I Drew J. Couto, SBN 100 couto&associates 2 755 West A Street Suite 100 3 San Diego, California 92101 Telephone No. (858) 354-3739 4 Email:
[email protected] Attorney for Petitioner, Jerry Hollendorfer 5 6 7 SUPERIOR COURT OF THE STATE OF CALIFORNIA 8 FOR THE COUNTY OF -SAN DIEGO- 9 10 37-2020-0001 6369-CU-VVM-CTL JERRY HOLLENDORFER, CASE NO. 11 Petitioner, 12 VERIFIED PETITION FOR WRIT OF MANDATE AND DAMAGES 13 CALIFORNIA HORSE RACING BOARD, 1. PETITION FOR WRIT OF MANDATE 14 Respondent. AND DAMAGES (Code of Civil 15 Procedure, 01085 and 1095) 16 2. PETITION FOR WRIT OF MANDATE 17 AND DAMAGES (Code of Civil Procedure, §§1094.5 and 1095) 18 3. STATUTORY VIOLATION (Government 19 Code, §815.6) 20 21 22 Petitioner, Jerry Hollendorfer, by way of this Petition for Writ of Mandate and Damages, 23 through his attorney of record, based on information and belief, alleges as follows: 24 THE PARTIES 25 1. PETITIONER, Jerry Hollendorfer (hereinafter "Petitioner" or "Hollendorfer"), at all 26 times mentioned herein, was and is an individual residing in the City of Point Richmond, County of 27 Alameda, State of California. 28 2. RESPONDENT, California Horse Racing Board (hereinafter "CHRB") is, and at all 1 VERIFIED PETITION FOR WRIT OF MANDATE AND DAMAGES 1 times herein mentioned•0as, an agency of the State of California and•epartment of the Business, 2 Consumer Services and Housing Agency, which conducts business throughout the State including, but 3 not limited to, within the City of Del Mar, County of San Diego.