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SUPERIOR COURT OF THE STATE OF CALIFORNIA

IN AND FOR THE COUNTY OF SACRAMENTO

10 NATIONAL CONFERENCE OF BLACK


MAYORS, a Georgia not-for-profit corporation;
11 SACRAMENTO MAYOR KEVIN M.
JOHNSON, in his official capacity as the former
12 President of the National Conference of
Black Mayors; and EDWIN K. PALMER, in
13 his official capacity as Chapter 7 Trustee for
the National Conference of Black Mayors,
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Petitioners,
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v.
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CITY OF SACRAMENTO;
17 SACRAMENTO CITY ATTORNEYS OFFICE;
CHICO COMMUNITY PUBLISHING, INC.
18 a/k/a SACRAMENTO NEWS & REVIEW,
a California corporation; and DOES 1 through 20
19 inclusive.
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Case No. _________________


[PROPOSED] PEREMPTORY WRIT
OF MANDATE

Respondents.

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[PROPOSED] PEREMPTORY WRIT OF MANDATE

This matter is before the Court on Petitioners Verified Petition for Peremptory Writ

2 of Mandate filed on July 1, 2015 (the Petition). The Court, having fully considered the
3 Petition and all papers, evidence, and argument presented by counsel in connection therewith,
4 and being otherwise fully advised in the premises, hereby enters this Peremptory Writ of
5 Mandate and ORDERS as follows:
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1.

The City of Sacramento and its officers, agents, employees and all other persons

7 acting on its behalf, including the City Attorneys Office (collectively, the City), are hereby
8 commanded, with respect to records otherwise discoverable pursuant to a request made by the
9 Sacramento News & Review under the California Public Records Act (the City Records),
10 not to release or disclose to the Sacramento News & Review or to any other person or entity any
11 e-mails, correspondence, communications, records, or any other materials of any kind that are
12 protected from disclosure by the attorney-client and work product privileges and which have
13 been sent or received by: (i) the National Conference of Black Mayors (NCBM); (ii) the office
14 of Sacramento Mayor Kevin M. Johnson acting in his official capacity as the former President of
15 the NCBM (President Johnson); (iii) Edwin K. Palmer, in his official capacity as Chapter 7
16 Trustee for the NCBM (Trustee Palmer); and (iv) Ballard Spahr LLP, acting in its capacity as
17 counsel for the NCBM, President Johnson, and/or Trustee Palmer (the Privileged
18 Communications).
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2.

Prior to the release or disclosure of any City Records, the City shall make

20 available, on a confidential basis, all such City Records to Ballard Spahr LLP, who shall be
21 permitted to present its views to the City concerning such City Records so that no Privileged
22 Communications are inadvertently disclosed.
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24 IT IS SO ORDERED
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DATED: _____________

BY: _____________________________
Hon. Superior Court Judge

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[PROPOSED] PEREMPTORY WRIT OF MANDATE

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