Adam Brandy et al v. Alex Villanueva et al

Filing 1

COMPLAINT Receipt No: ACACDC-25883116 - Fee: $400, filed by plaintiffs National Rifle Association of America, DG2A Enterprises Inc., Firearms Policy Coalition, Daemion Garr, Adam Brandy, Second Amendment Foundation, California Gun Rights Foundation. (Attachments: #1 Civil Cover Sheet) (Attorney George M Lee added to party Adam Brandy(pty:pla), Attorney George M Lee added to party California Gun Rights Foundation(pty:pla), Attorney George M Lee added to party DG2A Enterprises Inc.(pty:pla), Attorney George M Lee added to party Firearms Policy Coalition(pty:pla), Attorney George M Lee added to party Daemion Garr(pty:pla), Attorney George M Lee added to party National Rifle Association of America (pty:pla), Attorney George M Lee added to party Second Amendment Foundation(pty:pla))(Lee, George)

UNITED STATES DISTRICT COURT, CENTRAL DISTRICT OF CALIFORNIA
CIVIL COVER SHEET
I. (a) PLAINTIFFS ( Check box if you are representing yourself

DEFENDANTS

)

( Check box if you are representing yourself

)

Adam Brandy, Daemion Garr, DG2A Enterprises, Inc., Second Amendment
Foundation, California Gun Rights Foundation, National Rifle Association of America,
and Firearms Policy Coalition, Inc.

Alex Villanueva; Gavin Newsom, Sonia Y. Angel, Barbara Ferrer, all in their official
capacities, and County of Los Angeles

(b) County of Residence of First Listed Plaintiff Los Angeles

County of Residence of First Listed Defendant

(EXCEPT IN U.S. PLAINTIFF CASES)

(IN U.S. PLAINTIFF CASES ONLY)

(c) Attorneys (Firm Name, Address and Telephone Number) If you are

Attorneys (Firm Name, Address and Telephone Number) If you are

representing yourself, provide the same information.

representing yourself, provide the same information.

George M. Lee (SBN 172982) | Seiler Epstein LLP
275 Battery Street, Suite 1600
San Francisco, CA 9411
[phone]

III. CITIZENSHIP OF PRINCIPAL PARTIES-For Diversity Cases Only

II. BASIS OF JURISDICTION (Place an X in one box only.)

(Place an X in one box for plaintiff and one for defendant)
PTF

DEF

Incorporated or Principal Place
of Business in this State
Incorporated and Principal Place
of Business in Another State

1. U.S. Government
Plaintiff

3. Federal Question (U.S.
Government Not a Party)

Citizen of This State
Citizen of Another State

2

2

2. U.S. Government
Defendant

4. Diversity (Indicate Citizenship
of Parties in Item III)

Citizen or Subject of a
Foreign Country

3

PTF

3 Foreign Nation

IV. ORIGIN (Place an X in one box only.)
1. Original
Proceeding

2. Removed from
State Court

3. Remanded from
Appellate Court

V. REQUESTED IN COMPLAINT: JURY DEMAND:
CLASS ACTION under F.R.Cv.P. 23:

Yes

4. Reinstated or
Reopened

Yes

No

1

1

5. Transferred from Another
District (Specify)

4

DEF

5

6

6. Multidistrict
Litigation Transfer

5

6

8. Multidistrict
Litigation Direct File

(Check "Yes" only if demanded in complaint.)
MONEY DEMANDED IN COMPLAINT: $

No

VI. CAUSE OF ACTION (Cite the U.S. Civil Statute under which you are filing and write a brief statement of cause.

Do not cite jurisdictional statutes unless diversity.)

42 U.S.C. § 1983 (two counts, based on Second Amendment, Fifth and Fourteenth Amendments, U.S. Const.); 28 U.S.C. § 2201

VII. NATURE OF SUIT (Place an X in one box only).
OTHER STATUTES

CONTRACT

375 False Claims Act

110 Insurance

376 Qui Tam
(31 USC 3729(a))

120 Marine

400 State
Reapportionment
410 Antitrust
430 Banks and Banking
450 Commerce/ICC
Rates/Etc.
460 Deportation
470 Racketeer Influenced & Corrupt Org.
480 Consumer Credit
490 Cable/Sat TV
850 Securities/Commodities/Exchange
890 Other Statutory
Actions
891 Agricultural Acts
893 Environmental
Matters
895 Freedom of Info.
Act
896 Arbitration
899 Admin. Procedures
Act/Review of Appeal of
Agency Decision
950 Constitutionality of
State Statutes
FOR OFFICE USE ONLY:
CV-71 (05/17)

130 Miller Act
140 Negotiable
Instrument
150 Recovery of
Overpayment &
Enforcement of
Judgment
151 Medicare Act
152 Recovery of
Defaulted Student
Loan (Excl. Vet.)
153 Recovery of
Overpayment of
Vet. Benefits
160 Stockholders'
Suits
190 Other
Contract
195 Contract
Product Liability
196 Franchise
REAL PROPERTY
210 Land
Condemnation
220 Foreclosure
230 Rent Lease &
Ejectment

REAL PROPERTY CONT.
240 Torts to Land
245 Tort Product
Liability
290 All Other Real
Property
TORTS
PERSONAL INJURY
310 Airplane
315 Airplane
Product Liability
320 Assault, Libel &
Slander
330 Fed. Employers'
Liability
340 Marine
345 Marine Product
Liability
350 Motor Vehicle
355 Motor Vehicle
Product Liability
360 Other Personal
Injury
362 Personal InjuryMed Malpratice
365 Personal InjuryProduct Liability
367 Health Care/
Pharmaceutical
Personal Injury
Product Liability
368 Asbestos
Personal Injury
Product Liability

IMMIGRATION
462 Naturalization
Application

PRISONER PETITIONS
Habeas Corpus:

PROPERTY RIGHTS
820 Copyrights

463 Alien Detainee
510 Motions to Vacate
Sentence
530 General
535 Death Penalty

830 Patent

371 Truth in Lending

Other:
540 Mandamus/Other

SOCIAL SECURITY
861 HIA (1395ff)

380 Other Personal
Property Damage

550 Civil Rights
555 Prison Condition

862 Black Lung (923)

385 Property Damage
Product Liability
BANKRUPTCY
422 Appeal 28
USC 158
423 Withdrawal 28
USC 157
CIVIL RIGHTS

560 Civil Detainee
Conditions of
Confinement

864 SSID Title XVI

465 Other
Immigration Actions
TORTS
PERSONAL PROPERTY
370 Other Fraud

440 Other Civil Rights
441 Voting
442 Employment
443 Housing/
Accommodations
445 American with
DisabilitiesEmployment
446 American with
Disabilities-Other
448 Education

FORFEITURE/PENALTY
625 Drug Related
Seizure of Property 21
USC 881
690 Other

835 Patent - Abbreviated
New Drug Application
840 Trademark

863 DIWC/DIWW (405 (g))
865 RSI (405 (g))
FEDERAL TAX SUITS
870 Taxes (U.S. Plaintiff or
Defendant)
871 IRS-Third Party 26 USC
7609

LABOR
710 Fair Labor Standards
Act
720 Labor/Mgmt.
Relations
740 Railway Labor Act
751 Family and Medical
Leave Act
790 Other Labor
Litigation
791 Employee Ret. Inc.
Security Act

Case Number:
CIVIL COVER SHEET

4

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UNITED STATES DISTRICT COURT, CENTRAL DISTRICT OF CALIFORNIA
CIVIL COVER SHEET
VIII. VENUE: Your answers to the questions below will determine the division of the Court to which this case will be initially assigned. This initial assignment is subject
to change, in accordance with the Court's General Orders, upon review by the Court of your Complaint or Notice of Removal.
QUESTION A: Was this case removed
from state court?
Yes

No

STATE CASE WAS PENDING IN THE COUNTY OF:
Los Angeles, Ventura, Santa Barbara, or San Luis Obispo

If "no, " skip to Question B. If "yes," check the
box to the right that applies, enter the
corresponding division in response to
Question E, below, and continue from there.

Western

Orange

Southern

Riverside or San Bernardino

Eastern

QUESTION B: Is the United States, or B.1. Do 50% or more of the defendants who reside in
the district reside in Orange Co.?
one of its agencies or employees, a
PLAINTIFF in this action?

YES. Your case will initially be assigned to the Southern Division.
Enter "Southern" in response to Question E, below, and continue
from there.

check one of the boxes to the right

Yes

INITIAL DIVISION IN CACD IS:

No

NO. Continue to Question B.2.
B.2. Do 50% or more of the defendants who reside in
the district reside in Riverside and/or San Bernardino
Counties? (Consider the two counties together.)

YES. Your case will initially be assigned to the Eastern Division.
Enter "Eastern" in response to Question E, below, and continue
from there.

check one of the boxes to the right

If "no, " skip to Question C. If "yes," answer
Question B.1, at right.

NO. Your case will initially be assigned to the Western Division.
Enter "Western" in response to Question E, below, and continue
from there.

QUESTION C: Is the United States, or C.1. Do 50% or more of the plaintiffs who reside in the
district reside in Orange Co.?
one of its agencies or employees, a
DEFENDANT in this action?

YES. Your case will initially be assigned to the Southern Division.
Enter "Southern" in response to Question E, below, and continue
from there.

check one of the boxes to the right

Yes

No

NO. Continue to Question C.2.
C.2. Do 50% or more of the plaintiffs who reside in the
district reside in Riverside and/or San Bernardino
Counties? (Consider the two counties together.)

YES. Your case will initially be assigned to the Eastern Division.
Enter "Eastern" in response to Question E, below, and continue
from there.

check one of the boxes to the right

If "no, " skip to Question D. If "yes," answer
Question C.1, at right.

NO. Your case will initially be assigned to the Western Division.
Enter "Western" in response to Question E, below, and continue
from there.

A.

QUESTION D: Location of plaintiffs and defendants?

Orange County

B.
Riverside or San
Bernardino County

C.
Los Angeles, Ventura,
Santa Barbara, or San
Luis Obispo County

Indicate the location(s) in which 50% or more of plaintiffs who reside in this district
reside. (Check up to two boxes, or leave blank if none of these choices apply.)
Indicate the location(s) in which 50% or more of defendants who reside in this
district reside. (Check up to two boxes, or leave blank if none of these choices
apply.)
D.1. Is there at least one answer in Column A?
Yes

D.2. Is there at least one answer in Column B?

No

Yes

No

If "yes," your case will initially be assigned to the

If "yes," your case will initially be assigned to the

SOUTHERN DIVISION.

EASTERN DIVISION.

Enter "Southern" in response to Question E, below, and continue from there.

Enter "Eastern" in response to Question E, below.

If "no," go to question D2 to the right.

If "no," your case will be assigned to the WESTERN DIVISION.
Enter "Western" in response to Question E, below.

QUESTION E: Initial Division?

INITIAL DIVISION IN CACD

Enter the initial division determined by Question A, B, C, or D above:

WESTERN

QUESTION F: Northern Counties?
Do 50% or more of plaintiffs or defendants in this district reside in Ventura, Santa Barbara, or San Luis Obispo counties?
CV-71 (05/17)

CIVIL COVER SHEET

Yes

No
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UNITED STATES DISTRICT COURT, CENTRAL DISTRICT OF CALIFORNIA
CIVIL COVER SHEET
IX(a). IDENTICAL CASES: Has this action been previously filed in this court?

NO

YES

NO

YES

If yes, list case number(s):

IX(b). RELATED CASES: Is this case related (as defined below) to any civil or criminal case(s) previously filed in this court?
If yes, list case number(s):

Civil cases are related when they (check all that apply):
A. Arise from the same or a closely related transaction, happening, or event;
B. Call for determination of the same or substantially related or similar questions of law and fact; or
C. For other reasons would entail substantial duplication of labor if heard by different judges.
Note: That cases may involve the same patent, trademark, or copyright is not, in itself, sufficient to deem cases related.

A civil forfeiture case and a criminal case are related when they (check all that apply):
A. Arise from the same or a closely related transaction, happening, or event;
B. Call for determination of the same or substantially related or similar questions of law and fact; or
C. Involve one or more defendants from the criminal case in common and would entail substantial duplication of
labor if heard by different judges.

X. SIGNATURE OF ATTORNEY
(OR SELF-REPRESENTED LITIGANT): /s/ George M. Lee (SBN 172982)

DATE: March 27, 2020

Notice to Counsel/Parties: The submission of this Civil Cover Sheet is required by Local Rule 3-1. This Form CV-71 and the information contained herein
neither replaces nor supplements the filing and service of pleadings or other papers as required by law, except as provided by local rules of court. For
more detailed instructions, see separate instruction sheet (CV-071A).

Key to Statistical codes relating to Social Security Cases:
Nature of Suit Code

Abbreviation

Substantive Statement of Cause of Action
All claims for health insurance benefits (Medicare) under Title 18, Part A, of the Social Security Act, as amended. Also,
include claims by hospitals, skilled nursing facilities, etc., for certification as providers of services under the program.
(42 U.S.C. 1935FF(b))

861

HIA

862

BL

All claims for "Black Lung" benefits under Title 4, Part B, of the Federal Coal Mine Health and Safety Act of 1969. (30 U.S.C.
923)

863

DIWC

All claims filed by insured workers for disability insurance benefits under Title 2 of the Social Security Act, as amended; plus
all claims filed for child's insurance benefits based on disability. (42 U.S.C. 405 (g))

863

DIWW

All claims filed for widows or widowers insurance benefits based on disability under Title 2 of the Social Security Act, as
amended. (42 U.S.C. 405 (g))

864

SSID

All claims for supplemental security income payments based upon disability filed under Title 16 of the Social Security Act, as
amended.

865

RSI

All claims for retirement (old age) and survivors benefits under Title 2 of the Social Security Act, as amended.
(42 U.S.C. 405 (g))

CV-71 (05/17)

CIVIL COVER SHEET

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