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1 important right affecting the public interest in that a significant benefit will be conferred 2 on a large class of persons, that is, public employees, and the necessity and financial 3 burden of private enforcement of said benefit are such as to make appropriate the 4 award of attorney fees pursuant to California Code of Civil Procedure §1021.5. 5 6 WHEREFORE, Plaintiffs pray for judgment against Defendants and each of them 7 as follows: 8 FIRST CAUSE OF ACTION 9 1. A declaration of the Court that the Defendants violated Penal Code 10 §832.5-832.7 and/or Evidence Code §§1043-1046 and that Plaintiffs are entitled to the 11 full relief afforded under Penal Code §832.5-832.7 and/or Evidence Code §§1043- 12 1046; 13 2. The granting of appropriate injunctive or other extraordinary relief to 14 remedy the violation and to prevent future violations of a like or similar nature, including, 15 but not limited to, the granting of a temporary restraining order, preliminary injunction, or 16 permanent injunction prohibiting Defendants, and each of them, and their agents, 17 representatives, employees, servants and/or investigators from releasing any 18 confidential information of peace officers, and/or requiring that prior to any disclosure 19 that the impacted officer(s) be notified; thus, being given the right to invoke their rights; 20 3. That this court issues a temporary restraining order, preliminary and/or 21 permanent injunction enjoining and restraining Defendants, and each of them, and their 22 agents, representatives, employees, servants and/or investigators from releasing any 23 confidential peace officer personnel information without full compliance with the 24 pertinent laws; 25 4. Awarding of all ancillary relief, including statutory penalties, damages and 26 attorney fees; 27 SECOND CAUSE OF ACTION 28 5. A declaration of the Court that the Defendants violated Penal Code 17 COMPLAINT