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8104863
PETITION FOR WRIT OF MANDATE AND COMPLAINT FOR VIOLATION OF CIVIL RIGHTS
AND DECLARATORY RELIEF
ELKINS
KALT
WEINTRAUB
REUBEN
GARTSIDE LLP 10345 W. Olympic Blvd. Los Angeles, California 90064 Telephone: 310.746.4400 • Facsimile: 310.746.4499
ELKINS KALT WEINTRAUB REUBEN GARTSIDE LLP
JACKSON D. McNEILL, State Bar No. 301606
[email protected]
MARCO A. ORNELAS LOPEZ, State Bar No. 343187
[email protected]
10345 W. Olympic Blvd.
Los Angeles, California 90064
Telephone: 310.746.4400
Facsimile: 310.746.4499
Attorneys for Plaintiff and Petitioner
Focus Line, LLC
SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF LOS ANGELES, CENTRAL DISTRICT
FOCUS LINE, LLC, a California limited
liability company,
Plaintiff and Petitioner,
v.
CITY OF SANTA MONICA, a California
Charter City; and DOES 1-100,
inclusive,
Defendants and
Respondents.
Case No.
VERIFIED PETITION FOR WRIT
OF MANDATE (CCP, § 1085), AND
COMPLAINT FOR VIOLATION OF
CIVIL RIGHTS (42 U.S.C. § 1983,
U.S. Const., amend. XIV) and
DECLARATORY RELIEF (CCP §
1060)
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8104863 2
PETITION FOR WRIT OF MANDATE AND COMPLAINT FOR VIOLATION OF CIVIL RIGHTS
AND DECLARATORY RELIEF
ELKINS
KALT
WEINTRAUB
REUBEN
GARTSIDE LLP 10345 W. Olympic Blvd. Los Angeles, California 90064 Telephone: 310.746.4400 • Facsimile: 310.746.4499 Petitioner and Plaintiff Focus Line, LLC (“Petitioner” or “Focus Line”) hereby alleges as follows:
INTRODUCTION
1. Petitioner seeks a building permit to convert an existing, attached accessory dwelling unit (“ADU”) into additional living space within its existing single-family residence at 1213 Pine Street in Santa Monica, California (“Property”).
2. Respondent and Defendant City of Santa Monica (“City”) does not dispute that an addition to the existing residence of the same size and configuration as the ADU is permissible and would meet all applicable development standards or that the ADU need not be preserved as an ADU.
3. Petitioner applied for a building permit, submitted code-compliant plans, passed plan check, and paid its permit fees, including permit issuance fees.
The City approved the application, collected those fees, and told Petitioner the permit was ready—only to have a senior planning official intervene at the last moment to opine that the project does not qualify as an “addition” because it involves no new physical construction.
4. Based solely on the senior planning official’s unsupported opinion, the City refused to issue the building permit. Instead, the City insists that Petitioner must first demolish the existing, lawfully permitted and fully inspected ADU structure in order to immediately rebuild the same structure from scratch, in the same location, with the same walls and dimensions before the City will recognize the structure as an “addition.”
5. Nothing in the Santa Monica Municipal Code or any other law supports this extraordinary waste of time, money, and resources.
6. This Petition asks the Court to compel the City to do what its own code already requires: issue a building permit allowing Petitioner to convert its existing ADU into additional living space for its existing single-family residence.
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8104863 3
PETITION FOR WRIT OF MANDATE AND COMPLAINT FOR VIOLATION OF CIVIL RIGHTS
AND DECLARATORY RELIEF
ELKINS
KALT
WEINTRAUB
REUBEN
GARTSIDE LLP 10345 W. Olympic Blvd. Los Angeles, California 90064 Telephone: 310.746.4400 • Facsimile: 310.746.4499
PARTIES
7. Petitioner and Plaintiff Focus Line, LLC is a California limited liability company with its principal address in Los Angeles, California. Focus Line owns the real property located at 1213 Pine Street, Santa Monica, California 90405.
8. Respondent and Defendant City of Santa Monica is a California Charter City organized and existing under the laws of the State of California. The City operates and administers a Building and Safety Division responsible for issuing building permits and enforcing the Santa Monica Municipal Code (“SMMC” or “Municipal Code”), including the City’s Zoning Ordinance.
JURISDICTION AND VENUE
9. This Court has jurisdiction over this Petition and Complaint pursuant to Code of Civil Procedure sections 1085 and 1060, and Article VI of the California Constitution.
10. Venue is proper in the Superior Court of Los Angeles County pursuant to Code of Civil Procedure section 394, as the City of Santa Monica is located within the County of Los Angeles.
FACTUAL BACKGROUND
A. The Property and the Certificate of Occupancy.
11. The Property lies within the City’s R1 (Single-Family Residential) zoning district, and the Property is improved with a single-family residence with an attached Accessory Dwelling Unit (“ADU”).
12. The single-family residence and attached ADU at the Property were constructed pursuant to Building Permit No. 19BLD-3695, issued on August 19, 2021.
13. On May 14, 2025, the City’s Building and Safety Division conducted a final inspection of the Property and approved the structure for occupancy. The City’s Building Official issued a Certificate of Occupancy dated June 3, 2025, confirming that the residence and attached ADU had been inspected and approved.
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8104863 4
PETITION FOR WRIT OF MANDATE AND COMPLAINT FOR VIOLATION OF CIVIL RIGHTS
AND DECLARATORY RELIEF
ELKINS
KALT
WEINTRAUB
REUBEN
GARTSIDE LLP 10345 W. Olympic Blvd. Los Angeles, California 90064 Telephone: 310.746.4400 • Facsimile: 310.746.4499 B. The Proposed Conversion and Building Permit Application.
14. On September 16, 2025, Petitioner applied to the City for a building permit (Permit No. 25BLD-3311) to convert the attached ADU into living space constituting an addition to the primary single-family residence (the “Project”).
15. The City’s R1 zoning standards establish a maximum Floor Area Ratio (“FAR”) of 0.45 for new construction on R1 parcels. However, section 9.07.030 and Table 9.07.030 of the City’s Municipal Code provide an enhanced FAR of 0.55 for an “existing structure with addition.” The same section and table further state this provision “[a]pplies to projects that do not result in a demolition as defined in Chapter 9.25, Demolition and Relocation.”
16. As confirmed in communications with senior staff in the City’s Community Development Department, because the Property’s single-family residence received its certificate of occupancy prior to filing the permit application for the addition, it qualified (and continues to qualify) as an “existing structure” for purposes of this provision.
17. The Project does not result in a demolition as defined in Chapter 9.25 of the City’s Municipal Code.
18. The Project complies with the 0.55 FAR standard and all other applicable development standards.
C. The City’s Initial Approval, Fee Collection, and Representations of Imminent Permit Issuance.
19. City Building and Safety Division staff reviewed Petitioner’s application for Building Permit No. 25BLD-3311 that would authorize converting the ADU into the single-family residence as an addition.
20. In late October 2025, the City advised Petitioner that the permit was ready to be issued, subject to paying permit issuance fees. On or about October 29, 2025, the City demanded, received, and accepted final permit issuance fees from Petitioner.
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8104863 5
PETITION FOR WRIT OF MANDATE AND COMPLAINT FOR VIOLATION OF CIVIL RIGHTS
AND DECLARATORY RELIEF
ELKINS
KALT
WEINTRAUB
REUBEN
GARTSIDE LLP 10345 W. Olympic Blvd. Los Angeles, California 90064 Telephone: 310.746.4400 • Facsimile: 310.746.4499
21. The permit would have been issued but for what was described as a technical glitch with the City’s ProjectDox application, which the City uses to process certain permit applications. Prior to that technical issue, City planner Liku Abera had confirmed in writing on October 14, 2025: “I discussed the project with [City Planner] Shira [Moch] and other colleagues, and we confirmed that the change of use of the ADU into the primary home may be treated as an addition to the home.”
22. Petitioner reasonably relied on this confirmation and the City’s representations at substantial cost.
D. Senior City Staff’s Last-Minute Intervention and Refusal to Issue the Permit.
23. On the day the permit was scheduled to be issued, Acting Planning Manager Ross Fehrman intervened and blocked the issuance of Building Permit No. 25BLD-3311. Mr. Fehrman issued plan check comments asserting, among other things, that “[y]our proposed scope of work is not accurate and the work being proposed is not permitted [because] … [y]ou are not proposing a 2nd floor addition.
Instead, you are converting existing square footage that was permitted as an ADU.
Pursuant to SMMC Section 9.07.030, an increased FAR allowance is only for ‘existing structures with addition.’”
24. In a written communication dated November 13, 2025, Mr. Fehrman stated: “Although the municipal code does not have a formal definition of ‘addition,’ the additional Parcel Coverage/FAR for ‘existing structure with addition’ that came out of the 2019 R1 update was adopted with the intent that this additional living space would be through a newly constructed addition and not the conversion of existing space.”
25. In a written communication dated November 24, 2025, Community Development Director Jing Yeo likewise stated that “[f]undamentally, the issue is that what is being proposed is conversion of space as opposed to a new addition.”
26. In other words, the City’s position, as articulated by Mr. Fehrman and DRAFT
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8104863 6
PETITION FOR WRIT OF MANDATE AND COMPLAINT FOR VIOLATION OF CIVIL RIGHTS
AND DECLARATORY RELIEF
ELKINS
KALT
WEINTRAUB
REUBEN
GARTSIDE LLP 10345 W. Olympic Blvd. Los Angeles, California 90064 Telephone: 310.746.4400 • Facsimile: 310.746.4499 Ms. Yeo, is that the conversion of the existing attached ADU into additional square footage of the primary residence does not qualify as an “addition” under the SMMC because it does not involve the physical alteration or new construction of the structure.
27. Instead, Mr. Fehrman stated by email on December 9, 2025, that “[t]he property owner can demolish the ADU and construct an addition to the house.” On January 29, 2026, Mr. Fehrman reiterated that “your client is still required to demolish the ADU and build a new addition if he still wants this additional space to be part of the main house. Conversion in order to achieve this expansion is not permitted.” City Community Development Director Jing Yeo reiterated this position in written communications.
28. Thus, in the City’s view, Petitioner must first demolish the existing, permitted, and fully inspected ADU and then rebuild the exact same structure, in the same location, with the same walls, size, and configuration, in order to qualify it as an “addition.” This demolition would waste resources, generate unnecessary construction waste and environmental impact, and impose an arbitrary and substantial financial penalty on Petitioner without serving any legitimate public purpose.
29. The City has never identified any specific resolution, policy document, staff report, minutes, or other record to support this interpretation of “addition.” The SMMC does not define “addition,” and no provision of the SMMC, City charter, general plan, or any other applicable law prohibits the conversion of an ADU into additional square footage of an existing residence.
E. No Administrative Hearing or Other Administrative Remedy Exists.
30. The permit application is subject to ministerial review. There was no administrative hearing required or available with respect to Permit No. 25BLD-3311, and the City’s refusal to issue Permit No. 25BLD-3311 was not subject to administrative appeal.
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8104863 7
PETITION FOR WRIT OF MANDATE AND COMPLAINT FOR VIOLATION OF CIVIL RIGHTS
AND DECLARATORY RELIEF
ELKINS
KALT
WEINTRAUB
REUBEN
GARTSIDE LLP 10345 W. Olympic Blvd. Los Angeles, California 90064 Telephone: 310.746.4400 • Facsimile: 310.746.4499
31. Petitioner has exhausted all available administrative remedies. Further, Petitioner, through counsel, engaged in extensive pre-litigation correspondence with City Planning staff, including Acting Planning Manager Ross Fehrman and Community Development Director Jing Yeo, seeking reconsideration of the City’s position. The City has confirmed on multiple occasions that its position remains unchanged.
FIRST CAUSE OF ACTION
Petition for Writ of Mandate (Code of Civil Procedure § 1085) (Against Respondent City of Santa Monica)
32. Petitioner re-alleges and incorporates by reference all preceding allegations as if fully set forth herein.
33. Code of Civil Procedure section 1085 authorizes this Court to issue a writ of mandate to compel a public agency or officer to perform an act which the law specially enjoins as a duty resulting from an office, trust, or station, where there is no plain, speedy, and adequate remedy in the ordinary course of law.
34. Petitioner has a beneficial interest in the issuance of Building Permit No. 25BLD-3311. The City has a ministerial, non-discretionary duty to issue a building permit when an application is submitted in compliance with applicable law and all development standards are satisfied. Here, Petitioner’s application complies with all applicable development standards, including the 0.55 FAR standard for an “existing structure with addition” that does not result in a demolition as set forth in SMMC section 9.07.030 and Table 9.07.030.
35. SMMC section 9.07.030 and Table 9.07.030 provides an enhanced 0.55 FAR standard for projects that constitute an “existing structure with addition” and do not result in a “demolition” as defined in Chapter 9.25. The Project meets both criteria: the single-family residence is an existing structure that has received its final inspection, and the Project does not result in a demolition.
36. In effect, the conversion of the attached ADU into additional square DRAFT
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8104863 8
PETITION FOR WRIT OF MANDATE AND COMPLAINT FOR VIOLATION OF CIVIL RIGHTS
AND DECLARATORY RELIEF
ELKINS
KALT
WEINTRAUB
REUBEN
GARTSIDE LLP 10345 W. Olympic Blvd. Los Angeles, California 90064 Telephone: 310.746.4400 • Facsimile: 310.746.4499 footage of the primary residence takes the floor area from the now-eliminated ADU and adds that floor area to the primary residence; this constitutes an “addition” within the ordinary and common meaning of that term.
37. The term “addition” is not defined in the SMMC. No provision of the SMMC, the City’s charter, the California Building Code, or any other applicable law allows the City to require that an “addition” involve the physical alteration of a structure, or that an attached ADU be demolished before its square footage may be incorporated into the primary residence.
38. The City’s interpretation of the applicable law was arbitrary, capricious, and irrational. By not issuing the building permit, the City violated its ministerial, non-discretionary duty to do so and abused its discretion.
39. Petitioner has no plain, speedy, and adequate remedy in the ordinary course of law. Petitioner has been unable to obtain relief through exhaustion of available informal administrative remedies, and no administrative hearing process is available.
40. The building permit application for Building Permit No. 25BLD-3311 remains open and the permit remains capable of being issued.
41. Petitioner is therefore entitled to a writ of mandate compelling the City to process, approve, and issue Building Permit No. 25BLD-3311.
SECOND CAUSE OF ACTION
Declaratory Relief (Code of Civil Procedure § 1060)
(Against Respondent City of Santa Monica)
42. Petitioner re-alleges and incorporates by reference all preceding allegations as if fully set forth herein.
43. An actual and justiciable controversy exists between Petitioner and the City concerning: (a) whether the conversion of the existing attached ADU into additional square footage of the primary residence at the Property constitutes an “addition” within the meaning of SMMC section 9.07.030 and Table 9.07.030; and (b) DRAFT
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8104863 9
PETITION FOR WRIT OF MANDATE AND COMPLAINT FOR VIOLATION OF CIVIL RIGHTS
AND DECLARATORY RELIEF
ELKINS
KALT
WEINTRAUB
REUBEN
GARTSIDE LLP 10345 W. Olympic Blvd. Los Angeles, California 90064 Telephone: 310.746.4400 • Facsimile: 310.746.4499 whether the City is obligated to issue Building Permit No. 25BLD-3311.
44. Petitioner contends that: (a) the conversion of the attached ADU constitutes an “addition” within the ordinary meaning of that term and within the intent of SMMC section 9.07.030 and Table 9.07.030; (b) the Project complies with the 0.55 FAR standard and all other applicable development standards; and (c) no provision of the SMMC or applicable law requires the demolition of the existing ADU as a prerequisite to issuing the permit. The City is therefore obligated to issue Building Permit No. 25BLD-3311.
45. The City contends that the conversion does not qualify as an “addition” under SMMC section 9.07.030 and Table 9.07.030 and that Petitioner must first demolish the ADU and then reconstruct the same structure in the same location before the 0.55 FAR standard may be applied.
46. A judicial declaration is necessary and appropriate to resolve this controversy and to establish the rights and obligations of the parties. Petitioner is entitled to a declaration that: (a) the conversion of the existing attached ADU into additional square footage of the primary residence constitutes an “addition” under SMMC Table 9.07.030; and (b) the City is required to issue Building Permit No. 25BLD-3311.
THIRD CAUSE OF ACTION
Violation of Civil Rights (42 U.S.C. § 1983, U.S. Const., amend. XIV) (Against Respondent City of Santa Monica)
47. Petitioner re-alleges and incorporates by reference all preceding allegations as if fully set forth herein.
48. 42 U.S.C. § 1983 provides that any person who, under color of state law, subjects any citizen of the United States to the deprivation of any rights, privileges, or immunities secured by the Constitution and laws of the United States shall be liable to the party injured in an action at law, suit in equity, or other proper proceeding for redress.
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8104863 10
PETITION FOR WRIT OF MANDATE AND COMPLAINT FOR VIOLATION OF CIVIL RIGHTS
AND DECLARATORY RELIEF
ELKINS
KALT
WEINTRAUB
REUBEN
GARTSIDE LLP 10345 W. Olympic Blvd. Los Angeles, California 90064 Telephone: 310.746.4400 • Facsimile: 310.746.4499
49. At all relevant times, Respondent City of Santa Monica, acting through its Planning Division and Building and Safety Division, acted under color of state law within the meaning of 42 U.S.C. § 1983.
50. At all relevant times, the City of Santa Monica, acting through its employees and representatives, constitutes a “person” for purposes of Section 1983 liability. (Monell v. Dep’t of Social Services (1978) 436 U.S. 658, 694 (“Monell”) [“[M]unicipalities and other local government units . . . [are] among those persons to whom § 1983 applies.”]; see also Bd. of County Comm’rs v. Brown (1997), 520 U.S. 397, 403.)
A. Municipal Liability Under Monell.
51. A municipality is liable under § 1983 where the constitutional deprivation complained of was caused by an official policy, custom, or practice of the municipality, or where the deprivation was caused by the act or decision of an official with final policymaking authority over the subject matter involved. (Monell v. Dep’t of Social Services (1978) 436 U.S. 658, 694 (“Monell”); Pembaur v. City of Cincinnati (1986) 475 U.S. 469, 480–481.)
52. The constitutional deprivations alleged herein were not the unauthorized acts of low-level employees acting outside the scope of their authority.
Rather, the decision to block the issuance of Building Permit No. 25BLD-3311 and to impose the demolition-and-rebuild requirement was made, confirmed, and maintained by officials at the highest levels of the City’s planning apparatus, including Acting Planning Manager Ross Fehrman and Community Development Director Jing Yeo, with the involvement of the City Manager’s office.
53. Ms. Yeo, as the City’s chief planning official, is a final policymaker with respect to the interpretation and application of the City’s zoning ordinance, including SMMC Table 9.07.030. (See SMMC § 9.37.140 [giving the Community Development Director the power to “interpret the relevant provision of the General Plan, Specific Plan, or Zoning Ordinance” subject to confirmation by the Planning Commission].) DRAFT
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8104863 11
PETITION FOR WRIT OF MANDATE AND COMPLAINT FOR VIOLATION OF CIVIL RIGHTS
AND DECLARATORY RELIEF
ELKINS
KALT
WEINTRAUB
REUBEN
GARTSIDE LLP 10345 W. Olympic Blvd. Los Angeles, California 90064 Telephone: 310.746.4400 • Facsimile: 310.746.4499 Her written communication on November 24, 2025, stating that “[f]undamentally, the issue is that what is being proposed is conversion of space as opposed to a new addition,” as well as her confirmation on March 9, 2026 that the City’s position was unchanged and would not be reconsidered, among other written and oral communications, constitute an official policy decision of the City of Santa Monica for purposes of Monell liability.
54. This decision constitutes the “moving force” behind the constitutional violation because it caused the building permit not to be issued. (See Monell, supra, 436 U.S. 658, 694; Polk County v. Dodson (1981) 454 U.S. 312, 326.) B. Substantive Due Process.
55. The Fourteenth Amendment to the United States Constitution prohibits governmental action that is arbitrary, capricious, or irrational and that deprives a person of a protected property interest without substantive due process of law. The Supreme Court established nearly a century ago that zoning regulations and their application are subject to substantive due process review, and that a zoning measure, however facially neutral, may be found unconstitutional as applied to specific premises or particular conditions where it is clearly arbitrary and unreasonable, having no substantial relation to the public health, safety, morals, or general welfare. (Village of Euclid, Ohio v. Ambler Realty Co. (1926) 272 U.S. 365, 395.) Critically, Euclid recognized that even a zoning scheme valid on its face may yield unconstitutional applications: “if ever the provisions set forth in the ordinance . . . come to be concretely applied to particular premises . . . or to particular conditions, or to be considered in connection with specific complaints, some of them, or even many of them, may be found to be clearly arbitrary and unreasonable.” (Ibid.) This is precisely such a case.
56. Here, Petitioner has a cognizable and protected property interest in the development and use of its real property at 1213 Pine Street in accordance with applicable law, and in the issuance of a building permit for the conversion of the DRAFT
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8104863 12
PETITION FOR WRIT OF MANDATE AND COMPLAINT FOR VIOLATION OF CIVIL RIGHTS
AND DECLARATORY RELIEF
ELKINS
KALT
WEINTRAUB
REUBEN
GARTSIDE LLP 10345 W. Olympic Blvd. Los Angeles, California 90064 Telephone: 310.746.4400 • Facsimile: 310.746.4499 ADU into an addition, to which it is entitled under the SMMC. Petitioner has a legitimate claim of entitlement to the building permit because the City lacks all discretion to deny issuance of the permit or withhold its approval. (Breneric Associates v. City of Del Mar (1998) 69 Cal.App.4th 166, 183; see also Galland v. City of Clovis (2001) 24 Cal.4th 1003, 1035 [noting “series of cases … that find substantive due process violations when municipalities refuse to issue nondiscretionary building permits”].) That protected interest is further grounded in the City’s approval of Petitioner’s application, its collection of final permit issuance fees, and its repeated representations that the permit was ready to be issued and would be issued, all of which gave rise to a legitimate claim of entitlement to the permit.
57. At the same time, no cognizable public benefit under the public health, safety, morals, or general welfare is served by compelling the destruction and reconstruction of an identical structure. The City’s refusal to issue Building Permit No. 25BLD-3311, and its imposition of a demolition-and-rebuild requirement that has no basis in the text of the SMMC or any other applicable law, constitutes arbitrary and irrational governmental action that is clearly arbitrary and unreasonable within the meaning of Euclid.
58. Accordingly, the City’s actions occurred under the color of state law and deprived Petitioner of rights secured by the Fourteenth Amendment of the U.S.
Constitution.
C. Damages.
59. As a direct and proximate result of the City’s violations of Petitioner’s rights under the Fourteenth Amendment to the United States Constitution, as alleged herein, Petitioner has suffered and continues to suffer damages including but not limited to permit and application fees paid to the City; financing and maintenance costs, property taxes and insurance premiums on the Property; costs incurred in reliance on the City’s representations that the permit would be issued; lost economic opportunity; and other economic harm in amounts to be proven at trial.
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8104863 13
PETITION FOR WRIT OF MANDATE AND COMPLAINT FOR VIOLATION OF CIVIL RIGHTS
AND DECLARATORY RELIEF
ELKINS
KALT
WEINTRAUB
REUBEN
GARTSIDE LLP 10345 W. Olympic Blvd. Los Angeles, California 90064 Telephone: 310.746.4400 • Facsimile: 310.746.4499
60. Petitioner is further entitled to an award of reasonable attorneys’ fees pursuant to 42 U.S.C. § 1988 as the prevailing party in a civil rights action.
PRAYER FOR RELIEF
WHEREFORE, Focus Line prays for relief as follows:
1. For a Writ of Mandate pursuant to Code of Civil Procedure section 1085, compelling Respondent City of Santa Monica to process, approve, and issue Building Permit No. 25BLD-3311 without requiring the demolition of the existing attached ADU;
2. For a judicial declaration, pursuant to Code of Civil Procedure section 1060, that: (a) the conversion of the existing attached ADU at 1213 Pine Street into additional square footage of the primary residence constitutes an “addition” within the meaning of SMMC Table 9.07.030; (b) the City is required to issue Building Permit No. 25BLD-3311;
3. For a judicial declaration that the City’s interpretation and application of SMMC Table 9.07.030 to require the demolition and reconstruction of the existing attached ADU as a prerequisite to permit issuance is arbitrary, unreasonable, and without substantial relation to the public health, safety, morals, or general welfare in violation of the substantive due process guarantees of the Fourteenth Amendment to the United States Constitution;
4. For damages against Respondent City of Santa Monica pursuant to 42 U.S.C. § 1983 for violation of Petitioner’s rights under the Fourteenth Amendment to the United States Constitution in amounts to be proven at trial;
5. For an award of reasonable attorneys’ fees pursuant to 42 U.S.C. § 1988 as the prevailing party in a civil rights action brought under 42 U.S.C. § 1983;
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8104863 14
PETITION FOR WRIT OF MANDATE AND COMPLAINT FOR VIOLATION OF CIVIL RIGHTS
AND DECLARATORY RELIEF
ELKINS
KALT
WEINTRAUB
REUBEN
GARTSIDE LLP 10345 W. Olympic Blvd. Los Angeles, California 90064 Telephone: 310.746.4400 • Facsimile: 310.746.4499
6. For an award of reasonable attorneys’ fees and costs of suit to the extent permitted by any other applicable law, including pursuant to Code of Civil Procedure section 1021.5;
7. For all costs of suit incurred herein; and
8. For such other and further relief as this Court deems just and proper.
DATED: April 21, 2026 ELKINS KALT WEINTRAUB REUBEN
GARTSIDE LLP
By:
JACKSON D. McNEILL
Attorneys for Plaintiff Focus Line, LLC
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8104863 15
PETITION FOR WRIT OF MANDATE AND COMPLAINT FOR VIOLATION OF CIVIL RIGHTS
AND DECLARATORY RELIEF
ELKINS
KALT
WEINTRAUB
REUBEN
GARTSIDE LLP
10345 W. Olympic Blvd.
Los Angeles, California 90064
Telephone: 310.746.4400 • Facsimile: 310.746.4499
VERIFICATION
I have read the foregoing VERIFIED PETITION FOR WRIT OF MANDATE (CCP, § 1085), AND COMPLAINT FOR VIOLATION OF CIVIL RIGHTS (42 U.S.C. § 1983, U.S. Const., amend. XIV) and DECLARATORY RELIEF (CCP § 1060) and know its contents.
I am the Managing Member of Focus Line, LLC, the Plaintiff/Petitioner in this action, and am authorized to make this verification for and on its behalf, and I make this verification for that reason. I am informed and believe and on that ground allege that the matters stated in the foregoing document are true.
I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct.
Executed on April 20, 2026.
Farhad Larian
Print Name of Signatory Signature
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