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1 <br />2 <br />3 <br />4 <br />5 <br />6 <br />7 <br />8 <br />9 <br />10 <br />11 <br />12 <br />13 <br />14 <br />15 <br />16 <br />17 <br />18 <br />19 <br />20 <br />21 <br />22 <br />23 <br />24 <br />25 <br />26 <br />27 <br />28 <br />C Ali mWsOE E <br />399uMaP1SiRFkT <br />RWEMU4CA91522 <br />(951) 926596) <br />through the governmental department known as the Registrar of Voters, responsible for <br />administering, coordinating and conducting elections within the County, including certifications <br />and elections pertaining to initiatives. <br />9. Plaintiff is informed and believes and based thereon alleges that real parties in <br />interest Defendants Kimberly Thompson ( "Thompson") and Michael Eppolito ( "Eppolito ") <br />(collectively, "Proponents ") are residents of the City and County, and are named as proponents <br />of the initiative. <br />10. The true names of defendants sued herein as DOES 1 through 10, inclusive, are <br />unknown to Plaintiff, who will seek leave of this Court to amend this Complaint when the names <br />of such defendants are ascertained. <br />11. The true names of defendants sued herein as ROES I through 10, inclusive, are <br />unknown to Plaintiff, who will seek leave of this Court to amend this Complaint when the names <br />of such real parties in interest are ascertained. <br />VENUE <br />12. This action is brought by Plaintiff City of Riverside against Riverside County <br />residents and a Riverside County official. As such, venue is proper in the Superior Court of <br />California, County of Riverside. <br />NATURE OF THE ACTION <br />13. The Initiative exceeds the initiative authority of the electorate by attempting to amend <br />local zoning laws in such a manner that they will conflict with federal law, state law, and with <br />other local laws that bar the enactment of any legislation that conflicts with state or federal law. <br />14. A local electorate's right to initiative is "co- extensive with the legislative power of <br />the local governing body." (DeVita v. County, of Napa (1995) 9 Cal.4111763, 775.) "Thus, if the <br />state Legislature has restricted the legislative power of a local governing body, that restriction <br />applies equally to the local electorate's power of initiative." (Mission Springs Water Dist. v. <br />Verjil (2013) 218 Cal.AppAth 892, 920.) <br />/// <br />0 <br />COMPLAINT FOR DECLARATORY RELIEF <br />