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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,
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inclusive,
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Defendants.
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2 J
PARTlES
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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
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(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 supporting
AFL-CrO IS an
the 2014
5.
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{,<;) ]
leave of the Court
les of
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designated when such'
has been
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8. Plaintiff is infonned and based upon such infonnation
belief alleges that eacb of the DOE Defendants is responsible in some manner for
acts, am occurrences and/or alleged in this
9. election for City Attorney is a municipal election
held in [he Long Beach ich is located in Los County, Cal
acts, omissions, OCCUlTences,
InJ
caused, and/or liabi . that are alleged In this
Complaint
this
10.
the
that section.
11.
candidate
in Los
to Ca.
action is
shall have j
aintiff Pappas
office
County, CaJ 1
Proc. 395,
of Election
iction in actions
STANDING
on the official
Accordingl y > venue is proper In
18350 that
to enforce the
ba:llot and has qualified as a
18350 of Election
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in-part
::: action brought by
3 the office at
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5 12. In
6 to thousands of
that, "Any violation
idatc for the
may
involved"
in a civil
idate for
action and has standing to seek injunctive
4, Pappas a true and correct copy of A mai ler sent
voters POA 1) that
7 included the facsimile a sibYfled Icuer President, which
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advertised that voters should "Re-elect Charles Parkin."
13. In
an article publl
along with a
Parkin for
is the mcumbent
14. In
telephone call
AFL-cro.
crimmal
elected" city
J 5.
16.
20 J 4, Charles Parkin, on hIs official campaign Website included
by the Long Beach newspaper ("Parkin
statemenr that the article are
" Thereafter, a balded of
2014, Long registered voter
a solicitor identifymg themselves as a
" Exhibit
for emphasis by
that Parkin
King received a
of defendant
ca II, the phone
drug offenders
of Long Beach.
Parkin has never
icitor stated to King that Parkin had
prostitutes and that to should be
ofLawrenceK' 3).
City Attomey Beach.
Parkin was appomted Long Beach City
resignation of now retired and formerly City Attorney
following the
Shannon in July,
2013.
17. is not an as that term is in the Cali
Elections Code J3107(a)(2).)
(Injunctive Relief)
18. leges and by remainder of
28 allegations ser in this Complamt as If lJy set forth herein.
(,O;\[I-'LAI.'<"" FOR I'iJr"lCTIVE REl.n:F
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19. fornia Elections 183 50 provides,
2 IS of a with intent to the
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voters tn
public
connection with or her campaign nomination or
or in connection with the campaign person
to a
nomination
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Long
elected
which,
the
or
or
or
case.
which
to
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24.
to a public either of the lowi acts:
(a) Assume, pretend, or imply, by his or her statements or conduct, that he
is the incumbent of a public office when that is not the case.
Assume, pretend, or imply, by his or statements or that he
been In capacity a public officer when that is not the
violation of this may be
for the public office i.nvolved.
. Elections
word "incumbent"
holds at
by a vote
to that office.
13! 07( a)(2)
the candidate IS a
noml
people, or. in the case
in a civil action
date for
papers,
same office
was elected
a supelior court' was
Defendant Parkin IS not an incumbent and was not elected to position of
Attorney previously.
of Superior
Defendant Parkin
is not a supenor court
Judge.
not held the position
and IS not the
Beach City
Long Beach Charter, is the elected individual solely responsible for
of Cflrnes. Parkin has oot 5erved as a
Parkin not held the
prosecutor at
Dlstlict A twrney
time.
has not
23 served as an Assistant District
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25 prostitute,
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27 Attorney
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At no time has Parkin ever criminally prosecuted a
In June, 2013, Parkin's former boss, S harmon, the then
Long Beach, he was
FOR I!'JI',,C l1VE RI"LI.EF
4
appointment
or
City
defendant
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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
9 29,
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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17 the
18 violation
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WH
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23 injunction
24 Code;
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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
FOR INHJ"iCTI"f, REI.If:F
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as be just,
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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
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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 _ _ cbarl"
I of 2
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 5p<: 00 March 14.2014 . F"",
link 10 Ofi9in81 Artide
PublIshed March 13, 21)14 Updated: 3'53 pm.
As maifboxes are stu1'/ed wlth campaign Riers and lawn si9ns are shoved Inlo patch of grass throughout the city, we focus foday on Long Bei!ch's city
attorney and city prosecutor races. The greatest attention isn', always paid to " down-ballot contests, but both offices are responsible for
crltlcaJ public service func!lorn;. and your careful consideration.
The city attorn.,y heads an offIce ot 20 lewyers wt10 serve as lhe dty's in sa coonsel. The office has wid6-rar;ging r6Sponsibirrt_. from drafting
ordinances for the City CourtcH, to providing legal advice 10 the city's man agf1cies, boards and commissions fo hedge against potemial liablli\ie-s They
also rep(esenl the cirt and i1s employees when lawsuits 8fe brough1 a nslthem, and decide when Ihe city seWes or ffghts such charges.
city pl'O&eCUl.or manages j 4 attorneys tasked with the narr ut neverlheless vllal. dlrecttve of prose<:Utlng all adult misdemeanor crimes sllCh as
thef1and drug possession are by tru! Los ales Coonty Dislrid Attorney's office). A prosecutor can establish safety protocolS and
pnaoemplively fight crime by creallllg programs that address!h 00\ causes.
Both jobs rltquire an attorney with a sharp le-gal miod, rodent and an even keel to manage their large teams and keep within btKlgel.
CUl'IlilfI! City Attome" City PWSflcutor Doug Haubert, to be the most suibble c.andidatas, and we
In lne city race, Mr. Parkrn faces 011 !lgSIIlSI current Seventh Dis1nct Councilman and CSUlB law proifiwr James Johnson and local civil nghts
attorney Matthew Pappas
last year, the City Council appointed Mr. Parkin. !hen an assistant city attorney, 10 the head post following the departure of his long-serving
Bob ShaMOO
Sinee taking on the role', he has proven to be an apt chief, and his 19 years s.erving In the o#f'Ice means he knows municipal law better than his
two opponents - a crucial body of knowledge considering the broad of the job.
The LOIl9 native has shown practical ktadet'shlp on hotbutton issues, advising council members to adjust Ihtlir ordinance parameters on
medical marijuana dispensaries when tI:N!' propos.al !hey sent his offiOl! didn't reflect the city's zoning realities.
In many ways, he'1; a ieadt!'rshlp style opposite what many perceived lIS a brasil Mr. Shannon, Aboul the dlfference, Mr_ Parl<ln lold IJ'S,
"Shannon wasn', a consensus builder - I am."
Four years on the CHy CounCIl atfords Mr. Parkin's Challenger, James JDhnson. a deep uf'\derntllnding of!he issues faclllg Long 6e.ech.
He is a candidate with lJle educal10n and chara<;te< to ensure him a fife-lol'lg career as an impact1ul public &efVanl. What prevents him, however, from
earning our enoorserrumt is his limited p!'.KW;.ing municipal law and mana.ging a large law office.
Ano!l'ler c.halh?nger. Matt Pappa,;, is weU known IhroughotJl the city lor his 20 years of legal advoC<!lC), worl<. We appreciate his patient-friendly "lew on
medical marijuana and we agree Wl!h him lhallhe dty shOUld business Nlgulati()fls.
But Mr. Pappas, who In his privale has several pendlrIQ laws.uits a-gainS1 the dly. told us he is running for the office I:lecause he would like to
prated \he of long 8ead1 from a oomJpt govemment. and sp&iflCalty. a police force he &<lid is prone to mlsOO!'1ducl,
EXHIBIT 2
3117/20148;56 PM
2
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] 9
th
day March, 2014 at Long u ... a.""l. California:
HIBI
T>ECI.ARATIOII\ - I
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