Filed 8/29/22 Rotter v. Feng CA2/6

NOT TO BE PUBLISHED IN THE OFFICIAL REPORTS

California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions 

not certified for publication or ordered published, except as specified by rule 8.1115(b). This opinion 

has not been certified for publication or ordered published for purposes of rule 8.1115. 

IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA

SECOND APPELLATE DISTRICT

DIVISION SIX

SAM ROTTER,

 Plaintiff and Appellant,

v.

TIAN FENG, as President of 

the California Architects Board,

 Defendant and Respondent.

2d Civil No. B313628

(Super. Ct. No. 56-2021-

00549228-CU-MC-VTA)

(Ventura County)

Appellant Sam Rotter was a licensed architect. He claims 

that, in violation of the Americans with Disabilities Act of 1990 

(ADA, 42 U.S.C. § 12101 et seq.), the California Architects Board 

(CAB) failed to accommodate his attention-deficit/hyperactivity 

disorder (ADHD) during architect licensing examinations he took 

in 2002. 

Appellant eventually passed the examination, but in 2004 

the CAB revoked his license. He contends that the CAB 

unlawfully published personal information about his license 

revocation on its website in violation of the Information Practices 
2

Act of 1977 (IPA, Civ. Code, § 1798 et seq.). In addition, he 

claims that the CAB violated the California Public Records Act

(CPRA, Gov. Code, § 6250, et seq.) and the Fair Employment and 

Housing Act (FEHA, Gov. Code § 12900 et seq.).

Appellant appeals in propria persona from the judgment of 

dismissal entered after the trial court had sustained, without 

leave to amend, the CAB’s demurrer to his first amended 

complaint.1 We reverse the judgment of dismissal. We remand 

the matter to the trial court with directions to sustain, without 

leave to amend, the demurrer to all causes of action except the 

cause of action for violation of the CPRA. 

Standard of Review

“A demurrer tests the legal sufficiency of factual allegations 

in a complaint. [Citation.] A trial court’s ruling sustaining a 

demurrer is erroneous if the facts alleged by the plaintiff state a 

cause of action under any possible legal theory. [Citations.]” (Lee 

Newman, M.D., Inc. v. Wells Fargo Bank (2001) 87 Cal.App.4th 

73, 78.) 

“[W]e apply the de novo standard of review in an appeal 

following the sustaining of a demurrer . . . .” (California 

Logistics, Inc. v. State of California (2008) 161 Cal.App.4th 242, 

247.) “[W]e assume the truth of all facts properly pleaded in the 

complaint and its exhibits or attachments, as well as those facts 

that may fairly be implied or inferred from the express 

allegations. [Citation.] ‘We do not, however, assume the truth of 

1 The CAB states it was erroneously sued as “Tian Feng, in 

his official capacity as Board President of C.A.B.” The CAB

maintains it should have been sued as the “State of California, 

acting by and through the California Architects Board.” 
3

contentions, deductions, or conclusions of fact or law.’ [Citation.]” 

(Cobb v. O’Connell (2005) 134 Cal.App.4th 91, 95.)

“The plaintiff has the burden of showing that the facts 

pleaded are sufficient to establish every element of the cause of 

action and overcoming all of the legal grounds on which the trial 

court sustained the demurrer, and if the defendant negates any

essential element, we will affirm the order sustaining the 

demurrer as to the cause of action. [Citation.]” (Martin v. 

Bridgeport Community Assoc., Inc. (2009) 173 Cal.App.4th 1024, 

1031 (Martin).)

When, as here, “a demurrer has been sustained without

leave to amend, unless failure to grant leave to amend was an 

abuse of discretion, the appellate court must affirm the judgment 

if it is correct on any theory. [Citations.] If there is a reasonable 

possibility that the defect in a complaint can be cured by 

amendment, it is an abuse of discretion to sustain a demurrer 

without leave to amend. [Citation.] The burden is on the 

plaintiff . . . to demonstrate the manner in which the complaint 

might be amended.” (Hendy v. Losse (1991) 54 Cal.3d 723, 742.)

Appellant’s First Amended Complaint

Appellant’s original complaint was filed in January 2021. 

Appellant’s first amended complaint, filed in March 2021, 

consists of three causes of action. Appellant sought various forms 

of relief, including damages of $4,445,900. 

Appellant attached numerous exhibits to the first amended 

complaint. We refer to these exhibits in our discussion of the 

causes of action. “‘[T]o the extent the [complaint’s] factual 

allegations conflict with the content of the exhibits to the 

complaint, we rely on and accept as true the contents of the 
4

exhibits.’” (Performance Plastering v. Richmond American Homes

of California, Inc. (2007) 153 Cal.App.4th 659, 665.) 

First Cause of Action

The first cause of action alleges violations of the ADA. The 

violations are based on the CAB’s failure to accommodate 

appellant’s ADHD during architect licensing examinations he 

took in 2002. 

The statute of limitations for a violation of the ADA is three 

years. (Sharkey v. O'Neal (9th Cir. 2015) 778 F.3d 767, 768, 773.) 

The trial court concluded that the first cause of action is timebarred because the ADA violations occurred in 2002, and the 

complaint was not filed until January 2021. The court noted that 

appellant had “complained of the ADA violations in 2002.” In 

March 2002 appellant wrote letters of complaint to the CAB and 

the Civil Rights Division of the United States Department of 

Justice. (Exhibits 1a, 7.) 

Appellant has not presented any cogent argument, 

supported by legal analysis, explaining why he had not timely 

filed his complaint within the three-year statutory period. 

Accordingly, he has not overcome the presumption that the trial 

court’s ruling is correct. (In re Marriage of Arceneaux (1990) 51 

Cal.3d 1130, 1133 [“A judgment or order of a lower court 

is presumed to be correct on appeal, and all intendments and 

presumptions are indulged in favor of its correctness”].)

Second Cause of Action

The second cause of action actually consists of two separate 

causes of action: one for a violation of Civil Code section 1798.24 

of the IPA and the other for a violation of Government Code 

section 6253 of the CPRA. The cause of action is entitled: 
5

“Second Cause of Action – VIOLATION OF CIV § 1798.24 

and GOV § 6253.”

Violation of Civil Code section 1798.24

The second cause of action alleges that the CAB violated 

Civil Code section 1798.24 of the IPA because it “published [on its 

website] a derogatory unchallenged set of allegations” about the 

2004 revocation of appellant’s architect license. The IPA 

“‘generally imposes limitations on the right of governmental 

agencies to disclose personal information about an 

individual. . . .’” (Bates v. Franchise Tax Bd. (2004) 124 

Cal.App.4th 367, 373.) Civil Code “section 1798.45 provides a 

private right of action against a state agency for violation of 

provisions of the IPA . . . .” (Id. at p. 381.) 

The offending publication on the CAB’s website said, and 

still says today: “Effective July 23, 2004, [appellant’s] architect 

license, number C-29196, was revoked, after the [CAB] adopted a 

Proposed Decision. An Accusation was filed against Rotter for 

violations of Business and Professions Code sections 5536.22 

(Written Contract), 5583 (Fraud in the Practice of Architecture), 

and 5584 (Willful Misconduct). The Accusation was based on 

evidence that [appellant] and his brother were potential buyers of 

a residence (property). [Appellant], without consulting or 

contracting with the owner of the property for any architectural 

services, chose to perform site analysis and feasibility studies in 

anticipation of purchasing the property. The owner canceled 

escrow. [Appellant] felt that the owner ‘breached’ her agreement 

with them to purchase the property and used his architectural 

license to file a Mechanic’s Lien against the owner in the amount 

of $56,283.72 for architectural design drawings. This caused the 

owner financial harm by encumbering her property and 
6

preventing her from selling it.” (Exhibit 8; see 

<https://www.cab.ca.gov/consumers/enforcement_actions/r.shtml#

citations> [as of June 13, 2022], archived at <https://perma.cc/ 

2BFA-5ZGS>. 

Appellant claims that the website publication violated Civil 

Code section 1798.24, subdivision (b), which provides: “An 

agency shall not disclose any personal information in a manner 

that would link the information disclosed to the individual to 

whom it pertains unless the information is disclosed, as 

follows: . . . With the prior written voluntary consent of the 

individual to whom the information pertains . . . .” 

 Appellant allegedly did not learn of the website 

publication until February 7, 2020, when a prospective employer 

brought it to his “attention during a job interview.” Appellant 

asserts that the website publication “did injury to not only this 

job interview but . . . many years of [his] deterred [sic] 

architectural job searches.” 

The trial court ruled: “The gravamen of [the alleged 

violation of Civil Code section 1798.24] concerns [appellant’s] 

learning in February, 2020, that CAB published negative 

information about [his] license status on its public website. The 

[first amended complaint] contains allegations which indicate 

[he] was aware of this publication by CAB of negative information 

as early as 2008. The limitations period for actions filed under 

this statute is two years. (Civ. Code, § 1798.49.) . . . The action is 

[therefore] time-barred.” (Italics added.) 

In his appellate briefs appellant argues: Until 2020, “he 

had no knowledge of a World Wide Web publication that 

published prohibited material to the entire planet.” In a 

September 15, 2008 letter to the State Auditor, he complained 
7

about the unlawful disclosure of his personal information in a 

“CAB architectural newsletter [(the newsletter)] . . . that is 

received by the subscription of less than 1000 California licensed 

architects . . . .”2 “[I]t should be emphasized that the newsletter 

article happened just once.” “[T]here is a large difference 

between releasing prohibited information to a discreet body of 

licensed California architects and the world at large through the 

World Wide Web.” Appellant argues that the running of the twoyear statute of limitations was delayed until his 2020 discovery of 

the internet publication. For the reasons discussed below, we 

need not decide this issue.

The CAB contends that, irrespective of the statute of 

limitations, it is “immune from suit with respect to its licensing 

activities.” Appellant cites Government Code section 818.4, 

which provides, “A public entity is not liable for an injury caused 

by the . . . revocation of . . . any . . . license . . . where the public 

entity . . . is authorized by enactment to determine whether or 

not such [license] should be . . . revoked.” But in the cause of 

action for a violation of Civil Code section 1798.24, appellant is 

not suing the CAB for an injury caused by the revocation of his 

license. He is suing the CAB for disclosing on its website 

2 To prove that this newsletter exists, appellant moved to 

augment the record to include the front page of issue 1 of the 

2015 edition of the newsletter. The motion is denied because 

appellant has not shown that this issue of the newsletter was 

“filed or lodged in the case in superior court.” (Cal. Rules of 

Court, rule 8.155(a)(1)(A).) In support of his motion to augment, 

appellant declared under penalty of perjury, “I received a copy of 

the Newsletter from CAB in the summer of the 2004 in which I 

read the offending mendacious account of their so called 

“enforcement action” against the plaintiff.” 
8

personal information about his license revocation in violation of 

section 1798.24. Appellant wants that information removed from 

the website. In his opening brief appellant “prays the court 

immediately order the CAB to eradicate the offending publication 

. . . .” 

The CAB claims it was required to disclose to the public the 

information that it published on its website. Therefore, the cause 

of action for a violation of Civil Code section 1798.24 is barred. 

The CAB relies on section 137 of Title 16 of the California Code of 

Regulations (section 137). But section 137 did not require the 

CAB to publish this information on its website. Section 137, 

subdivision (a) required the CAB to disclose the information “to 

members of the public, upon request, by telephone, in person, or 

in writing (including fax or email).” (Ibid., italics added.)

Business and Professions Code section 27, which is not 

cited by the CAB, requires it to disclose the information 

published on its website. The statute expressly applies to the 

CAB. (Id., subd. (c)(9).) Section 27, subdivision (a) provides that 

the CAB “shall provide on the internet information regarding the 

status of every license issued by that entity in accordance with 

the California Public Records Act [citation] and the Information 

Practices Act of 1977 [citation]. The public information to be 

provided on the internet shall include information on suspensions 

and revocations of licenses issued by the entity and other related 

enforcement action, including accusations filed pursuant to the 

Administrative Procedure Act [citation] taken by the entity 

relative to persons, businesses, or facilities subject to licensure or 

regulation by the entity. The information may not include 

personal information, including home telephone number, date of 

birth, or social security number.” Since section 27 required the 
9

CAB to disclose the information on its website, the trial court did 

not err in sustaining, without leave to amend, the demurrer to 

the cause of action for violation of the IPA.

The CAB’s failure to cite Business and Professions Code 

section 27 does not require us to allow the parties to submit

supplemental briefing on the statute’s applicability. Government 

Code section 68081 provides, “Before . . . a court of appeal . . . 

renders a decision in a proceeding . . . based upon an issue which 

was not proposed or briefed by any party to the proceeding, the 

court shall afford the parties an opportunity to present their 

views on the matter through supplemental briefing.” In its brief 

the CAB raised the issue of whether it was required to disclose to 

the public the information about the revocation of appellant’s 

license. “Government Code section 68081 does not give the 

parties a right to submit supplemental briefs when an appellate 

court relies upon authority that was not briefed by the parties: 

‘The parties need only have been given an opportunity to brief the

issue decided by the court, and the fact that a party does not 

address an issue, mode of analysis, or authority that is raised or 

fairly included within the issues raised does not implicate the 

protections of section 68081.’ (People v. Alice (2007) 41 Cal.4th 

668, 679, . . . italics added.)” (Gee v. Greyhound Lines, Inc. (2016) 

6 Cal.App.5th 477, 487, fn. 6.)

Violation of Government Code section 6253

The second cause of action alleges that the CAB violated 

Government Code section 6253 of the CPRA. Section 6253, 

subdivision (b) provides: “Except with respect to public records 

exempt from disclosure by express provisions of law, each state or 

local agency, upon a request for a copy of records that reasonably 

describes an identifiable record or records, shall make the records 
10

promptly available to any person upon payment of fees covering 

direct costs of duplication, or a statutory fee if applicable.”

The “CPRA establishes a basic rule requiring disclosure of 

public records upon request. ([Gov. Code] § 6253.) In general, it 

creates ‘a presumptive right of access to any record created or

maintained by a public agency that relates in any way to the 

business of the public agency.’ [Citation.] Every such record 

‘must be disclosed unless a statutory exception is shown.’” (City

of San Jose v. Superior Court (2017) 2 Cal.5th 608, 616, fn. 

omitted (City of San Jose).) 

The alleged violation of the CPRA is based on the CAB’s 

refusal to grant two requests for disclosure. Appellant’s first 

request was made in a March 20, 2020 letter to the CAB. 

Appellant asked it to “provide all the contents of the file upon 

which [his] personal information [published on the CAB’s 

internet site] is based . . . as well as all sources which contributed 

to the contents of this publication.” (Exhibit 10.)3 Appellant 

claimed that “[t]he statutory response [to the request] was never 

obeyed,” i.e., the CAB did not provide the requested records. 

3 The full text of the letter is as follows: “It has come to my 

attention that you have published on internet site 

(https://www.cab.ca.gov/consumers/license_search.shtml) 

personal information which I allege is without my consent, is 

inaccurate and requires review as well as correction. Please 

provide all the contents of the file upon which this personal 

information is based and/or related to as well as all sources which 

contributed to the contents of this publication. This request is 

pursuant to CIV [Civil Code] § 1798.18 through 1798.45.” 

Although appellant did not cite the CPRA in his letter, nothing in 

the CPRA requires such a specific citation. (See Gov. Code, 

§ 6253, subd. (b).) The CAB does not claim that the March 20, 

2020 request was deficient for not citing the CPRA.
11

During appellate oral argument (oral argument), the CAB’s 

counsel said the request is “still pending as far as I know.” The 

CAB does not contend that the records described in the March 20, 

2020 letter failed to comply with the requirement that the 

request “reasonably describe[] an identifiable record or 

records . . . .” (Gov. Code, § 6253, subd. (b).) 

The second request for disclosure was allegedly made in “a 

‘Demand’ letter” that appellant “served” on the CAB on June 3, 

2020. The letter “requir[ed] compliance with . . . GOV § 6253.” 

The record does not include a copy of the “ ‘Demand’ letter.” 

The trial court ruled: “The Court rejects CAB’s argument 

that this claim [for violation of the CPRA] is time-barred. The 

claim arose with the demand [appellant] made to CAB on March 

20, 2020, within three years of the filing of the Complaint. The 

real issue here is that violation of the Public Records Act does not 

create a private right of action. There simply is no legal basis for 

this claim.” 

The Legislature has not authorized an action for monetary 

damages for violation of the CPRA. But this does not mean that 

there is no private right of action for such a violation. The 

remedy is set forth in Government Code section 6258: “Any 

person may institute proceedings for injunctive or declarative 

relief or writ of mandate in any court of competent jurisdiction to 

enforce his or her right to inspect or to receive a copy of any 

public record or class of public records under this chapter.”4 

4 “When it is alleged that public records have been 

improperly withheld, [Government Code] section 6259, 

subdivision (a) directs that ‘the court shall order the officer or 

person charged with withholding the records’ to disclose the 

records or show cause why they should not be produced. If the 
12

In his prayer for relief, appellant did not seek injunctive, 

declaratory, or mandamus relief on the CPRA cause of action. 

But as to all causes of action, he sought “such other and further 

relief, including declaratory relief, as the Jury may deem proper.” 

For purposes of the CAB’s demurrer, it does not matter 

whether appellant requested the specific relief authorized by 

Government Code section 6258. He still stated a cause of action 

for violation of the Public Records Act. “‘In determining whether 

or not the complaint is sufficient, as against the demurrer, upon 

the ground that it does not state facts sufficient to constitute a 

cause of action, the rule is, that if upon a consideration of all the 

facts stated it appears that the plaintiff is entitled to any relief at 

the hands of the court against the defendants, the complaint will 

be held good, although . . . the plaintiff may demand relief to 

which he is not entitled under the facts alleged.’ [Citation.] In 

other words, ‘plaintiff need only plead facts showing that he may 

be entitled to some relief [citation].’” (Gruenberg v. Aetna Ins. Co.

(1973) 9 Cal.3d 566, 572; see also Weil & Brown, Cal. Practice 

Guide: Civil Procedure Before Trial (The Rutter Group, June 

2021 update) ¶ 7:42.1 [“A general demurrer challenges only the 

sufficiency of the cause of action pleaded, and must be overruled 

if any valid cause of action is pleaded; a demand for improper 

relief does not vitiate an otherwise valid cause of action”].)

court concludes ‘the public official’s decision to refuse disclosure 

is not justified,’ it can order ‘the public official to make the record 

public.’ (§ 6259, subd. (b).) If the court finds ‘that the public 

official was justified in refusing’ disclosure, it must ‘return the 

item to the public official without disclosing its content.’ (Ibid.)” 

(City of San Jose, supra, 2 Cal.5th at p. 622.)
13

At oral argument counsel for the CAB asserted that a 

complaint for violation of the CPRA “would require the filing of a 

government claim with the Department of General Services, and 

that was not done.” ““‘The Government Claims Act ([Gov. Code,] 

§ 810 et seq.) ‘establishes certain conditions precedent to the 

filing of a lawsuit against a public entity. . . . [A] plaintiff must 

timely [present] a claim for money or damages [to] the public 

entity. ([Id.,] § 911.2.) The failure to do so bars the plaintiff from 

bringing suit against that entity. ([Id.,] § 945.4.) . . . .’”’” (Coble v.

Ventura County Health Care Agency (2021) 73 Cal.App.5th 417, 

421.) Since appellant could not obtain an award of money or 

damages for the alleged violation of the CPRA, the Government 

Claims Act is inapplicable to this cause of action.

The CAB claims that appellant’s cause of action for 

violation of the CPRA is time-barred by “the three-year limitation 

period applicable to a statutory violation. (Code of Civ. Proc., 

§ 338, subd. (a).).” The CAB notes that, in his September 15, 

2008 letter to the State Auditor, appellant said, “I have requested 

[from the CAB] a copy of all public and secret meeting 

information in order to shed light on all aspects of this matter. 

The CAB’s refusal letter will be enclosed with this submission.” 

The CAB maintains that the three-year statute of limitations 

started to run no later than September 15, 2008, when appellant 

wrote the letter to the State Auditor. 

“There is no statute of limitations for an action under the 

[C]PRA. Arguably, the three-year limit of [Code of Civil 

Procedure] § 338 for statutory causes of action would apply, but 

wrongfully withholding a public record would be claimed to be a 

continuing violation. The action would be subject to equitable 

defenses such as laches . . . .” (Asimow et al., Cal. Practice Guide: 
14

Administrative Law (The Rutter Group, Nov. 2021 update) 

¶29:1030.)

We need not determine whether the three-year limitation 

period of Code of Civil Procedure section 338 applies to violations 

of the CPRA. If it did apply, it would not bar appellant from 

seeking to judicially enforce his 2020 records request even if we 

accept the CAB’s contention at oral argument that the renewal of 

a prior request for records does not start the running of a new 

three-year period. The 2020 request was not a renewal of the 

2008 request because the records sought in 2020 were different 

from those sought in 2008. In his September 15, 2008 letter to 

the State Auditor, appellant said he had requested from the CAB 

“a copy of all public and secret meeting information.” (Italics 

added.) At oral argument, appellant explained that the 2008 

letter referred to a request for information about the CAB’s 

“discussions behind closed doors” as to why it had decided to deny 

his application to reinstate his license. He wanted information as 

to the CAB’s “decision-making process” on this matter. In 

contrast, his 2020 request was for “all the contents of the file 

upon which [his] personal information [published on the CAB’s 

internet site] is based . . . as well as all sources which contributed 

to the contents of this publication.” (Exhibit 10.) Thus, the 

three-year limitation period began to run from the date of the 

2020 request, and the cause of action for violation of the CPRA 

was timely filed in 2021. 

The CAB argues, “To the extent [appellant] is seeking nonpublic notes or communications of the CAB members, the [C]PRA 

contains numerous exemptions that apply. (See Gov. Code § 

6254.)” The CAB does not specify which exemptions apply. Nor 

does it explain why they apply with supporting citations to 
15

authority and facts in the record. Consequently, its argument is 

forfeited. “[A] brief must contain ‘“meaningful legal analysis 

supported by citations to authority and citations to facts in the 

record that support the claim of error”’ and contain adequate 

record citations, or else we will deem all points ‘to be forfeited as 

unsupported by “adequate factual or legal analysis.”’” (Fernandes

v. Singh (2017) 16 Cal.App.5th 932, 942-943.) 

Accordingly, the trial court erroneously sustained the 

CAB’s demurrer to the cause of action for violation of the CPRA.

Third Cause of Action

The third cause of action states that the CAB denied 

appellant “an architecture license due to an ADHD disability” in 

violation of the FEHA. The trial court ruled: “This [cause of 

action] is time-barred.” 

A person “who wishes to file suit under the FEHA ‘must 

exhaust the administrative remedy provided by the statute by 

filing a complaint with the’ DFEH [Department of Fair 

Employment and Housing], ‘and must obtain from the [DFEH] a 

notice of right to sue.’ [Citation.] ‘The timely filing of an 

administrative complaint’ before the DFEH ‘is a prerequisite to 

the bringing of a civil action for damages.’” (Pollock v. Tri-Modal

Distribution Service, Inc. (2021) 11 Cal.5th 918, 931.) The 

maximum time allowed for filing a complaint with the DFEH is 

three years from the date that the unlawful practice occurred.

(Gov. Code, § 12960, subds. (e)(3), (e)(5).) “This requirement is 

‘[t]he statute of limitations for FEHA actions.’ ” (Pollock, supra,

at p. 931.)

In his opening brief appellant acknowledges that he did not 

file a complaint with the DFEH until May 2020. The unlawful 

practice occurred 18 years earlier in 2002 when the CAB 
16

allegedly failed to accommodate appellant’s ADHD during its 

administration of architect licensing examinations. Therefore, 

appellant’s third cause of action is time-barred under the threeyear statute of limitations for FEHA actions. 

The third cause of action claims that the three-year statute 

of limitations was tolled by the CAB’s “‘fraudulent concealment’” 

of its unlawful practice. But as we have previously explained, 

appellant was aware of the unlawful practice in 2002. (See ante, 

at p. 4.) Thus, the trial court did not err in sustaining, without 

leave to amend, the CAB’s demurrer to the third cause of action.

Disposition

The judgment dismissing appellant’s first amended 

complaint is reversed. The matter is remanded to the trial court 

with directions to sustain, without leave to amend, the demurrer 

to all causes of action except the cause of action for violation of 

the CPRA. The trial court is directed to overrule the demurrer to 

that cause of action. The parties shall bear their own costs on 

appeal.

NOT TO BE PUBLISHED.

YEGAN, J.

We concur:

GILBERT, P. J. PERREN, J.*

* Retired Associate Justice of the Court of Appeal, Second Appellate District, 

assigned by the Chief Justice pursuant to article VI, section 6 of the California 

Constitution.
Matthew P. Guasco, Judge

Superior Court County of Ventura

______________________________

Sam Rotter, in pro. per., for Plaintiff and Appellant.

Rob Bonta, Attorney General, Danielle F. O’Bannon, Senior 

Assistant Attorney General, Elizabeth S. Angres, Supervising 

Deputy Attorney General, Thomas M. McMahon, Deputy 

Attorney General, for Defendant and Respondent.