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MATTHEW S. PAPPAS (SBN: 171860) 426 Atlantic # 12 Long Beach, CA 90802 Phone (562) 464-8922 Facsimile: (949) 242-2605 E- Mad. malLpappas@mattpappaslaw.com Sher,; R. Carter

By Cristina 5 Attorney for Plaintiff

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SUPERIOR COlJRT OF THE STATE OF CALIFORNIA

COUNTY OF LOS ANGELES, CENTRAL DISTRICT

MA TTHEW PAPPAS, an individual,

Plamtiff,

CHARLES PARKIN, an individual; LONG BEACH POLICE OFFICERS

No.:

VERIFIED COMPLAINT fOR INJUNCTIVE RELlEF PURSUANT TO CA. ELEe. CODE 18350

16 ASSOCIATION; STEVE JAMES, an individual; AFL-CIO; and DOES 1 TO 20, 17 inclusive,

18 Defendants.

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2 J PARTlES 22 1. At all times mentioned herein, Plaintiff Matthew Pappas was and is a

23 resident of Long Beach, California and is a candidate for the ejected office of Long 24 Beach City Attorney.

2S 2 Defendant Charles Parkin is an individual who resides in Long Beach,

26 Caljfornia and is also a candidate for the elected office of Long Beach City Attorney 27 /1

28 /1

(O\'l!"!.AI'lT FOR l;-iJI.\i("rn r: HE1.IEF

3. election for City Attorney WI II held on '18,

2 14.

3 4. Long Beach Officer Association (LBPOA) lS an 4 association that endorsed Parkin m the election. The has fonned an

5 independent ,.","~J"'I1UJ supporting AFL-CrO IS an

the 2014

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7 independent

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lO Defendants

1 1 therefore sues

12 to amend

of unknown that has fonned an

supporting Parkin 2014 election.

Steve James is aD mdIvldual and is of the

IS presently unaware of the true names and capacities of

as DOES j 20, inclUSive,

Defendants fictitious names to set true names

Dejendanl{,

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Parkin to Attorney for of 's term to give a

"leg up" in the

3 27 statement by the thar Parkin should "re-elected"

4 Attomey when Parkin has never been to that position impJ

Election Code,

that Parkin is an

5 incumbent and

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7 Arromey

8 incumbent

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section! 8350

statement by

Parkin has never

section l83

10 that Parkin should

to (hat the Election

''Ie-elected''

(hat IS an

statement by Parkin on his campaign Website rendered in bold print

10 emphasis that Parkin is the inc

11 Election

City Attorney section 18350 of

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13 dealers and

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15 from

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18 violation

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23 injunction 24 Code;

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26 refac(

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28 provlslOns of

statement by that Parkm

is false and J8350(b) all of the each of the must be

to violate section 1 of the Ejections Code, all of the reasons, each of the should be

to retract and the statements made by In

18350 of the Code

PRA YER FOR RELIEF

RE, Plaintiff for relief as fol

a order, injunction, and prohibiting the from 18350

the Court of the Defendants to publlcaUy reSCind and

made by that violate section I 50 of the Elections

this Court Plaintiff reasonable attomeys' fees costs under

Civil Code:

CO:\I?LAIYI H)R I:"JI",f '[ IV!; I{tLlLI' ~

4. Court award such additional or alternative

2 proper, and

3 DATED: March 18,2014

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Attorney for Plaintiff

CO~IPLAL'

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VERJFICA TION (CCP 446, 20] 5,5)

4 STA TE OF CALIFORNIA, County of Los Angeles:

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J, MATTHEW PAPPAS, am the Plaintiff in the above-entitled action or proceeding and ] have read the foregOing VERIFIED COMPLAINT FOR INJtl NCTIVE: RELIEF and know the contents thereof, and I certify that the same is true and correct of my own knowledge, except as to those matters specific as to one of the

9 declarations included therewith or which are stated upon my mformation and beilef, and

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as to those matters and any other legal in nature I believe them to be true and correct

EXECUTED TH1S 18th day of March, 2014 at Long Beach, California, United States of America.

I declare under penalty of perjwy under the Jaws of the State of California that the foregoing is true and correct.

MATtHEW PAPPAS

V E R { I, J C i\ 'r ION 7

Section of Long Beach Police Officer's Association Election Mail r from February, 2014.

EXHIBI 1

Long Beach Register Endorses Charles Parkin lfles Parkin I City All .. hup:Jlwww.parkinci me y.com/looL beach_register _ endorsc~ _ cbarl"

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OffiCIAL CAMPAIGN SITE

2014 -lOME i ABOUT CITY ATIORNEY MEDIA ENDORSEMENTS EVENTS DONATE VOLUNTEER HOme ~ Media -

Long Beach Register Endorses Charles Parkin Posted by Admin 5pEXHIBIT 2 3117/20148;56 PM

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3 I, Lawrence King, declare as follows:

4 1. J am a of Beach, ifornia am a registered voter.

5 On March 1 J, 2014, l .. ",n, .. " .. ",.' a telephone call from a person identifying

6 themselves as a representative the AFL-CTO calling 2014 Beach

7 Municipa.l election.

8 3. During , [he '"''''''-''''''..., asked me if r was voting to re-elect Charles

9 Parkin. When r told her I was not, she told me that r should vote to "re-elect" him

!O was now City and for criminal iy prosecuted 11 criminals and prostitutes.

12 under penalty of perj under the Jaws of the State of California that 13 above is true and correct.

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this] 9th day March, 2014 at Long u ... a.""l. California:

HIBI T>ECI.ARATIOII\ - I

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