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1 <br />2 <br />3 <br />4 <br />5 <br />6 <br />7 <br />S <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 />CM AiroWWS OMF <br />39DOMAWSMff <br />RWEMME�CA925n <br />(951 ) 626-5561 <br />32. Plaintiff is informed and believes and based thereon alleges that real parties in <br />interest, Proponents, dispute these contentions and contend that: <br />a. The Initiative is valid and permissible under California and local law, and <br />b. Plaintiff and the Registrar of Voters are required to continue with all necessary <br />acts to ensure that the Initiative, if it receives sufficient signatures to otherwise <br />qualify for the ballot, is submitted to the voters in accordance with the pertinent <br />Elections Code provisions. <br />33. Plaintiff desires a judicial determination of its rights and duties and a declaration <br />regarding whether the Initiative and any measure based thereon is impermissible under <br />California law for the foregoing reasons and therefore outside the power of Plaintiff s electorate <br />to adopt, and that, if so, Plaintiff and the Registrar of Voters need not include the Initiative on the <br />ballot in comtection with an election. <br />WHEREFORE, Plaintiff prays: <br />1. For a judicial declaration: <br />a. That the Initiative is impermissible for the foregoing reasons; <br />b. That the Initiative is beyond the power of Plaintiff's electorate to adopt; <br />c. That Plaintiff and the Registrar of Voters are relieved of any duty to further <br />process the Initiative in connection with any future election; and <br />d. That no additional public funds should be expended to process the Initiative. <br />2. For costs of suit herein incurred; and <br />3. For such other and further relief as the Court may deem proper. <br />DATED: June 3, 2014 GREGORY P. PRIAMOS, City Attorney <br />JAMES E. BROWN, Supervising Deputy City Attorney <br />NEIL OKAZAKI, Deputy City Attorney <br />BY, Nt'"i (1/ v--- <br />GREGORY P. PRIAMOS <br />NEIL OKAZAKI <br />Attorneys for Plaintiff, CITY OF RIVERSIDE <br />CA #L]3 -0454 <br />OACywm\W PDocs\D039M 19100201720.docx <br />-9- <br />COMPLATNTFOR DECLARATORY RFLIFF <br />