1 LAW OFFICE OF FELIX TINKOV Felix Tinkov, State Bar No. 234276 2 225 Broadway, Suite 1900 San Diego, CA 92101 3 (619) 862-1761
[email protected] 4 Attorney for Petitioner Voice of San Diego 5 6 7 IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA 8 FOR THE COUNTY OF SAN DIEGO, CENTRAL DIVISION 9 VOICE OF SAN DIEGO, a California CASE NO. 10 corporation, VERIFIED PETITION FOR WRIT OF 11 Petitioner, MANDATE TO COMPEL COMPLIANCE WITH PUBLIC RECORDS ACT; 12 v. COMPLAINT FOR DECLARATORY AND PRELIMINARY AND PERMANENT 13 SAN DIEGO STATE UNIVERSITY; and INJUNCTION DOES 1-10, inclusive, 14 [Cal. Gov. Code §§ 6258 and 6259] Respondents. 15 16 17 18 INTRODUCTION 19 1. This action, brought pursuant to the California Public Records Act (Gov. Code § 6250 et 20 seq.) (“CPRA”) by Petitioner VOICE OF SAN DIEGO (“VOICE”), a news media outlet, challenges 21 the determination of Respondent SAN DIEGO STATE UNIVERSITY (“UNIVERSITY”), a public 22 institution, to withhold public records in its possession or control. 23 2. VOICE submitted seven related categories of CPRA requests to the UNIVERSITY in 24 search of the public institution’s records regarding the financing and development of the former San 25 Diego Chargers football stadium, and adjacent parking lot, site in the Mission Valley community of 26 San Diego, currently owned by the City of San Diego through its Public Utilities Department. A true 27 and correct copy of the CPRA requests made to the UNIVERSITY is attached as Exhibit “A,” wherein 28 each of the seven requests is individually presented as Exhibits “A-1” through “A-7.” 1 VERIFIED PETITION FOR WRIT OF MANDATE; COMPLAINT FOR INJUNCTIVE & DECLARATORY RELIEF 1 3.