2021 Emeryville Special Election Petition

83578.0011334269158.4 PETITION FOR PEREMPTORY WRIT OF MANDATE
PURSUANT TO ELECTIONS CODE SECTION 13313 SUBDIVISION (B)(2)
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Petitioner SHERI HARTZ, in her capacity as City Clerk for the City of Emeryville and
the Elections Official for the City of Emeryville (“Petitioner”), alleges as follows:
INTRODUCTION
1. Petitioner seeks a peremptory writ of mandate pursuant to California Elections
Code section 133131
subdivision (b)(2) ordering Respondents ALAMEDA COUNTY BOARD
OF SUPERVISORS and ALAMEDA COUNTY REGISTRAR OF VOTERS (“Respondents”) to
amend the candidate statement of Real Party in Interest COURTNEY WELCH (“Ms. Welch”), a
candidate for the November 2, 2021 Emeryville City Council special election. Specifically,
Petitioner requests that the Court order Respondents to delete the portion of Ms. Welch’s
candidate statement that states “[a]s the first Black woman in 34 years to seek a seat on Council”
because after submission, it was discovered that this portion of the candidate statement is false. A
true and correct copy of Ms. Welch’s candidate statement is attached as Exhibit 1 to the
concurrently-filed Declaration of Sheri Hartz (“Hartz Decl.”) and incorporated herein by this
reference.
PRIORITY MATTER
2. Pursuant to Elections Code section 13314, subdivision (a)(3), as an election law
writ petition, this matter shall have priority over all other civil matters. Time is of the essence in
this proceeding because of Respondents’ impending August 27, 2021 deadline to finalize the
voter information pamphlet and related election materials and forward them to the printer. This
matter is timely brought because the factual error in the statement was discovered for the first
time on Wednesday, August 4, 2021, the nominations period closed on August 6, 2021, and this
petition is being filed within Respondents’ 10-calendar day public examination/statute of
limitations period. (See Elec. Code Elec. Code § 13313(b).) A true and correct copy of the email
notifying Petitioner of the factual error dated August 4, 2021 is attached as Exhibit 2 to the
concurrently-filed Declaration of Sheri Hartz and incorporated herein by this reference.
1
All further statutory references are to the Elections Code unless otherwise noted.

83578.0011334269158.4
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PETITION FOR PEREMPTORY WRIT OF MANDATE
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PARTIES
3. Petitioner is, and at all relevant times was, the City Clerk for the City of
Emeryville, a municipal corporation organized and existing under the laws of the State of
California. As City Clerk, Petitioner is the “election official” for purposes of Elections Code
sections 13313 and 13314. She is charged with responsibility for preparing the candidates’
statements for the election for City Council.
4. Upon information and belief, Respondents are charged by law with printing the
voter information pamphlet and other election materials in compliance with the law, and are
required to be named as Respondents herein.
5. Ms. Welch, Real Party in Interest, is a candidate for City Council of the City of
Emeryville in the November 2, 2021 special election to fill a vacancy created by a Council
Member’s resignation. Ms. Welch submitted a candidate statement that contains a factually
inaccurate representation that Ms. Welch is “the first Black woman in 34 years to seek a seat on
Council.” In fact, a Black woman sought a seat on City Council in Emeryville in 2016.
JURISDICTION & APPLICABLE LAW
6. This Court has jurisdiction over this matter pursuant to Elections Code sections
13313 and 13314.
7. This Petition is brought pursuant to section 13313, subdivision (b):
(1) During the 10-calendary-day public examination period provided
by this section, any voter of the jurisdiction in which the election is
being held, or the elections official, himself or herself, may seek a
writ of mandate or an injunction requiring any or all of the material
in the candidates statements to be amended or deleted. The writ of
mandate or injunction request shall be filed no later than the end of
the 10-calendar-day public examination period.
(2) A peremptory writ of mandate or an injunction shall issue
only upon clear and convincing proof that the material in question
is false, misleading, or inconsistent with the requirements of this
chapter, and that issuance of the writ or injunction will not
substantially interfere with the printing or distribution of official
election materials as provided by law. (Emphasis added.)
(3) The elections official shall be named as respondent and the
candidate who authored the material in question shall be named as
the real party in interest. In the case of the elections official bringing
the mandamus or injunctive action pursuant to this subdivision, the

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board of supervisors of the county shall be named as the respondent
and the candidate who authored the material in question shall be
named as the real party in interest.
(Elec. Code § 13313(b).)
8. Section 13307, subdivision (a)(1) permits each candidate for nonpartisan elective
office in any city to prepare a candidate’s statement that includes the “name, age, and occupation
of the candidate and a brief description…of the candidate’s education and qualifications
expressed by the candidate himself or herself.” Subdivision (a)(3) provides that the statement
may be withdrawn, but not changed, during the period for filing nomination papers and until 5:00
p.m. the next working day after the close of the nomination period.
FACTUAL ALLEGATIONS
9. On August 4, 2021, Ms. Welch submitted her papers and candidate statement for
her candidacy for member of City Council for the City of Emeryville in Alameda County,
California in the November 2, 2021 election. (Hartz Decl., ¶ 2.) As part of that submission, Ms.
Welch signed a statement and took an oath affirming everything submitted was true and correct.
(Hartz Decl., ¶ 2; Declaration of Courtney Welch (“Welch Decl.”), ¶ 2.)
10. Shortly after submission, Ms. Welch’s campaign discovered that the candidate
statement contained a factual error because it contained the statement: “[a]s the first Black
woman in 34 years to seek a seat on Council,” however, another Black woman, Brynnda Collins,
ran for a City Council seat in Emeryville in 2016. (See Welch Decl., ¶ 3, Exs. 1 & 2.)
11. Immediately upon learning of the factual inaccuracy, Ms. Welch’s campaign
contacted Petitioner to advise of the error and request that the language be stricken from the
statement. (Welch Decl., ¶ 4, Hartz Decl., ¶ 3, Ex. 1.)
12. When Ms. Welch’s campaign brought the error to Petitioner’s attention, Petitioner
confirmed the factual inaccuracy of the statement at issue. (Hartz Decl., ¶ 4.)
13. The nominations period for the November 2, 2021 election closed on
August 6, 2021 at 5 p.m. (Hartz Decl., ¶ 5.)
14. On information and belief, the voter information pamphlet printing deadline for
the November 2, 2021 special election August 27, 2021. (Hartz Decl., ¶ 6.)

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EQUITABLE RELIEF IS APPROPRIATE AND JUSTIFIED
15. The issuance of the requested writ of mandate will not substantially interfere with
the conduct of the election insofar as there is sufficient time for the parties to brief the matter and
for oral argument to be held and a trial court decision rendered prior to the August 27, 2021 voter
information pamphlet printing deadline.
16. Should the requested writ not issue, irreparable harm will occur in that the false
information in Ms. Welch’s candidate statement will appear in the voter information pamphlet
and on the ballot, which is likely to mislead and/or confuse voters.
17. Petitioner is entitled to prompt judicial review of this matter, and this procedure
for a writ of mandate is the appropriate procedure for obtaining that judicial review.
FIRST CAUSE OF ACTION
(Petition for Writ of Mandate – Elections Code, §§ 13313(b)(2) & 13314)
Against Respondents
18. Petitioner realleges and incorporates herein by reference the allegations of
paragraphs 1 through 17, inclusive.
19. The statement, “[a]s the first Black woman in 34 years to seek a seat on Council”
is false in light of the fact that a Black woman ran for a Council seat in Emeryville in 2016.
20. Based on the foregoing, Petitioner is entitled to a writ of mandate pursuant to
Elections Code section 13313, subdivision (b)(2), striking the following language from the
candidate statement submitted by Ms. Welch: “As the first Black woman in 34 years to seek a
seat on Council.”
PRAYER
WHEREFORE, Petitioner prays:
1. That this Court issue a peremptory writ of mandate directing Respondents to
amend the candidate statement of Real Party in Interest Welch to delete the language : “As the
first Black woman in 34 years to seek a seat on Council” before the candidate statement is
included in the official election materials for the November 2, 2021 special election; and

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2. That this Court grant such other and further relief as may be just and proper.
Dated: August 11, 2021 BEST BEST & KRIEGER LLP
By:
MALATHY SUBRAMANIAN
A. PATRICIA URSEA
EMILY CHAIDEZ
Attorneys for Petitioner
Sheri Hartz, City of Emeryville Elections
Official

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PROOF OF SERVICE
At the time of service I was over 18 years of age and not a party to this action. My
business address is 300 South Grand Avenue, 25th
Floor, Los Angeles, CA 90071. I am a resident
and/or employed in the county where the service occurred.
On August 11, 2021, I served the following document(s):
PETITION FOR PEREMPTORY WRIT OF MANDATE PURSUANT TO
ELECTIONS CODE SECTION 13313 SUBDIVISION (b)(2)
 By United States mail. I caused the document(s) listed above to be placed in a
sealed envelope or package addressed to the persons at the addresses listed below..
I am a resident and/or employed in the county where the mailing occurred. The
envelope or package was placed in the mail at Los Angeles County, California.
 Deposited the sealed envelope with the United States Postal Service, with
the postage fully prepaid.
 Placed the envelope for collection and mailing, following our ordinary
business practices. I am readily familiar with this business's practice for
collecting and processing correspondence for mailing. On the same day that
correspondence is placed for collection and mailing, it is deposited in the
ordinary course of business with the United States Postal Service, in a
sealed envelope with postage fully prepaid.
 By Federal Express Overnight delivery. I caused the documents to be placed in
an envelope or package provided by Federal Express an overnight delivery carrier
and addressed to the persons at the addresses listed below. The envelope or
package were placed for collection and overnight delivery at an office or a
regularly utilized drop box of the overnight delivery carrier.
 By e-mail or electronic transmission. Based on a court order or an agreement of
the parties to accept service by e-mail or electronic transmission, I caused the
documents to be sent to the persons at the e-mail addresses listed below. I did not
receive, within a reasonable time after the transmission, any electronic message or
other indication that the transmission was unsuccessful.
Raymond Lara
Office of the County Counsel
1221 Oak Street, Ste. 450
Oakland, CA 94612
Telephone: 510-272-6700
Email: raymond.lara@acgov.org
Counsel for Respondents
Courtney Welch
courtneyforemeryville@gmail.com
Real Party in Interest

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I declare under penalty of perjury under the laws of the State of California that the above
is true and correct.
Executed on August 11, 2021, at Los Angeles, California.
_____________________________________
Joy Oates

83578.0011334269267.4
DECLARATION OF SHERI HARTZ
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Declaration of Sheri Hartz
I, Sheri Hartz, declare as follows:
1. I am the City Clerk for the City of Emeryville, a municipal corporation organized
and existing under the laws of the State of California. As City Clerk, I am charged with
responsibility for preparing the candidates’ statements for inclusion with the voter information
pamphlet for the November 2, 2021 City Council special election for the City of Emeryville. I
have personal knowledge of the facts set forth in this declaration and could and would
competently testify thereto.
2. On August 4, 2021, Real Party in Interest Courtney Welch, a candidate for the
November 2, 2021 special election, submitted her papers and candidate statement. As part of that
submission, Ms. Welch signed a statement and took an oath affirming everything submitted was
true and correct. A true and correct copy of Ms. Welch’s candidate statement may be found
online at: https://www.ci.emeryville.ca.us/1094/Candidates, and a true and correct copy of a clip
of the City’s website bearing Ms. Welch’s statement is attached hereto as Exhibit 1.
3. Later that same day, Welch’s campaign contacted my office to advise that the
statement “[a]s the first Black woman in 34 years to seek a seat on Council” in Welch’s candidate
statement was false because another Black woman, Brynnda Collins, ran for a City Council seat
in Emeryville in 2016. A true and correct copy of the email from Welch’s campaign alerting my
office of the inaccuracy is attached hereto as Exhibit 2.
4. Upon being alerted of the error in the candidate statement, I confirmed that the
representation at issue is false.
5. The nominations period for the November 2, 2021 election closed on
August 6, 2021 at 5:00 p.m.
6. It is my understanding that the deadline for Respondents Alameda County Board
of Supervisors and Alameda County Registrar of Voters to finalize the voter information
pamphlet and related election materials and forward them for printing is August 27, 2021.

1
From: Dyana Marie Delfin Polk <campaignmanagerdyana@gmail.com>
Sent: Wednesday, August 4, 2021 4:37 PM
To: Sheri Hartz <shartz@emeryville.org>; Courtney Welch <courtneyforemeryville@gmail.com>; Andrea Visveshwara
<avisveshwara@emeryville.org>; Lorrayne Leong <lleong@emeryville.org>; Michael Guina <mguina@emeryville.org>;
Sheri Hartz <shartz@emeryville.org>
Subject: Re: [External] Error in Candidate Statement for Courtney Welch
Hi Sheri, upon further research, the candidate statement draft that was submitted contained a factual error. According
to Elections Code 13107, we cannot replace the statement, we can only withdraw. However, we interpret the Elections
Code to give the City Clerk the ability to allow changes only if a statement is known to be untrue. The portion of the
candidate statement that is factually incorrect is "As the first Black woman in 34 years to seek a seat on Council,.." This is
not true. Brynnda Collins ran for a city council seat in 2016, she is now President of the Emery USD School Board.
The candidate, Courtney Welch, signed a statement and took an oath that stated everything that was submitted was
true and correct. The campaign found out that the language provided in that sentence is in fact, factually incorrect and is
advising the City Clerk's office of this error as soon as it was made available to the campaign. We are recommending that
the language that is incorrect be stricken from the candidate statement. We understand that the candidate statements
are published for 10 days after the filing period and there is potential for someone to file a writ of mandamus against
the Clerk and name Courtney Welch as an interested party. The matter gets court priority, and if the facts are
determined to be inappropriate or untrue, the court could strike some or all of the statement itself. With the hopes of
avoiding that situation and to avoid offending a current elected official in Emeryville, we are requesting that the City
Clerk strike "As the first Black woman in 34 years to seek a seat on Council,.." from Courtney Welch's candidate
statement, as the Elections Code interpretation we are providing allows the City Clerk to do so.
We are copying the Emeryville City Attorney to get an opinion on this matter as well. We hope to resolve this matter
expeditiously.
Thank you,
On Wed, Aug 4, 2021 at 2:51 PM Dyana Marie Delfin Polk <campaignmanagerdyana@gmail.com> wrote:
Sheri, can we use the following language for Courtney's candidate statement? We submitted the wrong version in
error.
Courtney Welch
Policy Director
As a community advocate, a mom and housing champion, I am honored to run for Emeryville City Council. I am an
East Bay native and moved to Emeryville’s Christie Core neighborhood to raise my two sons. In a professional
capacity, I work on affordable housing policy and currently serve on Emeryville’s Housing Committee, working with
city and community partners to develop solutions to our housing crisis. In addition to my housing background, I am
also a former small business owner and prioritize economic and small business development while balancing public
health concerns during the COVID-19 pandemic. Additional priorities include increased public transit accessibility,
addressing public safety concerns, keeping our budget financially solvent and ensuring that Emeryville’s working
families are represented in government. I hope to earn your support.

2
--
Dyana Marie Delfín Polk, MPP
CampaignManagerDyana@gmail.com
(209) 658-5837 (mobile)
--
Dyana Marie Delfín Polk, MPP
CampaignManagerDyana@gmail.com
(209) 658-5837 (mobile)

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PROOF OF SERVICE
DECLARATION OF SHERI HARTZ
Raymond Lara
Oakland, CA 94612
Telephone: 510-272-6700
Courtney Welch

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I declare under penalty of perjury under the laws of the State of California that the above
is true and correct.
Executed on August 11, 2021, at Los Angeles, California.
_____________________________________
Joy Oates

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DECLARATION OF COURTNEY WELCH
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Declaration of Courtney Welch
I, Courtney Welch, declare as follows:
1. I am a candidate for Emeryville City Council in the November 2, 2021 special
election. I have personal knowledge of the facts set forth in this declaration and could and would
competently testify thereto.
2. On August 4, 2021, my campaign submitted my candidacy papers, including my
candidate statement, to the City Clerk for the City of Emeryville (“Petitioner”), including an oath
signed by me that the materials submitted were true and correct. At the time, I believed the
contents of my candidate statement to be true.
3. Later the same day, my campaign discovered that the candidate statement I had
submitted contained a factual error. The portion of the candidate statement that is factually
incorrect is "As the first Black woman in 34 years to seek a seat on Council". In fact, Brynnda
Collins, who is also a Black woman, ran for an Emeryville City Council seat in 2016. Ms.
Collins is currently President of the Emery Unified School District School Board. A true and
correct clip of Ms. Collins’ biographical information from the Emery Unified School District
website is attached hereto as Exhibit 1. A true and correct copy of an election-related article
dated September 15, 2016, entitled “2016 Emeryville City Council Candidate Questionnaire:
Brynnda Collins,” is attached hereto as Exhibit 2.
4. Immediately upon discovering that the campaign statement contained this factual
error, my campaign contacted Petitioner to advise of the error. I understand that a candidate is
permitted by law only to withdraw, but not change, a candidate statement once it has been
submitted. My campaign therefore requested Petitioner bring this petition to seek a writ directing
that the factually inaccurate language be stricken from my candidate statement.

8/9/2021 2016 Emeryville City Council Candidate Questionnaire: Brynnda Collins - The E'ville Eye Community News
https://evilleeye.com/news-commentary/politics/2016-emeryville-city-council-candidate-questionnaire-brynnda-collins/ 1/7
Search Here SEARCH
2016 EMERYVILLE CITY COUNCIL CANDIDATE QUESTIONNAIRE:
BRYNNDA COLLINS
Published On September 15, 2016 | By Rob Arias | 2016-Candidate Questionnaires, Election Coverage, Local
Government, News & Commentary, Politics
This 2016 Emeryville City Council election will see six candidates vying for three available seats in
what could see a shift in city priorities. The E’ville Eye distributed twenty questions covering a gamut
of relevant topics in our city to each candidate. Our hope is to help our readers better understand the
priorities of each candidate and see where they align with your own. Candidate Questionnaires will
be published daily over the next week in the order they will appear on the ballot which is determined
randomly by our Secretary of State (John Van Geffen, Louise Engel, Christian Patz, Brynnda
Collins, Ally Medina & John Bauters). Candidates have been instructed to provide answers no
longer than 250 words.
Next up is former EUSD employee Brynnda Collins. Collins is mother to recently appointed Emery
School Board Trustee Brittany Collins-Rogers. In addition to traffic, public safety, schools, small
businesses and tenant rights, Brynnda vows to make community building one of her top priorities.
“Using a proven track record for building networks and effective personal relationships, I intend to
accomplish creating a sense of family and bridging the gaps throughout our wonderful city”. If
elected, Brynnda would be the first female African-American Councilmember since Nellie Hannon
who served from 1983-87.
Brynnda Collins: Youth Development Coordinator
1). Please state your party affiliation (i.e. Democratic, Green Party, Republican, Independent,
Libertarian, etc.) and please list any campaign donations you’ve received or have been
pledged by PACs.

Democratic Party / Funding for my campaign has been raised by The Committee to Elect Brynnda
Collins in addition to donations from friends and family. Former Emeryville Mayor Kurt Brinkman has
been a great supporter.
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2). How long have you lived in Emeryville, what has your involvement been with the city thus
far and what compelled you to run for council?

While living in Emeryville for the past 13 Years. I am deeply engaged in outreach with the Alameda
County Fire Dept., Emeryville Police Dept. and Emeryville’s Community Action Program as well as
spending many hours working with the city and schools. While sitting on the Traffic Planning
Committee, helping to form the COC (which is the body that oversees the expenses of the Center for
Community Life project) sitting on several city art committees and completing Emeryville’s Citizens
Police Academy I have received a deeper understanding of our community. I have been called to
action for council knowing that I have the ability to address issues within our community with positive
outcome.
3). What is your professional background and explain how this is applicable to local
government.
As a programs and project coordinator, I have demonstrated outstanding leadership skills by
participating on several committees throughout the city and for the school district. Including but not
limited to the Wellness Team, Instructional Leadership Team, the Response to Intervention and
Instruction Team, the School Site Council (chair), and the Parent-Teacher Organization (President).
As a participant of these teams, I was instrumental in making the decisions, planning, and facilitation
of the school redesign work for Emery Secondary and the Emery Unified School District. I have a
combined strong sense of character and leadership skills to make a positive impact on our city,
schools and community.
4). List your top-5 priorities in order, explain why and list one specific thing you intend to
accomplish in your four year term should you be elected.

Addressing our issues in regards to traffic, public safety, schools, small businesses, as well as
respecting the renters of Emeryville are some of my top priorities. These are some of our ongoing
issues in Emeryville in addition to creating greener space and bike safety. Using a proven track
record for building networks and effective personal relationships, I intend to accomplish creating a
sense of family and bridging the gaps throughout our wonderful city.
5). You hear people’s desires for a “vibrant community” thrown out a lot in political
discussions. What does a vibrant community mean to you?

A Vibrant community has many looks, they stem from the exterior of what we see on the outside to
how we feel on the inside. A vibrant community should also include love and kindness. Personal
connection and meeting the needs of our community is also a huge part of creating a vibrant
community.
6). Will you gather community input outside of the dais and if so, how (social media, your own
blog, guest posts on The E’ville Eye)? Would you be supportive of a neighborhood council to
better understand the perspectives of the different neighborhoods and demographics of our
city that don’t always have time to attend council meetings?

This question targets a huge area in which I intend to focus on. I feel a need to deepen our
community outreach, engagement and input. Yes, I most certainly will gather input targeting the
means in which it will take to reach our community. We must have a line of communicating in no less
than five areas of communications, in order to be inclusive of our community members. Social media
is a must now days to keep our communications progressive with today’s tech world. However, we
must always remember the community members that may not be tech savvy and resort to phone
calls, our postal service and good old word of mouth. I would be in full support of neighborhood
council and have recently been engaged in conversation in regards to needing transparency for
community to understand what’s taking place in our city if not able to attend meeting or study
sessions.
7). What do you think the most important outcome of the Sherwin Williams project is for our
city (i.e., the inclusion of ownership housing, maximizing the percentage of “affordable” units,
Parking & Traffic Mitigation, etc.)?

I firmly believe the project itself need to have an important outcome overall. Include i.e ownership
housing, affordable housing without segregation, green space, bike safety, safe hiking and walking
trails while offering safe connections and calm traffic.
8). The ECCL finally opened its doors after being in the works for more than a decade. Would
you (theoretically) have any reservations sending your children to a K-12 school? Will you
fight to retain Anna Yates Elementary as part of the EUSD?

My daughter was a student at a K-12 school from grade K-6, however, private and with much smaller
enrollment than offered through EUSD, I did have concerns with the high school students on the
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same campus with the elementary age students. We relocated to Emeryville where she than moved
forward attending Emery Secondary. Again, I had reservations with the middle school being housed
on a high school campus. Seeking employment with the district offered me the opportunity in
assuring the health and welfare of not just my own student but of the overall student population. As a
member of the ECCL redesigning committee, I fought hard to retain Anna Yates Elementary as part
of EUSD strongly thinking that the large concerns and reservations expressed by the parents and
staff consolidating both schools should have been considered in the decision making process.
9). Can you reference any conversations you’ve had with the owners of any non-publicly
subsidized businesses in our city and do you get the sense that they’re thriving or struggling
and what their sentiment toward operating in our city is?

I have had several conversations in regards to the struggles some of the small business owners are
facing in Emeryville. One reference in particular has mentioned that in will not be feasible for her to
continue running her business in Emeryville much long with our minimum wage trajectory and Fair
Work Week. Her feeling expressed there has been a war waged on small businesses in Emeryville.
10). Is retaining and in fact growing our base of small businesses important to you and what
will you commit to doing to help small businesses thrive in our city if elected?

Retaining and growing small business help to create the strong sense of community that can be
offered throughout our city which will become more attractive to families. If elected I will commit and
keep our city from turning into large commercial space by reaching out to the small business
community, address their concerns and moving forward with action to make sure small business
owners know they too are part of community helping to create a vibrant city.
11). Governor Jerry Brown recently signed a $15 minimum wage into state law that includes
gradual increases and “off-ramps” in the event of economic consequences. If the impacts of
our local MWO are proven to have the negative impacts that were predicted by business,
would you be willing to “pause” ours and defer to the state model? Do you see the advantage
of a regional approach to passing economic policies?

If the impacts of our local MWO are proven to have the negative impacts predicted, I would be willing
to revisit ours and possibly deferring to the state model. I see advantages as well as disadvantages
and would like to see a study on regional competitiveness.
12). Our current council is looking to implement a scheduling & employment ordinance being
referred to as “Fair Work Week”. Do you support this ordinance? Do you foresee any
unintended consequences that could come from this?

Data from the “Fair Work Week” study session are reflecting no changes are needed. However,
several employees throughout the city have no idea the survey existed. After hearing story after story,
opinions and deep hearted feeling of both employers and employees we must focus on what will
work and what won’t. I realize some of the expressed issues need to be addressed on a case by
case basis. Employers are always going to need to make last minute changes needed to
accommodate real life events happening with employees as well as the stability of running their
business. On the other note employees have the right to fair working respectable hours with and
affordable wages. I foresee unintended consequences and hear talk of businesses leaving Emeryville
with the current ordinance. Our council should offer support that comforts employer and employee
fairness.
13). Do you feel being the “model city” for new legislation by labor groups puts our
businesses at a competitive disadvantage? Do you have any concerns that businesses will
choose neighboring cities instead of settling in Emeryville or of our city developing the
stigma of being labeled “Anti-Business”?

As stated in a previous question small businesses are starting to feel as if a war has been waged
against them in Emeryville. I have great concerns that businesses will choose neighboring cities.
14). I think a lot of us would like some form of “Rent Control” but achieving this in actuality is
complicated and limited. How can we maintain affordability in our city and protect existing
residents from getting priced out?

I have been looking into the affordable housing issue in Emeryville. It will take intensive work but
most certainly can take place in Emeryville as it does in joining cities. If elected I intend to form a
Rental/ Landlord Accountability Task Force for starters.
15). Which intersections do you think deserve the most attention in regards to Traffic
Mitigation and Bike/Ped safety?

After seeing someone on his bike get hit by a car just a few weeks ago I would say the area entering
and leaving Target need immediate mitigation.
RECENT COMMENTS
»
Rob, I know the pain you’re going
through. My beautiful......
Dan Craver »
I think you are correct, who
rescued who? So very......
Benay »
Your story is testimony that the
joy Fiona brought you......

16). Emeryville is consistently listed as one of the statistically most violent cities in the Bay
Area and crime in our city is on the rise (Much of this crime is petty theft attributed to our
shopping centers and auto burglaries because of this and our base of hotels). In terms of
public safety, what resources or legislation will you be supportive of to allow the EPD to do
their best job keeping our residents safe?

There has to be conversations with the EPD as to what supportive measures they feel should be
taken and the role they would need the council to play in assisting with public safety. I would
however, like to establish crime busters in every neighborhood where citizens are educated and
aware of suspicious behavior while learning how to safely reporting their observations without fear.
17). Homelessness is a regional and very complex issue. Encampments continue to pit
neighbors against the unhoused and create quality of life issues for residents. We know
“kicking them out” doesn’t solve anything … but neither does the status quo. What solutions
are you most supportive of and can you commit to working regionally with neighboring cities
to help alleviate this humanitarian crisis?

Homeless need to be addressed and quickly. I would like to work on using vacant space for housing
offering a work study program that will lead to self sufficiency.
18). We’ve often advocated for a “resident first” approach to policymaking meaning resident
considerations should come before outside special interest groups (such as Oakland-based
labor organizations) or at least negative impacts on residents should be divulged and
communicated. Do you agree or disagree with this and why?

I agree on resident first approach, although the views of special interest groups are valuable the
voice of the residence is what should count. We are the people who are the face of community and
have to live here while the special interest groups give their input they can’t call Emeryville home.
19). Civic participation and community spirit in Emeryville is sadly lacking. Do you have any
ideas to further community building in our town? Do you think resident retention and
ownership opportunities are important components to this equation?

Civic participation and community spirit most certainly needs attentions in Emeryville. By electing me
to council you will help to bridge the gaps and improve spirit in our city. I have many great ideas and I
am passionate about serving our children and elders and building the capacity of others to create
positive change. I am confident that my personal strength along with my strong background makes
me an excellent candidate to build community. Resident retention and ownership opportunities are
most certainly essential to community spirit.
20). A huge focus of our site is civic transparency and oversight. We’re in a unique position to
facilitate communication with our residents as Emeryville’s largest media outlet with an
estimated quarter of the population visiting our site regularly (and growing every year). Can
we get your guarantee that you’ll be responsive to our inquiries even in the event we disagree
on something?

I can guarantee that I will be responsive to your inquiries and firmly believe in transparency. In times
of agreement or disagreement the community has a right to know what’s going on throughout our city.
Follow Brynnda on her Facebook Page →
E’ville Eye Preliminary Readers Poll:
Based on what you know thus far, which three candidates will you vote for on November 8th?
John Van Geffen (Attorney / Father / Volunteer)
Louise Engel (Businesswoman / Urban Planner)
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ABOUT THE AUTHOR
← Previous post Next post →
2 RESPONSES TO 2016 EMERYVILLE CITY COUNCIL CANDIDATE QUESTIONNAIRE: BRYNNDA
COLLINS
Rob Arias
is a third generation Californian and East Bay native who moved to Emeryville in
2003. A new parent in the community, he can often be seen walking his French Bulldog rescue
"Fiona" around his Park Avenue District neighborhood, traversing the greenway on his bike or
enjoying his favorite Emeryville small businesses. Rob's "day job" is as a creative
professional.
Richard Ambro, Ph.D. says:
September 27, 2016 at 3:54 pm
Brenda, It is critical that you get better known… beginning with plastering your smiling face all over.. do you
have campaign posters? A Black, renter CC candidate with an agenda should be welcome among renter
Emeryvilleans and Progressives. We need protection of Rent Control, Renter Justice, Diversity, and Working
Class Ethics. Our Emeryville City Council and City Government has been too Lilly-White. We desperately
need Blacks, Asians and Latinos/ Latinas in City Government.
Reply
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PROOF OF SERVICE
DECLARATION OF COURTNEY WELCH
Raymond Lara
Oakland, CA 94612
Telephone: 510-272-6700
Courtney Welch

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PROOF OF SERVICE
[PROPOSED] ORDER
Raymond Lara
Oakland, CA 94612
Telephone: 510-272-6700
Courtney Welch

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NOTICE AND EX PARTE APPLICATION
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TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD:
PLEASE TAKE NOTICE THAT, pursuant to California Rules of Court, Rule 3.1200 et
seq., Petitioner Sheri Hartz (“Petitioner”) hereby applies ex parte for issuance of a peremptory
writ of mandate requested in her Petition, filed concurrently, seeking that Respondents Alameda
County Board of Supervisors and Alameda County Registrar of Voters (“Respondents”) be
ordered to amend the candidate statement of Real Party in Interest Courtney Welch (“Ms.
Welch”) to delete a portion of the candidate statement that was discovered to be false.
Alternatively, Petitioner requests issuance of an alternative writ of mandate ordering Respondents
to show cause as to why the Court should not order the above-described amendment and setting a
briefing schedule and hearing date for a writ of mandate as soon as possible so as not to
substantially interfere with the printing and distribution of official election materials.
Per Emergency Local Rule 1.8(a)(h)(3), this ex-parte application may be set for a remote
hearing, if at all, on a date and time set by the Court.
This writ is sought under Elections Code sections 13313 and 13314 on the grounds that
Ms. Welch’s candidate statement contains false material and that a neglect of duty or an error or
omission will occur in the printing of the voters’ information pamphlet for the November 2, 2021
election without the requested deletion. If this ex parte relief is not granted, the public will be
irreparably harmed in that false material will be included in Ms. Welch’s candidate statement in
the voters’ information pamphlet.
This ex parte application is made pursuant to California Rule of Court (“CRC”) 3.1200 et
seq. Ex parte relief will ensure that the November 2, 2021 election and printing of related
materials may proceed according to schedule. As set forth in the attached Declarations of A.
Patricia Ursea and Andrea Visveshwara, notice of this ex parte application was provided to
counsel for Respondents and Ms. Welch as required by law and CRC 3.1203 and 3.1204. (See
attached Declarations of A. Patricia Ursea, ¶ 3 and Andrea Visveshwara, ¶ 2.)
Pursuant to CRC 3.1202(a), the parties or attorneys for the parties can be reached at the
following addresses, e-mail addresses, and phone numbers:

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Respondents
Raymond Lara
1221 Oak ,St Ste 450, Oakland, CA 94612
510-272-6700
raymond.lara@acgov.org
Courtney Welch
This ex parte application is made pursuant to CRC 3.1200 through 3.1207 on the grounds
that good cause exists for the requested relief as discussed above. It is based on this application,
the attached memorandum of points and authorities, the attached Declarations of A. Patricia
Ursea and Andrea Visveshwara, the pleadings and records on file with the Court in this matter,
and such further evidence and argument as the Court may choose to consider.
By:
MALATHY SUBRAMANIAN
A. PATRICIA URSEA
EMILY CHAIDEZ
Official

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MEMORANDUM OF POINTS AND AUTHORITIES
I. INTRODUCTION
Petitioner Sheri Hartz, in her capacity as City Clerk for the City of Emeryville and the
Elections Official for the City of Emeryville (“Petitioner”), submits this memorandum of points
and authorities in support of her ex parte application as follows:
After submission of her candidate statement in support of her candidacy for City Council
in the November 2, 2021 special election, Real Party in Interest Courtney Welch (“Ms. Welch”)
notified Petitioner that the submitted candidate statement contained false information.
Specifically, the statement included a representation that Ms. Welch was the first Black woman to
seek a seat on City Council in the last 34 years; in fact, another Black woman sought a seat on
City Council in 2016. California Elections Code permits a candidate to withdraw, but not change,
a candidate statement once it has been submitted. (Elec. Code § 13107.) The Elections Code also
provides for injunctive relief or the issuance of a peremptory writ of mandate striking false
information from a candidate statement upon clear and convincing proof that the material in
question is false. (Elec. Code § 13313, subd. (b).)
For the reasons set forth below, the Court should issue a writ of mandate directing
Respondents to delete the false statement in Ms. Welch’s candidate statement.
II. STATEMENT OF FACTS
As a candidate for Emeryville City Council in the November 2, 2021 special election to
fill a vacancy left a Council Member resignation, Ms. Welch submitted a candidate statement to
Petitioner on August 4, 2021 containing the following statement: “As the first Black woman in 34
years to seek a seat on Council,…”. (See Petition, ¶ 9.) Shortly after submitting the statement,
Ms. Welch’s campaign discovered the error and immediately contacted Petitioner to advise of the
error and request that the language be stricken from the statement. (Petition, ¶¶ 10-11.) On
August 6, 2021 at 5 p.m., the nominations period for the November 2, 2021 election closed.
(Petition, ¶ 13.) The deadline for Respondents Alameda County Board of Supervisors and
Alameda County Registrar of Voters (“Respondents”) to finalize the election materials and voter
information pamphlet for submission to the printers is August 27, 2021. (Petition, ¶ 14)

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III. ARGUMENT
Elections Code section 13313, subdivision (b)(1) provides that during the 10-calendar-day
public examination period following the close of the nominations period, the elections official
“may seek a writ of mandate or an injunction requiring any or all of the material in the candidates
statements to be amended or deleted.” That section also provides that a “peremptory writ of
mandate or an injunction shall issue only upon clear and convincing proof that the material in
question is false…and that issuance of the writ or injunction will not substantially interfere with
the printing or distribution of official election materials.” (Elec. Code § 13313 (b)(2).)
Elections Code section 13307 sets forth the information to be included in a candidate’s
statement. In construing that section in light of an opposing candidate’s petition for a writ
seeking to delete certain paragraphs from another candidate’s statement, one court explained:
The language of section 13307 is unambiguous. “The statement may
include the name, age and occupation of the candidate and a brief
description...of the candidate's education and qualifications....” As
noted by the Supreme Court in Clark v. Burleigh (1992) 4 Cal.4th
474, 14 Cal.Rptr.2d 455, [t]he negative implication of this specific
list, of course, is that the Legislature did not intend the statutory
candidate’s statement to contain any other material: expressio unius
est exclusio alterius.
(Dean v. Superior Court of Orange County (1998) 62 Cal.App.4th 638, 641 [citations omitted].)
The court in Dean granted the petition, directing that the first three paragraphs of the
statement, which were dedicated to attacking his opponent’s qualifications, be stricken. (Id. at p.
642.) Similarly, a candidate statement containing false information must also be stricken where it
is challenged by petition and clear and convincing proof indicates the information is false. (Elec.
Code § 13313(b)(2).)
As shown below and in the Petition, the statement that Ms. Welch is the first Black
woman in 34 years to seek a seat on City Council is false and must be deleted. The same day Ms.
Welch submitted her candidate statement, her campaign contacted Petitioner to advise of the false
information. (Petition, ¶¶ 10-11.) In addition, Ms. Welch signed a declaration, filed with the
Petition, stating unequivocally that the information is false and attaching an article referencing the
candidacy of another Black woman in the 2016 election. (See Welch Decl., ¶ 3, Exs. 1 & 2.)

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The portion of Ms. Welch’s candidate statement that is false should be deleted by order of
the Court. (Elec. Code § 13313(b)(2); see Dean, supra, 62 Cal.App.4th at 641.)
IV. CONCLUSION
For the foregoing reasons, Petitioner respectfully requests the Court order Respondents to
delete the aforementioned statement in the candidate statement of Ms. Welch.
By:
MALATHY SUBRAMANIAN
A. PATRICIA URSEA
EMILY CHAIDEZ
Official

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DECLARATION OF A. PATRICIA URSEA
I, A. Patricia Ursea, declare as follows:
1. I am an attorney with the law firm of Best Best & Krieger, LLP, counsel of record
for Petitioner Sheri Hartz. I make this declaration in support of Petitioner’s ex parte application,
and I have personal knowledge of the facts set forth herein and could and would competently
testify thereto.
2. Petitioner filed this action on August 11, 2021. On that same day, Petitioner filed
this ex parte application.
3. Prior to filing the petition and this ex parte application, on August 10, 2021, I
notified counsel for Respondents Alameda County Board of Supervisors and Alameda County
Registrars of Voters via telephone that Petitioner was planning to file this ex parte application. I
left a voicemail. I sent e-mail notice on August 10, 2021 as well and counsel for Respondents
acknowledged receipt of that email on the same day.
I declare under penalty of perjury under the laws of the State of California that the
foregoing is true and correct.
Executed this 11th day of August, 2021 at Los Angeles, California.
A. Patricia Ursea

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14
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19
20
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B
EST
B
EST
&
K
RIEGER
LLP
A
TTORNEYS
AT
L
AW
300
S
OUTH
G
RAND
A
VENUE
,
25
TH
F
LOOR
L
OS
A
NGELES
,
C
ALIFORNIA
90071
PROOF OF SERVICE
Raymond Lara
Oakland, CA 94612
Telephone: 510-272-6700
Courtney Welch

2021 Emeryville Special Election Petition

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2021 Emeryville Special Election Petition