The following excerpt is from Fleming v. City Of Oceanside, CASE NO. 10cv1090-LAB (BLM) (S.D. Cal. 2011):
Fleming relies upon DuCharme v. Int'l Bhd. of Elec. Workers, 110 Cal.App.4th 107, 118 (2003), for the proposition that "the constitutionally protected activity must at a minimum occur in the context of an ongoing controversy, dispute, or discussion, such that it warrants protection by a statute that embodies the public policy of encouraging participation in matters
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