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BRIGGS LAW CORPORATION [FILE: 1593.19]
Cory J. Briggs (State Bar no. 176284)
Anthony N. Kim (State Bar no. 283353)
Kelly E. Mourning (State Bar no. 299721)
99 East "C" Street, Suite 111
Upland, CA 91786
Telephone: 909-949-7115
Fax: 909-949-7121

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Attorneys for Plaintiff San Diegans for Open Government
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SUPERIOR COURT OF THE STATE OF CALIFORNIA
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COUNTY OF SAN DIEGO--CENTRAL DIVISION,
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SAN DIEGANS FOR OPEN GOVERNMENT,

) CASE NO. 37-2013-00052721-CU-MC-CTL

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Plaintiff,

PLAINTIFF SAN DIEGANS FOR OPEN
GOVERNMENT'S NOTICE OF
vs.
') INABILITY TO PAY
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CITY OF SAN DIEGO; and DOES 1 through 1,000,) Complaint Filed:
June 12, 2013
C-71 (Prager)
Department:
Defendants.

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TO THE COURT AND ALL PARTIES AND THEIR ATTORNEYS:

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PLEASE TAKE NOTICE that Plaintiff San Diegans for Open Government, a non-profit

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corporation, does not have the financial resources to make the $6,000.00 payment required by the Court

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as a condition to its granting of Plaintiffs motion for leave to amend its operative pleading. Plaintiffs

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inability to pay was unknown by the undersigned at the time oflast week's hearing on the motion.

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Date: May 5, 2015.

Respectfully submitted,
BRIGGS LAW CORPORATION

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By:

.............::

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Plaintiff San

Diegans

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Kelly E. Mourning

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Attorneys for
Government

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for

Open

 PROOF OF SERVICE
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My name is Janna F_errarq___________ . I am over the age of eighteen. I am employed in the
State of California, County of _san Diegq_ _ _ _ _ _ .

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My_/_ business _ _ residence address is Br~Law C...Q_ffioration - - - - - - - - - - - - - - - - - ~J~~~reQ~»1Y~~Ji~iteJ]J~Sa~_D~~CA~111Q_ ____________________________________ j __ .

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On _______________1\:l!!YJ!.., J.!lJ~----' I served ___ an original copy _L_a true and correct copy of the

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,

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following documents:_rtalu.tiff S!!nJ!L~...IlS_fu.LO.P~~-G..!l_V~.mmg_nt'~.N!!.ti~g_ ofJ.PJI.lllliW!!..f..:nc___ j _
___________________________________________________________________ _l__
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====================== -=============================-r=
4.

I served the documents on the person(s) identified on the attached mailing/service list as follows:

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__ by personal service. I personally delivered the documents to the person(s) at the address(es) indicated on the
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list.

by U.S. mail. I sealed the documents in an envelope or package addressed to the person(s) at the address(es)
indicated on the list, with first-class postage fully prepaid, and then I
_deposited the envelope/package with the U.S. Postal Service
__ placed the envelope/package in a box for outgoing mail in accordance with my office's ordinary
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practices for collecting and processing outgoing mail, with which I am readily familiar. On the same
day that mail is placed in the box for outgoing mail, it is deposited in the ordinary course ofbusihess

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with the U.S. Postal Service.

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I am a resident of or employed in the county where the mailing occurred. The mailing occurred in the ci\Y of
_________S_a.P_Di~, California.
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___ by overnight delivery. I sealed the documents in an envelope/package provided by an overnight-delivery
service and addressed to the person(s) ~t the address(es) indicated on the list, and then I placedl the
envelope/package for collection and overnight deli very in the service's box regularly utilized for receiving items
for overnight delivery or at the service's office where such items are accepted for overnight delivery.

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__ by facsimile transmission. Based on an agreement of the parties or a court order, I sent the documents to the
person(s) at the fax number(s) shown on the list. Afterward, the fax machine from which the documents .t.ere
sent reported that they were sent successfully.

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_,(_ by e-mail delivery. Based on the parties' agreement or a court order or rule, I sent the documents to the person(s)
at the e-mail address(es) shown on the list. I did not receive, within a reasonable period of time afterward! any
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electronic message or other indication that the transmission was unsuccessful.
I declare under penalty of perjury under the laws _ _ of the United States
that the foregoing is true and correct.
Date: __________1Yiay_6_,

J]J.S____

of the State of California

 SERVICE LIST

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San Diegans for Open Government v. City of San Diego, et al.
San Diego County Superior Court Case No.: 37-2013-00052721-CU-MC-CTL

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Jan I. Goldsmith
Daniel F. Bamberg
Carmen A. Brock
Office of the City Attorney
1200 Third Avenue, Suite 1100
San Diego, CA 92101-4100
cbrock@sandiego.gov

Attorneys for Defendant City of San
Diego

Michael G. Colantuono
Jennifer L. Pancake
Ryan T. Dunn
Colantuono, Highsmith & ~hatley, PC
300 South Grand Avenue, Suite 2700
Los Angeles, CA 90071
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· ancake chwlaw.us
rdunn schlaw.us

Attorneys for Defendant City of San
Diego