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Verified petition for writ of mandate to order compliance with California Public Records Act (December 9, 2015)

Complaint for declaratory relief

Petitioner brings this action to compel La Vonda M-Pearson and the Town of Apple Valley (Respondents) to fully comply with Petitioner’s California Public Records Act request made on August 20, 2015. To date, the Respondents have produced some, but not all of the requested records and have withheld some records without a legal basis to do so. They have also refused to identify the date on which all records will be produced and have produced patently non-responsive records in order to feign compliance.