94104
Tel: 415-433-4949
Fax: 415-433-7311
Email: kolson@rocklawcal.com
Attorneys for Amici

TABLE OF CONTENTS
I.

INTRODUCTION .......................................................................................1

II.

INTEREST OF AMICI CURIAE .................................................................2

III.

THE COURT OF APPEALS DECISION DISREGARDS THE

CALIFORNIA CONSTITUTION, CONFLICTS WITH EARLIER
PRECEDENT, AND WOULD PREVENT THE PUBLIC FROM
MONITORING PUBLIC SPENDING. .......................................................4
A.

The Court of Appeal Disregarded the Constitutional

Mandate to Narrowly Construe Statutes Limiting Access
and Broadly Construe Statutes Promoting Access...........................4

B.

Consistent Precedent Has Held That Invoices Are Not

Privileged. ......................................................................................11

C.

Access to Invoices Allows the Public to Monitor Public

Spending ........................................................................................13

IV.

IT WOULD NOT BE ABSURD, AS THE COUNTY

CONTENDS, FOR THIS COURT TO ADHERE TO THE
NARROW CONSTRUCTION OF EXEMPTIONS FROM
DISCLOSURE SET FORTH IN ARTICLE I, SECTION 3(b)(2)
OF THE CALIFORNIA CONSTITUTION. .............................................16

V.

THE COUNTY ADVOCATES FOR A LIMITLESS PRIVILEGE. ........18

VI.

INVOICES ARE THE BEST INFORMATION ABOUT

SPENDING ON OUTSIDE COUNSEL. ..................................................19

VII.

THE COUNTYS POSITION WOULD HAVE UNDESIRABLE

CONSEQUENCES IN FEE LITIGATION. ..............................................20

CERTIFICATE OF WORD COUNT ....................................................................22

TABLE OF AUTHORITIES
Cases
Bighorn- Desert View Water Agency v. Verjil
39 Cal.4th 205, 214 (2006). 17
CBS, Inc. v. Block
42 Cal. 3d 646, 653 (1986).. 7
City of New Haven v. FOIC
205 Conn. 767, 535 A.2d 1297 (1988).. 13
City Pages v. State of Minnesota
655 N.W.2d 839, 844-847 (Minn. App. 2003).. 13
Clarke v. American Commerce Natl Bank
974 F.2d 127, 129-130 (9th Cir. 1992) 13, 17
Commission on Peace Officers Standards and Training v. Superior Court
(CPOST) 42 Cal. 4th 278, 291(2007)6
Costco Wholesale Corp. v. Superior Court
47 Cal. 4th 725, 743(2009)... 11, 13
County of Los Angeles v. Superior Court (Anderson-Barker)
211 Cal. App. 4th 57(2012) 12, 17, 21
Cypress Media, Inc. v. City of Overland Park
997 P.2d 681, 692-93 (Kan. 2000).13
Doe 2 v. Superior Court
132 Cal. App. 4th 1504, 1522 (2005)... 4
Hotel Employees and Restaurant Employees v. Davis
(1999) 21 Cal.4th 585, 602

17

International Federation of Professional and Technical Engineers Local 21 v.

Superior Court 42 Cal. 4th 319, 333
passim
Mitchell v. Superior Court
37 Cal. 3d 591, 599 (1984).. 9
Montebello Rose Co. v. Agricultural Labor Relations Board
119 Cal. App. 3d 1, 32 (1981). 9
Northern California Police Practices Project v. Craig
90 Cal. App. 3d 116, 123-124 (1979).. 9
Pasadena Police Officers Association v. Superior Court
240 Cal. App. 4th 268, 291(2015) 8

ii

People v. Arias
45 Cal. 4th 169, 180 (2008) 10
People v. Sinohui
28 Cal. 4th 205, 215-216 (2002). 17
Recorder v. Commission on Judicial Performance
72 Cal. App.4th 258, 269-274 (1999). 17
Sierra Club v. Superior Court
57 Cal. 4th 157, 166-67 (2013). 4
Solin v. OMelveny & Myers
89 Cal.App. 4th 451, 457 (2001).. 9
State Board of Equalization v. Superior Court
10 Cal. App. 4th 1177, 1187 (1992). 8
Wellpoint Health Networks, Inc. v. Superior Court
59 Cal. App. 4th 110, 123 (1997). 4
Rules
Evidence Code section 952. 6, 10, 17
Government Code section 6253(b).. 7
Government Code section 6250...4
Constitutional Provisions
Article I, section 3(b)(2) of the California Constitution. passim

iii

I.

INTRODUCTION
This case involves access to information shedding light on the spending of

large amounts of public money. Los Angeles County spent $118.9 million in
litigation expenses in fiscal year 2015-15, up 24 percent from the $85.6 million it
spent in fiscal year 2013-14 .1 The $118.9 million it spent in the most recent
fiscal year included $59.9 million in judgments and settlements and an almost
equal amount, $59 million, in attorneys fees and costs. Yet if the County has its
way, the taxpayers who foot that bill will be deprived of such basic information as
who worked how many hours on what day and at what hourly rate, all because
such a basic thing as attorney invoices would be swallowed by the attorney-client
privilege.
That has never been and should not be the law. The Countys position
defies the required narrow construction of statutes required by article I, section
3(b)(2) of the California Constitution, and it ignores what this Court has described
as the strong public interest in knowing how the government spends its money.
International Federation of Professional and Technical Engineers Local 21 v.
Superior Court (Contra Costa Newspapers) 42 Cal. 4th 319, 333 (hereafter
IFPTE). The Countys position would deny the public access to spending
records, which makes it possible for members of the public to expose
corruption, incompetence, inefficiency, prejudice and favoritism. (Id. at 333,
internal quotation marks omitted.)
This Court observed in the IFPTE case, It is difficult to imagine a more
critical time for public scrutiny of its governmental decision-making process than
when the latter is determining how it shall spend public funds. (42 Cal. 4th at

County Counsel Annual Litigation Cost Report Fiscal Year 20142015, subject of accompanying Motion for Judicial Notice.

334, citation omitted.) The Countys position would block that public scrutiny in
a case which would serve none of the core interests advanced by the attorneyclient privilege.

For the foregoing reasons, this Court should reverse the

decision of the Court of Appeal and deny the countys Petition for Writ of
Mandate.

II.

INTEREST OF AMICI CURIAE

Los Angeles Times Communications LLC, a subsidiary of Tribune

Publishing Company, LLC, publishes the Los Angeles Times, the states largest
newspaper, and a number of smaller community papers. Tribune Publishing
Company, LLC also publishes the San Diego Union-Tribune. Several recent Los
Angeles Times articles depended on using the California Public Records Act to
obtain fee invoices from public agencies to reveal government spending on legal
fees. These included UCLAs spending $4.5 million in legal fees to defend a
chemistry professor in a fatal lab fire (http://www.latimes.com/local/education/lame-ucla-legal-20141016-story.html) and a water district spending $5 million in
legal fees in 10 months defending a lawsuit brought by local cities over the
districts pumping rates, which was about $1 million more than what attorneys for
the plaintiff cities charged over five years
(http://www.latimes.com/local/california/la-me-huge-legal-fees-20150513story.html).
McClatchy Newspapers, Inc. publishes The Sacramento Bee, The Fresno
Bee, The Modesto Bee, and the Merced Sun-Star.
The First Amendment Coalition (FAC) is a non-profit organization
whose members include citizens and media organizations. FACs core mission is
to promote the publics right to know what its government is doing. It has
participated as an amicus in all of this Courts recent Public Records Act cases.

Gannett Co., Inc. is an international news and information company that

publishes 93 daily newspapers in the United States and Guam, including The
Desert Sun in Palm Springs, The Salinas Californian, Visalia Times-Delta/Tulare
Advance-Register and USA TODAY. Each weekday, Gannetts newspapers are
distributed to an audience of 9 million readers and the websites associated with
the companys publications serve online content to 95 million unique visitors each
month.

California Broadcasters Association (CBA) is the trade

organization representing more than 1,000 radio and television broadcast
stations in the state. Founded in 1947, the CBA promotes the customs and
practices that allow licensed broadcasters to effectively serve the best
interests of their communities.
California Newspaper Publishers Association (CNPA) is a non-profit
organization with 907 member newspapers. CNPA has been a friend of this Court
in all of its recent cases involving the California Public Records Act.
The Reporters Committee for Freedom of the Press is a voluntary,
unincorporated association of reporters and editors that works to defend the First
Amendment rights and freedom of information interests of the news media. The
Reporters Committee has provided guidance and research in First Amendment
and Freedom of Information Act litigation since 1970.
Californians Aware, the Center for Public Forum Rights, is a non-profit
public benefit corporation organized under the laws of California, established in
2004 to help journalists and others keep Californians aware of what they need to
know to hold government and other powerful institutions accountable for their
actions. Its mission, rooted in the protections guaranteed by the First
Amendment as well as other state and federal laws, is to support and defend
open government, an enquiring press and a citizenry free to exchange facts and
opinions on public issues. Californians Aware has a diverse membership and

support base throughout the state, reflected in a board comprising equal numbers
of directors, including lawyers, from the fields of journalism, government service,
and community watchdog advocacy. Further information about its mission and
activities is available at https://www.calaware.org/calaware.

III.

THE COURT OF APPEALS DECISION DISREGARDS THE

CALIFORNIA CONSTITUTION, CONFLICTS WITH
EARLIER PRECEDENT, AND WOULD PREVENT THE
PUBLIC FROM MONITORING PUBLIC SPENDING.
A.

The Court of Appeal Disregarded the Constitutional

Mandate to Narrowly Construe Statutes Limiting Access
and Broadly Construe Statutes Promoting Access.

Article I, section 3(b)(2) of the California Constitution requires that

statutes limiting the right of access be construed narrowly, and that statutes
furthering the right of access be broadly construed. Given this constitutional
mandate, and the strong public policy favoring access to information set forth in
Government Code section 6250, the preamble to the Public Records Act, all
public records are subject to disclosure unless the Legislature has expressly
provided to the contrary. Sierra Club v. Superior Court (2013) 57 Cal. 4th 157,
166-67.
The corollary of the rule that statutes promoting access must be broadly
construed is that, The burden is on the agency maintaining the records to
demonstrate that the record in question is exempt. (IFPTE, supra, 42 Cal. 4th at
337.)
Similarly, a party claiming the attorney-client privilege has the burden of
showing that the communication sought to be suppressed falls within the
parameters of the privilege. Doe 2 v. Superior Court (2005) 132 Cal. App. 4th
1504, 1522; Wellpoint Health Networks, Inc. v. Superior Court (1997) 59 Cal.
App. 4th 110, 123 [burden of showing preliminary facts necessary to support the
privilege lies with the party claiming it]. Thus, the burden in this case rests upon

the County both as the party resisting disclosure of public records and as the party
claiming an attorney-client privilege.
A consistent past practice of disclosure is relevant in determining whether
records should be disclosed. (IFPTE, supra, 42 Cal.4th at 337 [citing past practice
of disclosing salaries in ruling that named public employees salaries must be
disclosed].
There is a long history of disclosure including in Los Angeles County
of attorney invoices. Going at least as far back as 1991, Los Angeles County was
producing the costs billed by private firms to the county to defend lawsuits. See
Los Angeles Times January 22, 1991 article entitled $6 Million Spent by County
in Voting Case: Lawsuit: The legal bill in the losing battle will rise because
plaintiffs' costs must be paid. Supervisors defend the expense,
http://articles.latimes.com/1991-01-22/local/me-627_1_legal-expenses [showing
that Los Angeles County spent $6 million in fighting a voting-rights lawsuit].
The Court of Appeals decision thus overturns decades of practice in this state of
turning over redacted invoices, with nary a problem about revealing client
confidences. The Court of Appeals decision thus solves a problem which
doesnt exist revealing client confidences and endorses keeping secret a
problem that does exist, outside attorneys in some cases spending unusually high
amounts of taxpayer money with little oversight from the bureaucrats who hire
them.
The right of access is most clear, and most essential, when the spending of
public money is at issue. As this Court observed in International Federation of
Professional and Technical Engineers Local 21 v. Superior Court (hereafter
IFPTE) (2007) 42 Cal. 4th 319, 334, It is difficult to imagine a more critical
time for public scrutiny of its governmental decision-making process than when
the latter is determining how it shall spend public funds.

The Court of Appeal here paid lip service to the constitutional mandate of
broad construction of statutes favoring access, but largely ignored it. Instead, it
broadly construed Evidence Code section 952, the attorney-client privilege, in a
way that blocks all access to attorney invoices to public agencies, rather than
simply providing for the ability of public agencies to redact privileged portions of
an invoice such as descriptions of the content of an attorney-client communication
or descriptions of specific topics researched by an attorney.
This Court has rejected such an all or nothing or in this case nothing
approach in Public Records Act cases. In Commission on Peace Officers
Standards and Training v. Superior Court (CPOST) (2007) 42 Cal. 4th 278,
291, this Court rejected a broad interpretation of the term personnel files which
would shield an entire file from disclosure, observing, In light of the
Legislatures policy favoring disclosure of public records, the court [in an earlier
case] concluded it was unlikely that the Legislature intended an all or nothing
approach.
Here, the Court of Appeals ruling takes an all or nothing approach,
leaving the public with nothing in the way of information about how tens of
millions of public dollars are spent. A typical attorney-client invoice contains
virtually nothing in the way of confidential information: it will have pages upon
pages of descriptions of what an attorney did (attended a deposition, made a court
appearance), virtually none of which is confidential. The confidential parts can
easily be redacted, and are redacted in fee motions. For example, if the invoice
says phone call with client re whether to raise waiver argument, or phone call
with client regarding whether x should be part of direct examination, everything
after the re can be redacted but the rest including obviously how much time
was spent and what the rate is should be disclosed.
The Court of Appeals decision that entire invoices are privileged also

disregards the mandate of Government Code section 6253(b) that [a]ny

reasonably segregable portion of a record shall be available for inspection by any
person requesting the record after deletion of the portions that are exempted by
law. This along with this Courts rejection of an all or nothing approach is
a clear command that redaction, not withholding of an entire record, is the way to
safeguard both any legitimate assertion of an attorney-client privilege and the
publics ability to see how public money is spent.
The County posits a scenario where an invoice must be 90 percent
redacted because 90 percent contains an attorneys legal theories and opinions,
and posits another scenario where an opinion letter contains one paragraph of an
opinion and nine paragraphs detailing work performed and demanding payment.
(Answer Brief on the Merits at 26.) With all due respect, the County has dreamed
up hypotheticals divorced from reality. Opinion letters arent invoices, and
invoices dont deliver opinions. A typical invoice describes the work an attorney
has done and tells the client who did the work, on what day the work was done,
how much time it took, and the lawyers rate. A typical invoice might have a few
privileged entries describing specific research performed or specific topics
discussed with a client which can easily be redacted, and are redacted in fee
motions. The countys parade of horribles has only a tenuous grasp on reality.
Both this Court and the Court of Appeal have followed the mandate of
disclosing non-exempt portions of a record while redacting exempt portions in
Public Records Act cases. In CBS, Inc. v. Block (1986) 42 Cal. 3d 646, 653,
involving concealed weapons licenses, this Court explained, The fact that parts
of a requested document fall within the terms of an exemption does not justify
withholding the entire document. Thus, the Court held, any information on the
applications and licenses that might indicate when a licensee is vulnerable to
attack could be deleted. (Ibid.) Likewise, in the CPOST case, this Court held,

We consider it unlikely the Legislature intended to render documents

confidential based on their location rather than their content. (42 Cal. 4th at 291.)
The Court explained, [W]e do not believe that the Legislature intended that a
public agency be able to shield information from public disclosure simply by
placing it in a file that contains the type of information specified in [Penal Code]
section 832.8. (Ibid.)
Likewise, the Court of Appeal in Pasadena Police Officers Association v.
Superior Court (2015) 240 Cal. App. 4th 268, 291, in the context of police
personnel records, held, Here the trial court properly rejected petitioners
factually unsupported contention that information regarding the administrative
investigation is inextricably intertwined with the criminal investigation so as to
render the entire report exempt....Where, as here, non-exempt materials are not
inextricably intertwined with exempt materials and are reasonably segregable,
segregation is required. The limited exempt portions of a typical attorney
invoice are easily segregable from the non-exempt majority of the invoice.
Similarly, the Court of Appeal in State Board of Equalization v. Superior
Court (1992) 10 Cal. App. 4th 1177, 1187, remarked, The Board spills much ink
in defense of the interest of taxpayers in the privacy of information which may
identify them. That is not in issue. Such information may not be disclosed. But
the fact that a public record may contain some confidential information does not
justify withholding the entire document. (Id. at 1187.) [W]here nonexempt
materials are not inextricably intertwined with exempt materials and are otherwise
reasonably segregable therefrom, segregation is required to serve the objective of
the [Public Records Act] to make public records available for public inspection
and copying unless a particular statute makes them exempt. (Ibid.) The Court
went on to hold, Here, the public interest in disclosure is substantial, the manifest
public interest in the avoidance of secret law and a correlative interest in the

disclosure of an agencys working law. On the other side of the equation, the
Board overstates the burden of segregating the exempt from the nonexempt
material. As noted, the record contains exemplars of similar documents the Board
has disclosed in the past with confidential information excised. ... [S]egregation
here would not impose a burden on the Board to inquire from numerous outside
sources whether information contained on the documents is confidential. (Id. at
1190.)
Many of the rules on segregability derive from Northern California Police
Practices Project v. Craig (1979) 90 Cal. App. 3d 116, 123-124. In that case, the
Court of Appeal held that agencies must endeavor to segregate and disclose
nonsensitive information in records rather than withhold them. Id.
Undoubtedly, the requirement of segregation casts a tangible burden on
governmental agencies and the judiciary, the court explained. Nothing less will
suffice, however, if the underlying legislative policy of the PRA favoring
disclosure is to be implemented faithfully. If the burden becomes too onerous,
relief must be sought from the Legislature. Id.
Nothing in Evidence Code section 952 or this Courts attorney-client
privilege jurisprudence mandates or justifies departure from these settled
principles in a Public Records Act case. Evidence Code section 952s definition
of confidential communication states that it includes a legal opinion formed
and the advice given by the lawyer in the course of that relationship. The
purpose of the privilege is to promote full and open discussion of the facts and
tactics surrounding individual legal matters. Mitchell v. Superior Court (1984)
37 Cal. 3d 591, 599; Solin v. OMelveny & Myers (2001) 89 Cal.App. 4th 451,
457. The dominant purpose of an attorneys invoice is to get paid, not to
convey legal advice. (See Montebello Rose Co. v. Agricultural Labor Relations
Board (1981) 119 Cal. App. 3d 1, 32 [communications were not privileged unless

the dominant purpose of the particular communication was to secure or render

legal service and advice; since employers labor negotiations could have been
conducted by a non-attorney, communications with attorney relating to the
conduct of the negotiations were not privileged].)
The definition of confidential communication in Evidence Code section
952 as includ[ing] a legal opinion formed and the advice given by the lawyer in
the course of that relationship is instructive. In the IFPTE case, this Court
considered whether a Penal Code provision exempting personal data from
disclosure required that the salaries of peace officers be exempt from disclosure
under the Public Records Act. This Court followed the principle of ejusdem
generis, which restricts a general term to things that are similar to those
enumerated specifically, and which presumes that if the Legislature intends a
general word to be used in its unrestricted sense, it does not also offer as examples
peculiar things or classes of things since those descriptions then would be
surplusage. (IFPTE, supra, 42 Cal. 4th at 342.) This Court held, Had the
Legislature intended the word personal to be employed in its broadest sense, the
listing of examples in subdivision (a) would have been unnecessary; indeed, there
would have been no need to include items (b) through (e), each of which relates to
the individual officer. (Id. at 342-43.)
As this Court explained in People v. Arias (2008) 45 Cal. 4th 169, 180, the
ejusdem generis rule is based on the obvious reason that if the Legislature had
intended the general words to be used in their unrestricted sense, it would not
have mentioned the particular things or classes of things which would in that
event become mere surplusage.
Here too, had the Legislature in Evidence Code section 952 intended to
include something as routine as an invoice within the definition of a confidential
communication, or intended to use confidential communication in an

10

unrestricted sense, it would not have offered as examples a legal opinion

formed and the advice given by the lawyer in the course of that relationship.
Had the Legislature intended to include invoices within the privilege, it
could and would have either placed a period after the words accomplishment of
the purpose for which the lawyer is consulted and given no examples, or it could
and would have included invoices as an example of confidential
communications. It did neither.
Former Chief Justice George cited the ejusdem generis principle in his
concurring opinion in Costco Wholesale Corp. v. Superior Court (2009) 47 Cal.
4th 725, 743, a case which concerned the attorney-client privilege. Chief Justice
George remarked, in order to be privileged, the information transmitted between
the lawyer and the client must be similar in nature to the enumerated examples
namely, the lawyers legal opinion or advice. (Id. at 743, George, C. J.
concurring.) This construction of the privilege is eminently sensible in the
context of this case, involving invoices whose self-evident purpose is to facilitate
payment to attorneys and not to render legal advice.
Given the requirement set forth in article I, section 3(b)(2) of the
California Constitution that statutes limiting access be narrowly construed and
those furthering access be broadly construed, as well as the ejusdem generis
principle applied by this Court in the IFPTE case, the Court of Appeals broad
construction of Evidence Code section 952 to allow attorney invoices to be
entirely withheld cannot be justified.

B.

Consistent Precedent Has Held That Invoices Are Not

Privileged.

The Court of Appeals decision upset what virtually all attorneys have
always taken for granted and conflicted with another Second District decision
only three years old. In County of Los Angeles v. Superior Court (Anderson-

11

Barker) (2012) 211 Cal. App. 4th 57 (hereafter Anderson-Barker), the Court of
Appeal held that a party to a pending lawsuit against a public entity can obtain
documents under the Public Records Act relating to the attorney fees charged by
litigation counsel for the public entity. (Id. at 60.) In that case, as here, a Public
Records Act petition was filed against the County of Los Angeles seeking access
to invoices submitted to the County by law firms defending it. (Id. at 61.) In that
case, as here, the County argued that the invoices were attorney-client
communications. (Ibid.) In that case, as here, the Los Angeles County Superior
Court rejected the argument that the attorney-client privilege shielded entire
invoices, although the Court ruled that portions of the invoices showing attorney
work product could be redacted. (Id. at 61.)
The County thought so little of its attorney-client privilege argument in the
Anderson-Barker case that it did not challenge the trial courts ruling with respect
to the attorney-client and work product privileges. (Id. at 62.) Rather, it argued
only that the redacted documents it was ordered to disclose were exempt from
disclosure under the CPRAs pending litigation exemption. (Id. at 62.) The Court
of Appeal rejected that argument: it upheld the trial courts finding that the
dominant purpose for preparing the documents was not for use in litigation but as
part of normal record keeping and to facilitate the payment of attorney fees on a
regular basis. That such documents may have an ancillary use in litigation for
example, in connection with a request for attorney fees does not undermine the
substantial evidence before the trial court that the dominant purpose of the records
was not for use in litigation. (Id. at 67.)
Although the Court of Appeal in the Anderson-Barker case did not
explicitly discuss the attorney-client privilege because the County in that case
did not challenge the trial courts ruling rejecting the privilege argument on
appeal both the result in that case and the Court of Appeals reasoning are in

12

direct conflict with Division Threes now-superseded decision in this case.

After all, as this Court explained in Costco Wholesale Corp. v. Superior
Court (2009) 47 Cal. 4th 725, 740, and as the ACLU points out in its Reply Brief
(at 14-21), the dominant purpose of a communication determines whether the
privilege applies. The Second District Court of Appeal, Division Eight correctly
held in the Anderson-Barker case that the dominant purpose of an attorneys
invoice is simply part of normal record keeping and to facilitate the payment of
attorney fees on a regular basis. (211 Cal. App. 4th at 67.) Division Three of the
Second District here disregarded that common-sense conclusion and reached an
unprecedented result that prevents the public from monitoring public spending.
This Court should reverse District Threes decision.
Courts in other jurisdictions have consistently found that attorney invoices
are not exempt from disclosure. See, e.g., Clarke v. American Commerce Natl
Bank, 974 F.2d 127, 129-130 (9th Cir. 1992) (fee statements reflecting general
nature of services performed are not covered by attorney-client privilege and may
be released); Cypress Media, Inc. v. City of Overland Park, 997 P.2d 681, 692-93
(Kan. 2000); City of New Haven v. FOIC, 205 Conn. 767, 535 A.2d 1297 (1988);
City Pages v. State of Minnesota, 655 N.W.2d 839, 844-847 (Minn. App. 2003)
(attorney-client privilege does not completely protect billing records). These
decisions further dramatize the error of the Court of Appeals decision in this
case.

C.

Access to Invoices Allows the Public to Monitor Public

Spending

This Court in the IFPTE case, 42 Cal. 4th at 333, cited the strong public
interest in knowing how the government spends its money. As we have observed
in the context of the publics right of access to court proceedings and documents,
public access makes it possible for members of the public to expose corruption,

13

incompetence, inefficiency, prejudice and favoritism.

As noted above, scandals often cause agencies to hire outside counsel to
defend agencies and to dig into what went wrong: after all, it is easier for a public
official who presided over a mess to hire an independent outside law firm to study
the problem than it is to fire the officials complicit in the problem. The added
virtue for public officials in hiring outside counsel is that they often take a lot of
time to do their work, so by the time they finish a report many people have
forgotten about the problem or the scandal. While agencies may legitimately
need to hire an outside firm to figure out what went wrong, the public has a strong
interest in knowing what was done with its money by the outside counsel called in
to probe the problem, whether or not their hiring was appropriate.
As the Los Angeles Times reported, In Bell, legal expenses rose by at
least $1 million about 6 percent of last years general fund budget in the year
after the former city administrator and other officials were arrested for allegedly
stealing millions of dollars from the city by giving themselves exorbitant salaries
and benefits. The city attorney projected that higher-than-normal legal costs
stemming from the scandal could continue for two to five more years. In San
Diego, outside legal expenses rose from $1.4 million in 2005 to $10.9 million in
2009 after city officials were criminally charged in two scandals, dubbed pensiongate and stripper-gate. Corruption can leave cities with enormous legal bills,
supra, Los Angeles Times April 18, 2012,
http://articles.latimes.com/2012/apr/18/local/la-me-city-attorney-spending20120418.
There are many other examples of newspapers that used the CPRA to
track spending on attorneys. See, e.g.,
http://www.sfgate.com/bayarea/article/BART-s-price-tag-for-Grant-shooting-6million-3254682.php; http://www.times-standard.com/general-

14

news/20130509/humcpr-county-reach-100k-settlement-over-transparencylawsuit-humboldt-county-acknowledges-california-public-records-act-violation;
http://www.scpr.org/news/2014/02/03/41912/central-basin-water-districtdrowning-in-legal-fee/; http://www.sfgate.com/news/article/State-PUC-faces-5-1million-in-legal-fees-6163404.php;
http://www.utsandiego.com/news/2015/mar/26/cpuc-set-to-spend-52m-ondefense-lawyers/; http://www.utsandiego.com/news/2015/mar/26/cpuc-set-tospend-52m-on-defense-lawyers/. Only access to the invoices sent by outside
counsel can reveal whether, and to what extent, the attorneys who were hired to
study a problem ended up magnifying it by spending way too much time studying
and reporting on the obvious, or whether attorneys defending agencies spent far
more than was reasonably necessary. Invoices may show that inefficient or
inexperienced attorneys spent considerable time when it was not warranted, or
they may show that counsels time and expenses were reasonable. Either way, the
public should have a right to see them, with privileged material redacted.
Outside law firms have been accused of employing scorched earth
litigation tactics in defending excessive force lawsuits. II PE 5:424. The County
paid $20 million in the 2012-13 fiscal year alone just on litigation expenses in
excessive force cases. Access to the invoices at issue here would reveal whether
inefficiency was responsible for such a large expense.
Excessive force cases are by no means the only kind of litigation in which
public entities may spend excessive amounts of money on outside counsel. After
all, when outside counsel are defending public entities, neither the attorney nor
the client has any incentive to economize. Public officials who choose to employ
outside counsel especially in Public Records Act cases may be motivated by a
desire to make themselves look good and to avoid the disclosure of embarrassing
documents. (See IFPTE, supra, 42 Cal. 4th at 331 [public disclosure of an

15

individuals salary may cause discomfort or embarrassment, but strong public

policy supporting transparency justifies disclosure]. And public officials who
choose outside counsel arent spending their own money, so the incentives which
private parties have to ride herd on outside counsel arent present. Likewise,
outside counsel defending public agencies may have ample incentives to stroke
the egos of public officials and to encourage millions for defense, not a penny
for tribute attitudes which feed counsels bottom line but may not be in the best
interests of the taxpayers who are footing the bill.
This is by no means the only reason why the public should have access to
attorney invoices to public agencies. Lawyers have been known to be significant
contributors to politicians campaigns. The public has an overwhelming interest
in knowing whether a lawyer who contributed to a public officials campaign was
rewarded with a plum piece of business and proceeded to unnecessarily churn a
case which could have been settled cheaply. Disclosure of attorney invoices will
thus, as this Court stated with respect to public employee salaries, make it
possible for members of the public to expose corruption, incompetence,
inefficiency, prejudice and favoritism. (IFPTE, supra, 42 Cal. 4th at 333.)
Disclosure may also reveal favoritism, or financial mismanagement in state and
local government. (42 Cal. 4th at 334.) If the County is allowed to do what it did
in this case provide no descriptions of the work done by attorneys there will be
no effective way to see whether tens of millions of dollars have been well spent.

IV.

IT WOULD NOT BE ABSURD, AS THE COUNTY

CONTENDS, FOR THIS COURT TO ADHERE TO THE
NARROW CONSTRUCTION OF EXEMPTIONS FROM
DISCLOSURE SET FORTH IN ARTICLE I, SECTION 3(b)(2)
OF THE CALIFORNIA CONSTITUTION.
The Countys attempt to ignore the narrow construction of exemptions

mandated by article I, section 3(b)(2) of the California Constitution (Answer Brief

on the Merits at 41-47) fails.

16

As the ACLU observes, constitutional provisions prevail over statutes

where the two conflict. Hotel Employees and Restaurant Employees v. Davis
(1999) 21 Cal.4th 585, 602. Courts must give significance to every word in
constitutional enactments. Bighorn- Desert View Water Agency v. Verjil (2006)
39 Cal.4th 205, 214.
The Countys principal argument is that Evidence Code section 952 is
completely unambiguous in its exclusion of invoices from disclosure and that
there is accordingly no occasion to narrowly construe the statute.
The ACLU correctly points out that the phrase in the course of used in
Evidence Code section 952 is inherently ambiguous. (ACLU Reply at 9, citing
People v. Sinohui (2002) 28 Cal. 4th 205, 215-216.) The Court of Appeal, in a
similar context, held that the term proceeding was ambiguous, because it had
different possible meanings, and chose the meaning which best effectuated a
constitutional provision favoring openness in the proceedings of the Commission
on Judicial Performance. See Recorder v. Commission on Judicial Performance
(1999) 72 Cal. App.4th 258, 269-274. Here too, section 952 is ambiguous, and that
ambiguity should be resolved in favor of disclosure in accordance with article I,
section 3(b)(2) of the Constitution.
The County ignores the fact that many courts, both in California and
elsewhere, have concluded that invoices are not subject to the attorney-client
privilege. See cases cited in section III B supra including County of Los Angeles
v. Superior Court (Anderson Barker) (2012) 211 Cal. App. 4th 57, 61-62 [trial
court found invoices not entirely subject to attorney-client privilege, though
portions could be redacted; county did not challenge that portion of the ruling on
appeal]; Clarke v. American Commerce National Bank, 974 F.2d 127, 130 [under
federal common law, attorney billing statements were not privileged; the
statements contained information on the identity of the client, the case name for

17

which payment was made, the amount of the fee, and the general nature of the
services performed [o]ur previous decisions have held that this type of
information is not privileged; court found nothing in the statements that reveals
specific research or litigation strategy which would be entitled to protection from
disclosure] and out-of-state cases. If, as the County contends, the privileged
status of invoices is crystal clear and completely unambiguous (Answer Brief
on Merits at 44-46), and if acceptance of the ACLUs narrow-construction
argument and the narrow-construction mandate of article I, section 3(b)(2) of the
Constitution would lead to absurd results, as the County heatedly contends, the
crystal clarity of the statute and the absurdity of making invoices subject to
disclosure seems to have escaped a number of courts.
Likewise, the Countys argument that it would be absurd for this Court
to make invoices subject to disclosure in the Public Records Act context but not in
other contexts assumes too much. The County has failed to establish that invoices
fall within the privilege even outside the Public Records Act context. Adherence
to the narrow construction mandate of article I, section 3(b)(2) to resolve a
question which may have previously escaped clear resolution both under the
Public Records Act and in other California cases would not be absurd, it would
be faithful to a constitutional enactment which came into being with an 83
percent vote of the people for Proposition 59 in 2004.

V.

THE COUNTY ADVOCATES FOR A LIMITLESS

PRIVILEGE.
The County attempts to downplay the sweeping nature of the ruling it

seeks by saying that no one contends the privilege extends to every word or
writing exchanged between lawyer and client. (Answer Brief on Merits at 48.)
But its far from clear what would not be privileged under the Countys definition.
The County argues that any transmission of information between a lawyer and a

18

client falls within the privilege, including but not limited to a legal opinion or
invoice. (Answer Brief at 49.) Under that definition, even giving directions to a
lawyers office or communications about the time of a meeting would fall within
the privilege, since such ministerial communications would involve the
transmission of information during the course of a lawyer-client relationship.
Such a broad construction of section 952 is neither compelled by that statute nor
consistent with the required narrow construction of exemptions.

VI.

INVOICES ARE THE BEST INFORMATION ABOUT

SPENDING ON OUTSIDE COUNSEL.
The county argues that even if invoices are deemed privileged, the

same information may be discoverable by other means. (Amicus Brief at

49-50.)
This argument bears some resemblance to an argument made by
public employee unions in the IFPTE case, which was rejected by this
court. There, the public employee unions argued that disclosure of salaries
alone without names attached would suffice to educate the public about
the spending of public money. This court rejected that contention, holding
that disclosure of names along with salaries was essential to enable the
public to monitor public spending, because it might reveal corruption,
incompetence, inefficiency, prejudice and favoritism. (42 Cal.4th at 333.)
The court cited several newspaper articles to make that point. (Id. at 334.)
Here too, disclosure of invoices is essential to enable the public to
see whether money paid to outside counsel has been well spent. After all,
the purpose of an invoice is two-fold: to get the attorney paid, and to let the
client know what the attorney did to earn the fee. Gone are the days when
an attorney might send a corporate client an invoice reading simply for
services rendered, $25,000. Clients rightfully expect and demand an

19

itemization of who did what when and how many hours it took to do it.
In the context of spending on counsel by public agencies, the real
client is the public, the people whose taxes foot the bill. If the County gets
its way and invoices are shielded, the real client will be deprived of the
ability to see invoices, and will essentially be writing blank checks. That
would no doubt be convenient for the bureaucrats who decide to hire
outside counsel, but that sort of taxation without representation has never
been the norm in this country and should not become the norm now.
VII.

THE COUNTYS POSITION WOULD HAVE UNDESIRABLE

CONSEQUENCES IN FEE LITIGATION.
The County brushes aside the ACLUs concern that recognition of

an absolute privilege would have undesirable consequences in fee litigation.

(Answer Brief at 50-58.)
The ACLU has the better of the argument. The County spends a lot
of time arguing that parties seeking fees wont try to hide invoices (Answer
Brief at 52) and will suffer the consequences if they do. Maybe so. But the
County ignores the far more common situation where a party seeks fees
against a public agency and the agency contests the claim. If the County
gets its way, an agency would be free to claim that its adversary spent too
much time litigating a case or an issue, or that the rates were too high, and
at the same time, resist disclosure of its own invoices which might reveal
that the agency spent even more time at higher rates. This court should not
countenance such a heads I win, tails you lose argument.
CONCLUSION
The Court of Appeals decision here narrowly construed and ignored the
Public Records Act, and expanded the attorney client privilege to encompass
invoices whose self-evident purpose is not to communicate legal advice but

20

simply to facilitate the payment of attorney fees on a regular basis. (AndersonBarker, 211 Cal. App. 4th at 67.) The Court of Appeals decision conflicted with
the result reached by another division of the Second District less than three years
ago. As this Court stated in the IFPTE case, 42 Cal. 4th at 334, It is difficult to
imagine a more critical time for public scrutiny of its governmental decisionmaking process than when the latter is determining how it shall spend public
funds. This Court should reverse the Court of Appeals decision, to preserve
the efficacy of the Public Records Act.

Dated: February 11.2016

RAM, OLSON, CEREGHINO

& KOPCZYNSKI LLP
By:

/s/ Karl Olson_______________

Karl Olson
Attorneys for Amici Curiae

N:\Docs\1422-01 County of LA Amicus\Amicus-FINAL County of LA Board of Supervisors.doc

21

CERTIFICATE OF WORD COUNT

(California Rules of Court, Rule 8.204(c)(1))
Pursuant to Rule 8.204(c)(1), and in reliance upon the word count
feature of the software used, I certify that the foregoing REQUEST FOR
PERMISSION TO FILE TO FILE AMICI CURIAE BRIEF OF LOS
ANGELES TIMES COMMUNICATIONS LLC; MCCLATCHY
NEWSPAPERS, INC.; GANNETT; FIRST AMENDMENT COALITION;
CALIFORNIA BROADCASTERS ASSOCIATION; AND CALIFORNIA
NEWSPAPER PUBLISHERS ASSOCIATION IN SUPPORT OF REAL
PARTIES IN INTEREST ACLU OF SOUTHERN CALIFORNIA AND
ERIC PREVEN; BRIEF OF AMICI CURIAE contains 6,801 words,
exclusive of those materials not required to be counted under Rule
8.204(c)(3).
Dated: February 11, 2016

RAM, OLSON, CEREGHINO

& KOPCZYNSKI LLP

By:

/s/ Karl Olson_______________

Karl Olson
Attorneys for Amici Curiae

22

County

PROOF OF SERVICE

of Los Angeles Board of Supervisors et aL y.

of Los Angeles County

No. 5226645

I, David Blum, state:

I am a citizen

The Superior Court

of the United States. My business address is

101

Montgomery Street, Suite 1800, San Francisco, CA 94104. I am employed

in the City and County of San Francisco where this mailing occurs. I am

over the age of eighteen years and not a party to this action. On the date set
forth below, I served the foregoing documents described as:

REQUEST FOR PERMISSION TO FILE AMICI CURIAE BRIEF

OF LOS ANGELES TIMES COMMUNICATIONS LLC;
MCCLATCHY NEWSPAPERS, INC.; GANNETT; FIRST
AMENDMENT COALITION; CALIFORNIA BROADCASTERS
ASSOCIATION; AND CALLFORNL& NEWSPAPER PUBLISHERS
ASSOCIATION IN SUPPORT OF REAL PARTIES IN INTEREST
ACLU OF SOUTHERN CALIFORNIA AND ERIC PREVEN;BRIEF
OF AMICI CURIAE
REQUEST FOR JUDICIAL NOTICE AND PROPOSED ORDER;
DECLARATION OF KARL OLSON IN SUPPORT OF REQUEST
FOR JUDICIAL NOTICE OF LOS ANGELES TIMES
COMMUNICATIONS LLC; MCCLATCHY NEWSPAPERS, INC.;
GANNETT; FIRST AMENDMENT COALITION; CALIFORNIA
BROADCASTERS ASSOCIATION; AND CALIFORNIA
NEWSPAPER PUBLISHERS ASSOCIATION IN SUPPORT OF
REAL PARTIES lIN INTEREST ACLU OF SOUTHERN
CALIFORNIA AND ERIC PRE VEN;
on the following person(s) in this action addressed as follows:

SEE ATTACHED SERVICE LIST

X

BY FIRST CLASS MAIL - I am readily familiar with my firm's

practices for collection and processing of correspondence for

mailing with the United States Postal Service, to-wit, I deposited
with the United States Postal Sen'ice this same day in the
ordinary course of business the said correspondence in a sealed
envelope, postage prepaid.
I declare under penalty

of perjury under the laws of the State of

California that the foregoing is true and correct and that this declaration
was executed on February 11, 2016, at Saikrancisco California.

David Blum

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SERVICE LIST

County of Los Angeles Board of Supervisors et aL

of Los Angeles County
Office of the Clerk (LASC No. BS145753)
Honorable Luis A. Lavin
Los Angeles Superior Court Case
111 North Hill Street
Los Angeles, CA 90012

Frederick Bennett
Los Angeles Superior Court
111 North Hill Street, Room 546
Los Angeles, CA 90012

y.

The Superior Court

Office of the Clerk

California Court of Appeal
Second Appellate District, Division Three
300 South Spring Street
Second Floor, North Tower
Los Angeles. CA 90013

CFAC
2701 Cottage Way#12
Sacramento, CA 95825
Attorneys for Caljfornians Aware The Center for

Publie Forum Rights : Pub/Depublication

Peter Eliasberg
ACLU Foundation of Southern California
1313 West 8th Street

Los Angeles, CA 90017

Attorneys for Real Parties in InterestACLu

of Southern Caljfornia and Eric Preven

Jennifer Brockett
Rochelle L. Wilcox
Colin Wells
Diana Palacios
DAVID WRIGHT TERMAINE LLP
865 S. Figueroa, Suite 2400
Los Angeles, CA 90017
Attorneys for Real Parties in InterestACLU of
Southern California and Eric Preveis
Mary Wickham
Roger Granbo
Jonathan McCaverty
648 Kenneth Hahn Hall of Administration
500 West Temple Street
Los Angeles, CA 90012

Barbara Ravitz
GREINES, MARTIN, STEIN & RICHLAND,
LLP
5900 Wilshire Blvd., 12th Floor
Los Angeles, CA 90036
Attorneys for County of Los Angeles Board of Attorneys for County of Los Angeles Board of
Supervisors and The Office of County
Supervisors and The Office of County Counsel

Counsel

Sally Suchil
Los Angeles County Bar Association
P.O. Box 55020
Los Angeles, CA
Attorneys for Los Angeles County Bar

Association: Amicus curiae

Steven Samuel Fleischman

Lisa Perrochet
Horvitz & Levy LLP
15760 Ventura Boulevard, 18th floor
Encino, CA 91436

Attorneys for Association of Southern Caljfornia

Defense Counsel : Amicus curiae

Stephen Louis Raucher

Reuben Raucher & Blum
10940 Wilshire Boulevard, 18th floor
Los Angeles, CA
Attorneys for Beverly Hills Bar Association:

Amicus curiae

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