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LATHAM & WATKINS LLP Michael G. Romey (Bar No. 137993)

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LATHAM & WATKINS LLP Michael G. Romey (Bar No. 137993) Case 2:20-cv-08896 Document 1 Filed 09/28/20 Page 1 of 46 Page ID #:1 1 LATHAM & WATKINS LLP Michael G. Romey (Bar No. 137993) 2 [email protected] Sarah F. Mitchell (Bar No. 308467) 3 [email protected] 355 South Grand Avenue, Suite 100 4 Los Angeles, California 90071-1560 Telephone: +1.213.485.1234 5 Facsimile: +1.213.891.8763 6 Richard P. Bress (pro hac vice forthcoming) [email protected] 7 Andrew D. Prins (pro hac vice forthcoming) [email protected] 8 Eric J. Konopka (pro hac vice forthcoming) [email protected] 9 555 Eleventh Street, NW, Suite 1000 Washington, D.C. 20004-1304 10 Telephone: +1.202.637.2200 Facsimile: +1.202.637.2201 11 Attorneys for Plaintiffs and the Proposed Class 12 UNITED STATES DISTRICT COURT 13 CENTRAL DISTRICT OF CALIFORNIA 14 15 MY DREAM BOUTIQUE, a CASE NO. 2:20-cv-8896 16 California corporation, on behalf of itself and all others similarly situated; CLASS ACTION COMPLAINT 17 ANAHIT KHACHATRYAN, an individual; NELLI VIRABYAN, an 18 individual; DI ORO SALON, INC., a California corporation, on behalf of 19 itself and all others similarly situated; VARDGES AVETISYAN, an 20 individual; AL-AZIM INC., a California corporation, on behalf of 21 itself and all others similarly situated; RIAZ MOHAMMED, an individual; 22 WESTFIELD PROPERTY MANAGEMENT LLC, a Delaware 23 limited liability company; WESTFIELD TOPANGA OWNER 24 LLC, a Delaware limited liability company; SHERMAN OAKS 25 FASHION ASSOCIATES, LP, a Delaware limited liability partnership; 26 CULVER CITY MALL LLC, a Delaware limited liability company; 27 SANTA ANITA SHOPPINGTOWN 28 LP, a Delaware limited liability ATTORNEYS AT L AW CLASS ACTION COMPLAINT LOS ANGELES Case 2:20-cv-08896 Document 1 Filed 09/28/20 Page 2 of 46 Page ID #:2 1 partnership; and VALENCIA TOWN CENTER VENTURE, L.P., a Delaware 2 limited liability partnership, 3 Plaintiffs, 4 v. 5 COUNTY OF LOS ANGELES; COUNTY OF LOS ANGELES 6 BOARD OF SUPERVISORS; DR. MUNTU DAVIS, individually and 7 in his official capacity as County of Los Angeles Health Officer; 8 DR. BARBARA FERRER, in her official capacity as Director, County of 9 Los Angeles Department of Public Health; and ALEX VILLANUEVA, in 10 his official capacity as Sheriff, County of Los Angeles, 11 Defendants. 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 2 CLASS ACTION COMPLAINT ATTORNEYS AT L AW LOS ANGELES Case 2:20-cv-08896 Document 1 Filed 09/28/20 Page 3 of 46 Page ID #:3 1 Plaintiffs My Dream Boutique, a California corporation (“My Dream 2 Boutique”), on behalf of itself and all others similarly situated; Anahit Khachatryan 3 (“Ms. Khachatryan”); Nelli Virabyan (“Ms. Virabyan”); Di Oro Salon, Inc. (“Salon 4 Dioro”), on behalf of itself and all others similarly situated; Vardges Avetisyan (“Mr. 5 Avetisyan”); Al-Azim Inc. (“Al-Azim”), on behalf of itself and all others similarly 6 situated; Riaz Mohammed (“Mr. Mohammed”); Westfield Property Management 7 LLC (“Westfield”); Westfield Topanga Owner LLC; Sherman Oaks Fashion 8 Associates, LP; Culver City Mall LLC; Santa Anita Shoppingtown LP; and Valencia 9 Town Center Venture, L.P. (collectively, “Plaintiffs”) allege as follows against 10 Defendants County of Los Angeles (the “County”); County of Los Angeles Board 11 of Supervisors (the “Board”); Dr. Muntu Davis, individually and in his official 12 capacity as County of Los Angeles Health Officer (“Dr. Davis”); Dr. Barbara Ferrer, 13 in her official capacity as Director, County of Los Angeles Department of Public 14 Health; and Alex Villanueva, in his official capacity as Sheriff, County of Los 15 Angeles (collectively, “Defendants”): 16 PRELIMINARY STATEMENT 17 1. This case is about unlawful and unjustifiable action by the County and 18 its officials, ostensibly in the name of protecting public health, that in fact has 19 absolutely no public health justification. Defendants have forced hundreds of 20 businesses in indoor malls to close, kept thousands of County residents out of work, 21 caused millions of dollars in lost wages and revenue, and brought many businesses 22 to the brink of collapse—without offering a single valid, science- or health-based 23 reason for their actions, and despite the extensive measures indoor malls and their 24 tenants have taken to protect employees and customers. In doing so, the County and 25 its officials have overtly discriminated against businesses in indoor malls and their 26 employees without any rational basis whatsoever, trampling the constitutional rights 27 of those businesses and individuals. Plaintiffs bring this lawsuit to stop Defendants’ 28 unconstitutional conduct and the massive, irreparable harms Defendants are ATTORNEYS AT L AW CLASS ACTION COMPLAINT LOS ANGELES 3 Case 2:20-cv-08896 Document 1 Filed 09/28/20 Page 4 of 46 Page ID #:4 1 inflicting on Plaintiffs, other indoor mall businesses in the County, and their 2 employees. 3 2. At the beginning of the COVID-19 pandemic, government officials 4 closed businesses on a dramatic and unprecedented scale, attempting to minimize 5 the spread of the disease at a time they knew little about it. Over the past six months, 6 much has been learned about COVID-19, how it spreads, and how that spread can 7 be minimized or prevented. As a result, federal, state, and local officials have 8 regularly revised their guidance, recognizing that many activities—including 9 commercial activities—can be done safely, especially if employees and customers 10 take sensible and effective precautions, such as maintaining social distance and 11 wearing masks. When Plaintiffs were permitted to reopen for a short period this 12 summer, they took these precautions and more to protect employees and customers. 13 For example, My Dream Boutique (operating a children’s clothing store in Fashion 14 Square), Salon Dioro (operating a hair salon in Fashion Square), and Al-Azim 15 (operating the Metropolis Big & Tall men’s clothing store in Westfield Culver City) 16 each posted signs regarding social distancing, restricted the capacity of the store, 17 required face masks, offered hand sanitizer, implemented extensive cleaning 18 protocols, and kept the entrance open whenever the store was open. 19 3. The County has generally deferred to the State of California with 20 respect to business closures and reopenings. Over the summer, the County allowed 21 Plaintiffs and other businesses to reopen after the State changed its guidance, and 22 backtracked when the State backtracked. 23 4. On August 28, 2020, after extensive review of the relevant data and 24 science, the California Department of Public Health issued a statewide order 25 allowing counties throughout the State to reopen indoor malls and shopping centers 26 subject to sensible and effective restrictions, including 25% maximum capacity, 27 closed common areas, and closed food courts in counties where COVID-19 is 28 ATTORNEYS AT L AW CLASS ACTION COMPLAINT LOS ANGELES 4 Case 2:20-cv-08896 Document 1 Filed 09/28/20 Page 5 of 46 Page ID #:5 1 deemed “widespread.”1 That action is consistent with the actions of state and local 2 governments nationwide. And today, nearly every county has implemented the 3 State’s measured, evidence-based approach, and allowed indoor malls and shopping 4 centers to reopen. Indeed, Orange and San Bernardino Counties, which border Los 5 Angeles County, allowed indoor malls and shopping centers to reopen just days after 6 the August 28 order—and counties with uniformly worse metrics regarding the 7 spread of COVID-19 have done the same. Plaintiffs would reopen their indoor malls 8 and businesses subject to the restrictions put in place by the State. 9 5. Plaintiffs cannot reopen, however, because the County has refused to 10 follow the State’s science-based approach. On September 2, 2020, Dr. Davis, the 11 County of Los Angeles Health Officer, ordered that, in this County, all indoor 12 portions and operations of indoor malls and shopping centers must “remain closed 13 to the public until further notice.”2 That action breaks sharply from the County’s 14 previous practice of aligning its business restrictions with those imposed by the 15 State—as one member of the Board recently recognized.3 The County’s forced 16 closure of indoor malls and shopping centers stands in stark contrast to its treatment 17 18 1 See Exhibit 1, California Department of Public Health, Statewide Public Health Officer Order (Aug. 28, 2020), available at https://www.cdph.ca.gov/Programs/ 19 CID/DCDC/CDPH%20Document%20Library/COVID-19/8-28-20_Order-Plan- Reducing-COVID19-Adjusting-Permitted-Sectors-Signed.pdf. 20 2 See County of Los Angeles Department of Public Health, Order of the Health 21 Officer, Reopening Safer at Work and in the Community for Control of COVID-19 (revised Sept. 2, 2020), available at http://publichealth.lacounty.gov/media/ 22 coronavirus/docs/HOO/2020_09_02_HOO_Safer_at_Home.pdf. The most recent County Order of the Health Officer was issued on September 4 with minor changes, 23 and no changes to the County’s restrictions on indoor malls and shopping centers. See Exhibit 2, County of Los Angeles Department of Public Health, Order of the 24 Health Officer, Reopening Safer at Work and in the Community for Control of COVID-19 (revised Sept. 4, 2020), available at http://publichealth.lacounty.gov 25 /media/Coronavirus /docs/HOO/2020_09_04_HOO_Safer_at_Home.pdf. 3 See, e.g., Board of Supervisors Meeting, at 2:24:55 (Sept. 15, 2020) (statement of 26 Supervisor Barger) (“Early on, this Board agreed to align ourselves with the State, and somewhere along the way . we deviated from that. There are areas where 27 we have been given the green light, such as the indoor malls, but we have decided .
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