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KELLY A. AVILES (SBN 257168)
Law Offices of Kelly Aviles
1502 Foothill Blvd., #103-140
La Verne, California 91750
Telephone: (909) 991-7560
Facsimile: (909) 991-7594
Email: kaviles@opengovlaw.com

JOSEPH T. FRANCKE (SBN 88654)
2218 Homewood Way
Carmichael, California 95608
Telephone: (916) 487-7000
Facsimile: (916) 487-7999
Email: terry@calaware.org

Attorneys for Petitioner
CALIFORNIANS AWARE



SUPERIOR COURT OF THE STATE OF CALIFORNIA

FOR THE COUNTY OF LOS ANGELES



CALIFORNIANS AWARE,

Petitioner/Plaintiff,

v.

PASADENA AREA COMMUNITY
COLLEGE DISTRICT BOARD OF
TRUSTEES,

Respondent/Defendant,

DR. MARK W. ROCHA,
President/Superintendent of Pasadena
City College

Real Party in Interest.

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Case No.:

VERIFIED PETITION FOR WRIT OF
MANDATE, INJUNCTIVE AND
DECLARATORY RELIEF FOR
VIOLATIONS OF THE RALPH M.
BROWN ACT; EXHIBITS A
THROUGH H.

[Cal. Government Code Section 54950, et
seq.]


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VERIFIED PETITION FOR WRIT OF MANDATE


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This action seeks relief from the failure of Respondent/Defendant PASADENA
AREA COMMUNITY COLLEGE DISTRICT BOARD OF TRUSTEES to perform as
required by the Ralph M. Brown Act (Govt. Code, 54950 et seq.; Brown Act), thereby
denying the publics right to the protections afforded by our States open government
laws and the Article One, Section Three, of the California Constitution.
Petitioner/Plaintiff CALIFORNIANS AWARE seeks a writ of mandate,
injunctive, and declaratory relief under California Code of Civil Procedure sections 1085
and 1060 and Government Code sections 54960 and 54960.1. In this Verified Petition,
Petitioner alleges as follows:
INTRODUCTION
1. On August 7, 2014, Respondent made a surprise announcement that
Superintendent/President Dr. Mark Rocha would be retiring. Discussion or action
on this issue never appeared on any of Respondents agenda. Even though his contract
did not provide for any payment upon his retirement, the District has paid Dr. Rocha
over $400,000. This action is just the latest in the string of high-level executives of
public agencies in California being awarded huge amounts of taxpayer dollars in
severance even where their contract does not provide for such payment. There is a
great public interest in the award of public money to departing employees; yet, these
deals are almost always done in secret. In this case, the District never noticed or
discussed Dr. Rochas retirement or severance compensation. This violates the publics
right to participate in the decision-making process of its local agencies, a right
guaranteed by the Brown Act and the California Constitution. Therefore, Petitioners
seek a declaration that the Boards actions violated the Brown Act, and for an order
nullifying the action taken to approve the severance compensation and to return that
taxpayer money to the Board.
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VERIFIED PETITION FOR WRIT OF MANDATE


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THE PARTIES
2. Petitioner/Plaintiff CALIFORNIANS AWARE (Petitioner or
CalAware) is, and at all times mentioned in this petition has been, a 501(c)(3) non-
profit public benefit corporation organized under the laws of California, governed by a
board comprised of public officials, public-minded citizens, and journalists, whose
mission includes the promotion and defense of the principles of open government. Its
offices are located at 2218 Homewood Way, Carmichael, CA 95608. As such, CalAware
has a beneficial interest in Respondents performance of its legal duties under the
Brown Act.
3. Respondent/Defendant PASADENA AREA COMMUNITY COLLEGE
DISTRICT BOARD OF TRUSTEES (Respondent or Board), is the elected seven-
member governing body of the Pasadena Area Community College District (District)
and is part of the state community college system. The Boards offices are located at
1570 E. Colorado Boulevard, Pasadena, California 91106-2003. The District is defined
as a local agency by 54951. The Board is a legislative body under 54952.
4. Real Party in Interest, DR. MARK W. ROCHA, was the
Superintendent/President of Pasadena City College from approximately July 2010 to
August 2014.
FACTS
5. Dr. Mark W. Rocha was hired in 2010 as the Superintendent/President of
Pasadena City College (PCC.) At that time, the District and Dr. Rocha entered into
an employment agreement. A copy of Dr. Rochas original employment agreement,
dated June 9, 2010, is attached hereto as Exhibit A
1
. A copy of Dr. Rochas amended
employment agreement, dated October 2, 2013, is attached hereto as Exhibit B.
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All Exhibits are true and correct copies of the documents purported to be and are
incorporated into this petition as if set forth in full.
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VERIFIED PETITION FOR WRIT OF MANDATE



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6. The Agreements both provide for a number of scenarios for Mr. Rochas
separation from the PCC.
7. First, both Agreements could be terminated by mutual consent of the
parties. There is no provision for payment from the District to Dr. Rocha should the
contract be terminated under this provision.
8. Second, the Board can choose not to renew Dr. Rochas contract. There is
also no provision for payment from the District to Dr. Rocha should the Board choose
not to renew Dr. Rochas contract.
9. Third, both Agreements provide that Dr. Rocha could be terminated with
cause. There is no provision for payment from the District to Dr. Rocha should the Mr.
Rocha be terminated with cause.
10. The final scenario provides that the Board may terminate Dr. Rocha
without cause. It is only in this scenario that any sort of payment is provided from the
District to Dr. Rocha. Under the terms of the 2010 Agreement, if Dr. Rocha is
terminated without cause, he would have been entitled to payment equal to the lesser
of the remaining term of his contract or six months pay. Under the 2013 agreement,
this provision was amended to provide for payment equal to the lesser of the
remainder of his contract term or eighteen months pay. The expiration of the 2013 did
not occur until June 30, 2017.
11. Less than a year after the negotiation of the 2013 Agreement, on August
7, 2014, the Board announced that Dr. Rocha would be retiring as of August 31, 2014.
Exhibit C is a copy of the Press Release announcing Dr. Rochas retirement.
12. It was subsequently reported that the District has had agreed to pay Dr.
Rocha over $400,000 dollars as severance. Exhibit D is a true and correct copy of
an LA Times article reporting on Dr. Rochas severance package. Exhibit E is a copy
of the Districts press release responding to the inquiries regarding Dr. Rochas
retirement.
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VERIFIED PETITION FOR WRIT OF MANDATE


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13. There is no reference in any agenda for any Board meeting which
indicated that the Board was discussing or took action to provide a severance package
to Dr. Rocha.
14. The purpose of the Ralph M. Brown Act is to provide notice and
opportunity for members of the public to participate in the decision-making process of
local agencies. The failure to properly notice this matter, as well as the discussion of
compensation of Dr. Rocha in closed session violates the Brown Act, deprives the
notice and the opportunity to be hearing regarding matters of great public importance.
15. On August 27, 2014, Petitioner, though its legal counsel, sent a Notice of
Brown Act Violation which included a Demand to Cure and Correct pursuant to
Government Code 54960.1 and a Demand to Cease and Desist pursuant to
Government Cod 54960.2 (Demand) to the Board. A true and correct copy of the
Demand is attached hereto as Exhibit F.
16. In the Demand, Petitioner notified the Board it had violated the Brown
Act by (1) approving the severance agreement without properly agendizing the
discussion or action; (2) failing to report action taken to approve the severance
agreement or affect the employment status of a public employee at the meeting during
which it was taken; (3) failing to release the votes of each board member regarding the
action taken to approve the severance agreement or affect Mr. Rochas employment
agreement; (3) discussing and taking final action on compensation of an
unrepresented employee in closed session; and (4) failing to disclose the facts and
circumstances which constituted the Districts significant exposure to litigation.
17. In the Demand, Petitioners requested that the Board cure and correct
as follows:
1. Rescinding the action taken to approve the severance agreement
with Mr. Rocha;
2. Publically reporting the vote or abstention of every trustee to
approve the severance agreement with Mr. Rocha;
3. Disclose each date and under which agenda item the Board
discussed Mr. Rochas severance and/or resignation;
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VERIFIED PETITION FOR WRIT OF MANDATE


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18. In the Demand, Petitioners requested that the Board cease and desist
by making an unconditional commitment to refrain from the following practices in the
future:
1. Failing to set forth the facts and circumstances that justify threatened
or anticipated litigation closed sessions pursuant to Government
Code 54956.9(b);
2. Failing to report the vote at any meeting where an action is taken to
affect the employment status of a public employee, in violation of
Government Code 54957 and 54957.1; and,
3. Discussing and taking final action on employee compensation in a
closed session held pursuant to Government Code 54957.

19. On September 10, 2014, Petitioners counsel received correspondence
from Mary L. Dowell of Liebert Cassidy Whitmore, attorneys for the Board (the
Districts Response.) A copy of the Districts Response is attached as Exhibit G.
The letter argued that the Board had not violated the Brown Act and, therefore, the
Board was not obligated to cure or correct any of its actions leading up to the final
Agreement and Mutual General Release with Dr. Rocha. The letter also specifically
asserted that Dr. Rochas separation and severance were properly noticed at both the
July 22, 2014 special meeting and the August 6, 2014, regular meeting as anticipated
litigation. Finally, the letter asserted, that [no other facts or circumstances regarding
this discussion were stated because it was my opinion as counsel to the Board, and
remains my opinion as counsel to the Board, that to have done at [sic] so at either
meeting would have required the disclosure of information which was not yet known to
potential litigations.
CAUSE OF ACTION FOR VIOLATIONS OF THE RALPH M. BROWN ACT
(RELIEF PURSUANT TO SECTIONS 54960, 54960.1, 54960.2;
CCP SECTIONS 1060, 1085)
20. Petitioner hereby realleges and incorporates herein by this reference
Paragraphs 1 thorough 19 of this Petition as though set forth herein in full.
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VERIFIED PETITION FOR WRIT OF MANDATE


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21. The Brown Act requires that the agenda for each meeting contain a
general description of each item of business to be transacted, including those to be
discussed in closed session. Government Code 54952.2(a)(1).
22. The Brown Act prohibits a public agency from taking action or discussing
any item not appearing on the posted agenda. Government Code 54954.2(a)(2).
23. The Board violated Government Code 54952.2 by discussing and taking
action on the retirement of Dr. Rocha, and his severance package, without properly
listing it on any agenda and without any public notice.
24. Government Code section 54953(c) states No legislative body shall take
action by secret ballot, whether preliminary or final.
25. Government Code 54957.1(a)(5) requires that action taken to affect the
employment status of a public employee must be reported at the meeting in which the
closed session was held, including action to terminate the employment of a contract
employee with no administrative appeal rights.
26. The District violated Government Code 54953(c) and 54957.1(a)(5) by
failing to release the votes taken to terminate the Dr. Rochas contract and/or provide
him with a severance package.
27. Government Code 54957(b) authorizes a legislative body to hold a
closed session to consider the appointment, employment, evaluation of performance,
discipline, or dismissal of a public employee, but prohibits any discussion or action on
proposed compensation except for a reduction of compensation that results from the
imposition of discipline.
28. Government Code 54957.6(a) requires that final action on
compensation of unrepresented employees must be in open session.
29. The District violated Government Code 54957 and 54957.6(a) by
discussing Dr. Roachs severance compensation in closed session.
30. Petitioner is informed and belies, and upon that basis alleges that the
Board routinely notices closed sessions relating to anticipated litigation pursuant to
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VERIFIED PETITION FOR WRIT OF MANDATE


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Government Code 54956.9, which allows for closed sessions to allow a legislative
body of a local agency to hold a closed session to confer with, or receive advice from, its
legal counsel when there is a significant exposure to litigation based on the existing
facts and circumstances as defined in that section. However, the Board has a pattern
and practice of failing to disclose any information regarding the facts and
circumstances relating to the anticipated litigation even though it is expressly
required do so pursuant to Government Code 54956.9(b)(3)(B).
31. The Board failed to disclose existing facts and circumstances at all of
the following meetings prior to closed sessions regarding anticipated litigation: April
2, 2014, April 30, 2014, May 14, 2014, June 25, 2014, July 16, 2014, July 22, 2014,
August 6, 2014.
32. Petitioner is informed and believes, and upon that basis, alleges that the
Board discussed Dr. Roachs retirement and severance compensation during closed
sessions at its July 22, 2014 and August 6, 2014 Board meetings, noticed only as
anticipated litigation.
33. Petitioner is informed and believes, and upon that basis alleges,
2
that
existing facts and circumstances did not support that there was a significant exposure
to litigation.
34. Government Code section 54962 prohibits the Board from holding any
closed session except as expressly authorized.
35. Therefore, Petitioner alleges that the Boards discussion of Dr. Rochas
retirement and severance compensation in its July 22, 2014, and August 6, 2014,
violated Government Code 54962.
2
Petitioner attempted to obtain additional information regarding the termination to
determine whether there was, indeed, a significant exposure to litigation by submitting
a California Public Records Act Request on August 27, 2014. However, at the time of
filing this Petition, nearly a month after the request, the District has failed to provide
any responsive records. Therefore, Petitioner must allege on information and belief. A
true and correct copy of the Petitioners Requests, the Districts Response, as well as
follow-up correspondence, is attached hereto as Exhibit H.
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VERIFIED PETITION FOR WRIT OF MANDATE



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36. Even if there had been significant exposure to litigation, the District
violated the Brown Act by failing to disclose the facts and circumstances known to the
potential plaintiff, Dr. Rocha, as required by Government Code 54956.9(d)(2).
37. Petitioner alleges that these violations of the Brown Act, as set forth
above, evidence a pattern and practice of ignoring the states open meeting laws, and
have deprived Petitioner and members of the public of proper notice and of their right
to address the Board on anticipated litigation, and on Dr. Rochas
38. Without a writ of mandate, declaratory and injunctive relief provided for
by the Brown Act, Petitioner is informed and believes, and on that basis alleges, that it
and other interested persons, citizens, and taxpayers will be irreparably harmed
because they will be denied notice of and the opportunity to participate in the Boards
meetings, a right which is guaranteed by law.
39. Government Code Section 54960(a) provides that any interested person,
such as the Petitioner:
may commence an action by mandamus, injunction, or declaratory
relief for the purpose of stopping or preventing violations or threatened
violations of this chapter by members of the legislative body of a local
agency or to determine the applicability of this chapter to actions or
threatened future action of the legislative body, or to determine whether
any rule or action by the legislative body to penalize or otherwise
discourage the expression of one or more of its members is valid or invalid
under the laws of this state or of the United States, or to compel the
legislative body to audio record its closed sessions as hereinafter provided.
40. Because the Board has failed to acknowledge its violations of the Brown
Act, the Board is likely to continue to violate the Brown Act in the future.
41. Because legal counsel for the Board has stated that the Boards prior
actions did not constitute violations of the Brown Act, it is likely the Board will
continue to violate the Brown Act in the future.
42. Government Code section 54960.1 allows for a Petition to seek judicial
nullification of an action in violation of Government Code Sections 54953, 54954.2,
54954.5, 54954.6, 54956, or 54956.5.
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VERIFIED PETITION FOR WRIT OF MANDATE


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43. Petitioner has complied with all notice and demand requirements set
forth in Government Code section 54960.1.
44. The Board, through its legal counsel, has refused to cure its prior Brown
Act violations, including those in connection with Dr. Rochas retirement and
severance compensation.
45. The Board has also failed to make an unconditional commitment to
refrain from similar behavior in the future, as required by Petitioners Demand and
Government Code section 54960.2.
46. Therefore, Government Code section 54960.2 specifically authorizes
Petitioner to file a lawsuit to determine the applicability of this chapter to any past
action if the legislative body fails or refuses to make the unconditional commitment as
described in Petitioners Demand and Government Code section 54960.2.
47. The Board has ignored the publics rights to be informed and involved
and should therefore be ordered by this court to tape record future closed sessions.
48. The People of California have elevated the right to open government to
one protected by their State Constitution. The California Constitution, Article 1, Section
3, Paragraphs (a) - (b) state:
The people have the right to instruct their representatives, petition
government for redress of grievances, and assemble freely to consult for
the common good.
The people have the right of access to information concerning the conduct
of the people's business, and, therefore, the meetings of public bodies and
the writings of public officials and agencies shall be open to public
scrutiny.

A statute, court rule, or other authority, including those in effect on the
effective date of this subdivision, shall be broadly construed if it furthers
the people's right of access, and narrowly construed if it limits the right of
access.
49. Code of Civil Procedure 1060 provides:
Any person interested who desires a declaration of his or her rights or
duties with respect to another may, in cases of actual controversy relating
to the legal rights and duties of the respective parties, bring an original
action or cross-complaint in the superior court for a declaration of his or her
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VERIFIED PETITION FOR WRIT OF MANDATE


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rights and duties in the premises, including a determination of any question
of construction or validity arising under the instrument or contract. He or
she may ask for a declaration of rights or duties, either alone or with other
relief; and the court may make a binding declaration of these rights or
duties, whether or not further relief is or could be claimed at the time.

50. There presently exists, between the Petitioner and the Board, an actual
controversy relating to: (1) the legal rights of Petitioner and other members of the
public under the Brown Act and the California Public Records Act; and (2) the
ministerial duties imposed upon the Board by the Brown Act.
51. Petitioner requests a judicial determination that Respondent has violated
and is likely to continue to violate the Brown Act.
52. This determination is necessary and proper because Respondent refuses
to conform to the requirements of the Brown Act.
53. Respondent has a ministerial duty to perform according to the laws of the
State of California, including the Brown Act.
54. Respondent has failed and refused to perform its ministerial duties as
required by the Brown Act.
55. Petitioner has a clear, present, and legal right to Respondent's
performance of its ministerial duties, as required by the Brown Act.
56. Respondent has a present legal duty and present ability to perform its
ministerial duties set forth in both the Brown Act.
57. Petitioner has an interest in having the laws executed and public duties
enforced and, therefore, has a beneficial interest in the outcome of the proceedings.
58. Through this action, Petitioner seeks no greater relief that would be
afforeded to any other member of the public.
59. Petitioner has exhausted his administrative remedies.
60. Petitioner has sent a Brown Act Demand to Cure and Correct pursuant to
Government Code 54960.1 and a Demand to Cease and Desist pursuant to
Government Cod 54960.2 (Demand) to the Board.
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VERIFIED PETITION FOR WRIT OF MANDATE


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61. The Board, through its legal counsel, has refused to cure and correct any
of the alleged violations, and has failed to make an unconditional commitment to cease
and desist.
62. The only plain, speedy, and adequate remedy left to Petitioner is the relief
provided by Government Code sections 54960 and 54960.1.

WHEREFORE, PETITIONER PRAYS AS FOLLOWS:

1. For a declaration that Respondent PASADENA AREA COMMUNITY
COLLEGE DISTRICT BOARD OF TRUSTEES violated the Ralph M. Brown Act by:
a. discussing and taking action on Dr. Rochas retirement and severance
without proper notice in violation of Government Code 54952.2(a)(1)
and 54954.2(a)(2);
b. taking action by secret ballot, in violation of Government Code
54953(c);
c. Failing to report action taken to affect the employement status of a public
employee at the meeting where the action was taken in violation of
Government Code 54957.1(a)(5);
d. discussing and taking action on compensation in a closed session to
consider the appointment, employment, evaluation of performance,
discipline, or dismissal of a public employee, in violation of Government
Code 54957(b);
e. failing to take final action on compensation of unrepresented employees
in open session, in violation of Government Code 54957.6(a);
f. routinely holding closed session described as anticipated litigation
without announcing the existing facts and circumstances in violation of
Government Code 54956.9(b)(3)(B);
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VERIFIED PETITION FOR WRIT OF MANDATE


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g. discussing Dr. Roachs retirement and severance compensation during
closed sessions at its July 22, 2014 and August 6, 2014 Board meetings,
noticed as anticipated litigation, where there was no significant
exposure to litigation in violation of Government Code 54962; and,
h. discussing Dr. Roachs retirement and severance compensation during
closed sessions at its July 22, 2014 and August 6, 2014 Board meetings,
and failing to announce the existing facts and circumstances in violation
of Government Code 54956.9(d)(2).

2. To direct that a peremptory writ of mandate issue, ordering Respondent
PASADENA AREA COMMUNITY COLLEGE DISTRICT BOARD OF TRUSTEES to
perform as required by the Brown Act by:
a. only discussing and/or taking action on the matters within the Boards
subject matter jurisdiction where the item appears on a posted agenda
adequately describing subjects to be discussed, including items to be
discussed in closed session;
c. not taking action by secret ballot;
c. reporting action taken to affect the employement status of a public
employee at the meeting where the action was taken;
d. refraining from discussion or action on compensation in a closed session
to consider the appointment, employment, evaluation of performance,
discipline, or dismissal of a public employee;
e. taking final action on compensation of unrepresented employees in open
session,
f. disclosing the facts and circumstances that justify a closed session
regarding threatened or anticipated litigation closed sessions pursuant to
Government Code section 54956.9(d)(2); and,
g. holding closed sessions not specifically authorized by the Brown Act.
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VERIFIED PETITION FOR WRIT OF MANDATE


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3. To direct that a peremptory writ of mandate issue, ordering that the
action taken by Respondent PASADENA AREA COMMUNITY COLLEGE DISTRICT
BOARD OF TRUSTEES to approve any severance payment to Real Party in Interest
DR. MARK W. ROCHA in connection with his retirement is null and void;

4. For an order requiring Real Party in Interest DR. MARK W. ROCHA to
return any and all monies paid to him by the District for severance payment in
connection with his retirement;

5. For an order requiring Respondent PASADENA AREA COMMUNITY
COLLEGE DISTRICT BOARD OF TRUSTEES to produce for in camera review all of
the Boards documents, reports, minutes, transcripts, and tapes of its closed-session
meeting on April 2, 2014, April 30, 2014, May 14, 2014, June 25, 2014, July 16, 2014,
July 22, 2014 and August 6, 2014 to allow the Court to determine whether the Board
held discussions outside the scope of the posted agenda items, discussed topics not
expressly permitted by statute for closed session, took action not formally reported
and/or failed to properly announce facts and circumstances known to potential
plaintiffs;

6. For an order requiring that Respondent PASADENA AREA COMMUNITY
COLLEGE DISTRICT BOARD OF TRUSTEES to tape record its closed sessions for the
periord of three (3) years, and preserve the tape recordings for the period and under the
terms of security and confidentiality the court deems appropriate.

7. That the Petitioner/Plaintiff recover attorneys' fees incurred in this action
pursuant to Government Code Section 6259 and/or Code of Civil Procedure Section
1021.5;

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8. For an award of costs incurred in this action; and

9. For such other and further relief as the court deems just and proper.


DATED: September 25, 2014 LAW OFFICES OF KELLY A. AVILES



Kelly A. Aviles
Attorney for Petitioner


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VERIFIED PETITION FOR WRIT OF MANDATE