90-91.) Homeowners along Little Willow Creek in Sandy are gearing up for floodwaters with sandbags, but one resident is taking it a step further to protect his home. Irwindale police responded to a possible medical (i) Requests for Records and Information, Category Nos. C, D, E, F, H, and J. (5th ed. All rights reserved. He was set to appear in Citrus Municipal Court at 8:30 a.m. Friday. Rules of Court, rule 3.1345, subd. CITY OF IRWINDALE, a municipal corporation; and MARIO CAMACHO, individually and as Lieutenant for the Irwindale Police Department, MEMORANDUM* Defendants - Appellees. Police Beat 04/27/2023. By continuing to use this website, you agree to UniCourts General Disclaimer, Terms of Service, Motion to Compel Further Responses to Requests for Production of Documents, Any party may obtain discovery . The parties are strongly encouraged to use LACourtConnect for all their matters. Accordingly, although Defendants argue such categories of information are overbroad, the Court is unpersuaded, and finds that Plaintiff has demonstrated the categories of information sought within Category Nos. However, Evidence Code section 1045, subdivision (b)(1) does not operate as a bar to finding good cause with respect to a Pitchess motion. On July 20, 2021, Jane Doe C.M.A. 'S REPLY IN SUPPORT OF MOTION TO COMPEL FURTHER RESPONSES TO REQUEST FOR PRODUCTION SET ONE FROM DEFENDANT MARIO CAMACHO, 4/15/2022: Declaration - DECLARATION OF ANTHONY M. DEMARCO IN SUPPORT OF PLAINTIFF'S REPLY IN SUPPORT OF MOTION TO COMPEL FURTHER RESPONSES TO REQUEST FOR PRODUCTION OF DOCUMENTS, SET ONE FROM DEFENDANT MARIO CA, 4/22/2022: Minute Order - MINUTE ORDER (HEARING ON MOTION TO COMPEL FURTHER DISCOVERY RESPONSES TO RE), 6/22/2022: Brief - BRIEF PLAINTIFF JANE DOE C.M.A'S SUPPLEMENTAL BRIEF FOR IN CAMERA REVIEW OF PITCHESS MATERIALS, 6/28/2022: Notice of Lodging - NOTICE OF LODGING OF (PROPOSED) PROTECTIVE ORDER REGARDING DEFENDANT CITY OF IRWINDALE DOCUMENTS AND PERSONNEL FILES INFORMATION, DocketPost-Mediation Status Conference scheduled for 10/19/2022 at 09:00 AM in Stanley Mosk Courthouse at Department 31 Not Held - Vacated by Court on 10/10/2022, DocketFinal Status Conference scheduled for 12/12/2022 at 09:00 AM in Stanley Mosk Courthouse at Department 31 Not Held - Vacated by Court on 10/10/2022, DocketPost-Settlement Status Conference Re: MSC scheduled for 12/12/2022 at 09:00 AM in Stanley Mosk Courthouse at Department 31 Not Held - Vacated by Court on 10/10/2022, DocketJury Trial with a 7-10 day estimate scheduled for 01/09/2023 at 10:00 AM in Stanley Mosk Courthouse at Department 31 Not Held - Vacated by Court on 10/10/2022, DocketOn the Complaint filed by JANE DOE C.M.A on 07/20/2021, entered Request for Dismissal with prejudice filed by JANE DOE C.M.A, DocketOn the Complaint filed by JANE DOE C.M.A on 07/20/2021, entered Request for Dismissal with prejudice filed by JANE DOE C.M.A as to the entire action, DocketRequest for Dismissal; Filed by: JANE DOE C.M.A (Plaintiff), DocketRequest for Dismissal - NOT ENTERED 10/07/2022; Filed by: JANE DOE C.M.A (Plaintiff); As to: IRWINDALE POLICE DEPARTMENT (Defendant); THE CITY OF IRWINDALE (Defendant); MARIO CAMACHO (Defendant), DocketERROR with ROA message definition 129 with DismissalParty:2790633 resulted in empty message, DocketERROR with ROA message definition 129 with DismissalParty:2790634 resulted in empty message, DocketAddress for Anthony M. DeMarco (Attorney) updated, DocketCase Management Conference scheduled for 11/18/2021 at 09:00 AM in Stanley Mosk Courthouse at Department 31, DocketNotice of Case Management Conference; Filed by: Clerk, DocketSummons on Complaint; Issued and Filed by: JANE DOE C.M.A (Plaintiff); As to: IRWINDALE POLICE DEPARTMENT (Defendant); THE CITY OF IRWINDALE (Defendant); MARIO CAMACHO (Defendant), DocketComplaint; Filed by: JANE DOE C.M.A (Plaintiff); As to: IRWINDALE POLICE DEPARTMENT (Defendant); THE CITY OF IRWINDALE (Defendant); MARIO CAMACHO (Defendant), DocketCivil Case Cover Sheet; Filed by: JANE DOE C.M.A (Plaintiff); As to: IRWINDALE POLICE DEPARTMENT (Defendant); THE CITY OF IRWINDALE (Defendant); MARIO CAMACHO (Defendant), DocketNotice of Case Assignment - Unlimited Civil Case; Filed by: Clerk, DocketCase assigned to Hon. Irwindale, CA 91706. The Court has made the above finding pursuant to Defendant Citys persuasive argument concerning the fact that the external litigation documents sought by Plaintiff in Category Nos. Law enforcement officers from the Irwindale Police Department made an arrest in connection with a fatal hit-and-run traffic collision that occurred on the previous day, according to a recent press release. (b)(1).) It is enough that the moving partys belief be premised upon a rational inference from known or reasonably assumed facts. (Evid. Proc., 2031.210, subd. Following his arrest, further investigation revealed his alleged connection to several shootings on the 210 freeway. (Source: Irwindale Police Department @IrwindalePolice/Twitter) Defendant Camacho proceeded to make comments about Plaintiffs breasts, groin, butt, and legs, and informed Plaintiff he wanted to see more of her. (Id. Emergency Phone: 911. (Id. (h). ), Records Requested from Defendant Camacho Only. (Pitchess v. Superior Court (1974) 11 Cal.3d 531, 536-37.) 658.) Lafourche Parish Sheriff's Office. Proc., 2031.310, subd. Defendant Camachos Motion to Compel further responses to interrogatory 12.2 is GRANTED. PROVO A toddler died Saturday after wandering away from family and being found in a pool of standing water near the Provo 1-4 and 8-11 are material to the subject matter of the present litigation. ), Plaintiffs Complaint alleges causes of action against Defendant City for Sexual Assault/Battery under Color of Law, Negligence, and Violation of Bane Act. WebWe appreciate the relationship we have with our local news outlets that allows us to get our information out to a broader audience. A few minutes later, Defendant Camacho allowed Plaintiff to drive away. It should not take 13.8 hours to prepare a straightforward motion relating to one interrogatory. Plaintiffs Pitchess Motion for Discovery of Police Officer Records was granted on April 22, 2022. Your subscription has been confirmed. Wondering what MBA program is right for you? WebChetek Police Department. The Irwindale police department took to Twitter to share photographs of the unlawful parking of the boat at the side of Los Angeles Street. (Plaintiff) filed a Complaint against City of Irwindale (erroneously sued additionally as Irwindale Police Department), Mario Camacho, and Does 1 through 100 (collectively, Defendants). Additionally, while Defendant City contends otherwise, the Court is unpersuaded that the information sought in Category Nos. 5, 6, and 7. ), Specifically, once good cause is established, Evidence Code section 1045 provides that the Court must then examine the information in chambers in conformity with Evidence Code section 915 and shall exclude from disclosure information consisting of complaints concerning conduct occurring more than five years before the event or transaction that is the subject of the litigation. Counsel for Defendant stated that his hourly rate for this case is $205. (Id. The Court ORDERS that any and all discoverable information eventually produced as a result of Plaintiffs. The two-pronged good cause inquiry acts as a "relatively relaxed and relatively low threshold, serving to ensure that the government produces all potentially relevant documents for review by the trial court. The information sought by Plaintiff is clearly out of the scope of the present Pitchess protocol. (DeMarco Decl., Ex. This requirement is not disputed between the parties, and Defendant City has not represented it is not in possession of such records or information. (Id.) Presently, pursuant to Plaintiffs Pitchess Motion, Plaintiff requests the production of Defendant Camachos personal cell phone, which was used on July 21, 2019 and August 25, 2019, as well as, all electronically stored information, photographs, and communications relating to any and all female members of the public, for which Defendant Camacho obtained or captured while he was on duty as a sworn police officer, and for his own personal use. Select the option or tab named Internet Options (Internet Explorer), Options (Firefox), Preferences (Safari) or Settings (Chrome). Keeping this cookie enabled helps us to improve our website. 1138.) (Coy v. Superior Court (1962) 58 Cal.2d 210, 220; see also San Diego Professional Ass'n v. Superior Court of San Diego County (1962) 58 Cal.2d 194, 204.) (Evid. Photo provided as is by the Irwindale Police Department. Springfield Township Police Subscribe to our newsletter for this giveaway and many more. Plaintiff alleges that Defendant City failed to adequately supervise, discipline, or train Defendant Camacho, after having knowledge that Defendant Camacho had sexually harassed a female co-worker prior to the events relevant to Plaintiffs Complaint. Additional Information. The child was found a short time later in a small area of standing water. Link: Police Department Page. Code, 1043, subd. Find out more or adjust your settings. Rules of Court, Rule 3.1345 requires that all motions or responses involving further discovery contain a separate statement with the text of each request, the response, and a statement of factual and legal reasons for compelling further responses. Subsequently, on March 21, 2022, Plaintiff filed and served the present Motion, moving for an Order compelling Defendant Camachos further responses to Request for Production of Documents, Set One, Nos. (Evid. Law enforcement officers from the Irwindale Police Department made an arrest in connection with a fatal hit-and-run traffic collision that occurred on the previous 1-4 and 8-11are sufficiently material to Plaintiffs Complaint. Based on the foregoing, Plaintiffs Pitchess Motion for Discovery of Police Records is GRANTED, with respect to categories of information sought from Defendant City with the exception of Category Nos. Following a review of the parties moving, opposing, and reply arguments, the Court finds Plaintiffs Motion is moot in light of Defendant Camachos service of a supplemental response on March 28, 2022, and a second supplemental response on April 8, 2022. Anyone with pertinent information relating to these incidents is urged to contact Irwindale PD Detective Diego Cornejo at (626) 430-2290 or by email at dcornejo@irwindaleca.gov. The Court will award reduced sanctions and award $1,025.00, for 5 hours of work for preparing the motion and the reply at the billing rate of $205.00 per hour. Gomez is being held on $1,000,000 bail. (a).) (a) Categories of Records Requested for Production. 1 and 2 fall outside of the scope of the present, Remaining Request for Records and Information from the City, upon a showing that the evidence sought is admissible or may lead to discovery of admissible evidence. (. (Mamikonyan Decl. You've been added to our list and will hear from us soon. UniCourt uses cookies to improve your online experience, for more information please see our Privacy Policy. 01 May 2023 14:15:01 Sandy resident builds wall to divert water away from property in anticipation of flooding, Man taking family camping near Utah Lake hit and killed; driver criminally charged, UPDATE: Two injured in shooting at SLC park, Search and rescue on scene following reports of person screaming in Weber River, Orem resident hospitalized after being knocked unconscious in snowmobile crash, Old Laptop Upgrades You Need to Try Before Throwing it Away. On July 20, 2021, Jane Doe C.M.A. Essential Cookies should be enabled at all times so that we can save your preferences for cookie settings. In a short time you can create new ones in seconds. Second, Defendant Camacho argues Plaintiff has failed to serve the government agency in possession of the subject records, here, the City of Irwindale, as required by Evidence Code section 1043, subdivision (a). First, the moving party must demonstrate that the information sought is material to the subject matter of the pending litigation. The ambulance crew informed arriving officers that the suspect fled the scene in a 2015 Peterbilt tractor-trailer. 10:7-18. Ex. 8, Ex. Provo police and fire medics responded to the Class Ropes Course area at 3606 W Center Street, CPR was administered. Accordingly, the information and objects sought by Plaintiffs Pitchess Motion with respect to Defendant Camacho only outside of the scope of the records which may be produced pursuant to a Pitchess Motion. Provo police said the incident did not occur in the Provo River, but at an inlet nearby. Plaintiff requests the production of the following categories of records from Defendant Camacho only: (1). 5, 6, and 7, Following a review of the relevant statutory scheme, as well as the parties moving, opposing, and reply arguments, the Court finds the categories of information sought from Defendant City, within Category Nos. (Evid. (CCP 2030.290(c), 2030.300(d), 2031.300(c), 2031.310(h).) On today's show, the overlooked force motivating police departments to reform bad behavior not protests and picket signs, but spreadsheets and actuaries. Your request has been confirmed! Code, 832.8, subd. Irwindale Police Department According to a statement from Irwindale Police Department, officers were dispatched to the 5000 block of Azusa Canyon Road after ), As to whether a declarant states a reasonable belief that the government agency has possession of the type of records being sought, it is enough that his or her belief be premised upon a rational inference from known or reasonably assumed facts. (Evid. (Ekimyan Decl., Ex. (Riske, supra, 6 Cal.App.5th at p. This may be called Tools or use an icon like the cog. (Compl., 2-3.) (1) PITCHESS MOTION FOR DISCOVERY OF POLICE OFFICER RECORDS IS GRANTED, IN PART; (2) MOTION TO COMPEL FURTHER RESPONSES TO REQUEST FOR PRODUCTION OF DOCUMENTS, SET ONE AGAINST DEFENDANT MARIO CAMACHO IS DENIED, AS MOOT. The suspect immediately got out of the semi-truck and began to flee on foot, ignoring the officers commands. Category Nos. 9:9-10:6. WebPhysical Address: 5050 N. Irwindale Avenue. Based on the foregoing, Plaintiffs Pitchess Motion for Discovery of Police Records is GRANTED, with respect to the following categories of information sought from Defendant CityCategory Nos. (Evid. However, the Court is unpersuaded as the statutory provision does not require the moving party to identify the particular records being sought; rather, it is enough that the moving party describes the records by type. Such information clearly may lead to discovery of admissible evidence which Plaintiff may employ in order to prove her causes of action against Defendant City and Defendant Camacho. RONALD AUSTIN VS IRWINDALE POLICE DEPARTMENT, JANE DOE CR VS IRWINDALE POLICE DEPARTMENT ET AL, JANE DOE CB VS IRWINDALE POLICE DEPARTMENT ET AL. Gomez is also suspected in a series of local freeway shootings, according to Irwindale PD. As noted previously, Plaintiffs present Motion moves to compel Defendant Camachos further responses based upon Defendants service of boilerplate objections in response to Request Nos. 7.) Specifically, once good cause is established, Evidence Code section 1045 provides that the Court must then examine the information in chambers in conformity with Evidence Code section 915 and shall exclude from disclosure information consisting of complaints concerning conduct occurring more than five years before the event or transaction that is the subject of the litigation. (b)(2).) Yolanda Orozco in Department 31 Stanley Mosk Courthouse, Case Number: *******6652 Hearing Date: July 29, 2022 Dept: 31. On 07/20/2021 JANE DOE C M A filed a Civil Right - Other Civil Right lawsuit against IRWINDALE POLICE DEPARTMENT,. Plaintiffs Motion to Compel Further Responses to Request for Production of Documents Set One from Defendant Camacho is DENIED as MOOT. Moreover, counsel for Defendant Camacho tried on several occasions to meet and confer with Plaintiffs counsel to no avail. 1-4 and 8-11. WebThe city of Irwindale and the Irwindale Police Department are pleased to welcome Chris Hofford, MPA, FBINA as our new Chief of Police effective Monday, March 23, 2023. Plaintiffs Complaint alleges the following causes of action: (1) Sexual Assault under Color of Authority; (2) Negligence; and (3) Bane Civil Rights Act. Second, Defendant Camacho argues Plaintiff has failed to serve the government agency in possession of the subject records, here, the City of Irwindale, as required by Evidence Code section 1043, subdivision (a). (Coy v. Superior Court (1962) 58 Cal.2d 210, 220; see, San Diego Professional Ass'n v. Superior Court of San Diego County, Sanctions are mandatory in connection with motions to compel responses to interrogatories and requests for production of documents against any party, person, or attorney who unsuccessfully makes or opposes a motion to compel. Type: Police Departments Population Served: 1200 (b)(2).) 5, 6, and 7, do not constitute records which are within the scope of the present, are statutorily inappropriate and outside the scope of the records which may be produced pursuant to a. Code, 1043, subd. 657.) Anyone with information is asked to call Irwindale Police at 626-430-2244 or report anonymously at LA Crime Stoppers, 1-800-222-TIPS (8477). Proc., 2031.310, subd. New training opportunities from an historic tragedy. Harrison Epstein, Daily Herald A-B.) Accordingly, the Court finds that the documents sought in Category Nos. (Evid. Hours: Monday through Sunday, 24 Nor does the statute require the declarants personal knowledge. The suspect, 37-year-old El Paso, Texas resident Johnathan Gomez, was arrested and booked into West Covina Jail after being medically cleared at a local hospital. They attempted a traffic stop, but the vehicle failed to yield and continued on, initiating a slow-speed pursuit that ultimately ended near Peck Road and Wyland Way in Monrovia. 8, 9, and 10, on February 4, 2022. (Id. We will get in touch with you shortly. Take this quiz before you apply to see if it will help you meet your goals. Accordingly, Plaintiffs present Motion is DENIED as moot. Choice of Consultant to Probe Feud Among Irwindale Police Adds to Unrest. The Court is aware that Defendant has refused to produce these documents in response to Plaintiffs Requests for Production of Documents, Set Two, where Plaintiff seeks the production of identical documents. WI - Apr 08, 2023. Ex. For interrogatories, each answer in the response must be as complete and straightforward as the information reasonably available to the responding party permits. Following Plaintiffs filing of the present Motion, and pursuant to the parties meet and confer efforts, Defendant served two sets of supplemental responses to Request Nos. Earlier this year, the Irwindale Police Department, which has about 30 sworn positions, was embroiled in a small-town scandal when residents complained that officers at p. The officers were forced to physically detain the suspect, during which an electro-muscular disruption technology (EMDT) device was successfully deployed. (b)(3); City of Santa Cruz v. Municipal Court (1989) 49 Cal.3d 74, 90, quoting Black's Law Dict. MARIELA ISABEL AVILA VS CITY OF IRWINDALE, A CALIFORNIA MUNICIPALITY, ET AL. Code, 832.8, subd. . On February 24, 2022, Defendant Camacho filed this Motion to Compel Further Responses to Form Interrogatories-General, Set One along with a Separate Statement. Have YOU OR ANYONE ACTING ON YOUR BEHALF interviewed any individual concerning the INCIDENT? The moving party will have sufficiently made a showing of good cause when two elements are satisfied. Try these old laptop upgrades before throwing it out to keep it running fast and efficient. (See Proof of Service, filed April 1, 2022.). (b). Times Staff Writer. As stated, a party will be entitled to discovery of a police officers personnel records pursuant to a Pitchess Motion upon the moving partys showing [of] good cause for the discovery or disclosure sought. (Evid. (a). Accordingly, the arguments advanced in Plaintiffs Motion and Separate Statement are superseded and would not operate to compel a further response from Defendant Camacho. (Cal. No one was injured in the above-mentioned freeway shootings. ), Plaintiff requests the production of the following categories of records from Defendant Camacho only: (1) All personal cell phone(s) that Camacho used on July 21, 2019; (2) All personal cell phone(s) that Camacho used on August 25, 2019; (3) All electronically stored information relating to any and all female members of the public that you obtained while on duty as a sworn police officer and retained for your personal use; (4) All photographs, electronic or otherwise, relating to any and all female members of the public that you obtained while on duty as a sworn police officer and retained for your personal use while off duty; and (5) All communication that you have had with any and all female members of the public whom you came to know while on duty as a sworn police officer and then, proceeded to personally communicate with while off duty. (b)(3).). 8, 9, and 10, on March 28, 2022 and April 8, 2022, respectively. The department provides law enforcement and substance abuse services for the city of Irwindale. When they arrived, they found a large crowd leaving the area 04/22/22.) Chief Hofford states is excited to join the Irwindale Police Department and looks forward to serving the members of the police department and the Irwindale Community . This field is for validation purposes and should be left unchanged. In conjunction with the Courts finding above, the Court makes the following observation. 90. (Id. Following a review of the definition of records, as codified within Penal Code section 832.8, the litigation documents which have been compiled for the purposes of the Chavez action would clearly not be considered records which would be maintained in Defendant Camachos personnel file by Defendant City. (a). 1-4 and 8-11. A structured cabling system benefits businesses by giving you faster processing speeds and making your network more efficient and reliable. and manufacturers. 2015-04-10, Los Angeles County Superior Courts | Labor | Defendant Citys position appears to be that Plaintiff may not obtain these documents at all which would be contrary to case law that allows for the discovery of all relevant information, or information which may lead to the discovery of admissible evidence. All rights reserved. at p. (Evid. (Cal. Lexipol. (City of Santa Cruz, supra, 49 Cal.3d at pp. Yolanda Orozco in Department 31 Stanley Mosk Courthouse, Notice of the motions must be given within 45 days of service of the verified response, otherwise, the propounding party waives any right to compel a further response. He faces charges of attempted murder, assault with attempted murder, assault with a deadly weapon, false imprisonment, resisting arrest, evading arrest, driving under the influence of drugs and various weapons violations. Country: United States Address 1: 5050 N Irwindale Ave City: Irwindale State: California Zip Code: 91706-2193 County: Los Angeles County Phone #: 626-962-3601 Fax #: 626-856-0471. by inspecting, copying, testing, or sampling documents, tangible things, land or other property, and electronically stored information in the possession, custody, or control of any other party to the action. (Code Civ. 19-20. 18-19.) This first element is satisfied upon a showing that the evidence sought is admissible or may lead to discovery of admissible evidence. (Riske, supra, 6 Cal.App.5th at p. A Provo police officer watches as participants of the Cougar Pride Center march along Center Street in Provo on Saturday, April 29, 2023. However, sanctions are not mandatory if the court finds that the one subject to the sanction acted with substantial justification or that other circumstances make the imposition of the sanction unjust. (, Mamikonyan Decl. (Mamikonyan Decl. Therefore, the motion is Moot as to interrogatories 6.2 and 6.3. (Evid. Plaintiff alleges that on said date, Defendant Camacho laid in wait once again in front of Plaintiffs workplace and proceeded to pull Plaintiff over while she was driving home. Cancellation and Refund Policy, Privacy Policy, and Suspicious. The child was transported to the hospital where he died when he was taken off life support the following day. (Id. According to a statement from Irwindale Police Department, officers were dispatched to the 5000 block of Azusa Canyon Road after learning that a body had been discovered in the area. (a) [Pitchess motion must be served upon the governmental agency that has custody and control of the records].) Following these events, Plaintiff reported such conduct to Defendant City. According to Provo Police Department, a family was . 6.) After sweeping the area, officers found the suspect vehicle near the intersection of Longden Avenue and Myrtle Avenue in Irwindale. Anyone with information about the case 86. (Id. Further, the objects and categories of information sought by Plaintiff are not maintained by a state or local agency, here, Defendant City, but are alleged to be in the possession of Defendant Camacho only. Nothing may be incorporated by reference. If you do not agree with these terms, then do not use our website and/or services. Since there was no opposition, defense counsel only spent 13.8 on the motion amounting to a total of $2,829.00. Public Records Policy. 5, 6, and 7 are statutorily inappropriate and outside the scope of the records which may be produced pursuant to a Pitchess Motion. Code, 1043, subd. by inspecting, copying, testing, or sampling documents, tangible things, land or other property, and electronically stored information in the possession, custody, or control of any other party to the action., The party to whom a demand for inspection, copying, testing, or sampling has been directed shall respond separately to each item or category of item by any of the following: (1) A statement that the party will comply with the particular demand for inspection, copying, testing, or sampling by the date set for the inspection, copying, testing, or sampling pursuant to paragraph (2) of subdivision (c) of Section 2031.030 and any related activities[;] (2) A representation that the party lacks the ability to comply with the demand for inspection, copying, testing, or sampling of a particular item or category of item[; or] (3) An objection to the particular demand for inspection, copying, testing, or sampling., On receipt of a response to a demand for inspection, copying, testing, or sampling, the demanding party may move for an order compelling further response to the demand if the demanding party deems that any of the following apply: (1) A statement of compliance with the demand is incomplete[;] (2) A representation of inability to comply is inadequate, incomplete, or evasive[; or] (3) An objection in the response is without merit or too general., A demanding partys motion for an order compelling a further response must set forth the facts showing good cause justifying the discovery sought by the demand.. Plaintiff opposes the interrogatory on the grounds that it seeks attorney work-product, seeks information subject to sexual assault counselor privilege, and psychotherapist privilege. The Court has made the above finding pursuant to Defendant Citys persuasive argument concerning the fact that the external litigation documents sought by Plaintiff in Category Nos. 3 at pp. We are honored to have Chief Hofford join our ranks! WebCity Of Irwindale Police Department. ), On receipt of a response to a demand for inspection, copying, testing, or sampling, the demanding party may move for an order compelling further response to the demand if the demanding party deems that any of the following apply: (1) A statement of compliance with the demand is incomplete[;] (2) A representation of inability to comply is inadequate, incomplete, or evasive[; or] (3) An objection in the response is without merit or too general. (Code Civ. #Irwindale #IrwindalePD #IrwindalePolice . Plaintiff additionally alleges Defendant City ratified Defendant Camachos conduct by failing to adequately investigate, discharge, or discipline Defendant Camacho, after knowing Defendant Camacho had previously sexually harassed a female co-worker prior to the events relevant to Plaintiffs Complaint. (CCP. (b)(3). Request for Dismissal - REQUEST FOR DISMISSAL - NOT ENTERED 10/07/2022, Motion for Discovery of Peace Officer Personnel Records (Pitchess Motion), Declaration - DECLARATION OF ANTHONY M. DEMARCO IN SUPPORT OF PLAINTIFF JANE DOE CMA'S PITCHESS MOTION FOR DISCOVERY OF POLICE OFFICER RECORDS, Opposition - OPPOSITION TO PLAINTIFFS MOTION AND PITCHESS MOTION FOR DISCOVERY OF POLICE OFFICER RECORDS; MEMORANDUM OF POINTS AND AUTHORITIES, Opposition - OPPOSITION TO PLAINTIFFS MOTION TO COMPEL FURTHER RESPONSES TO REQUEST FOR PRODUCTION OF DOCUMENTS, SET ONE, Declaration - DECLARATION OF JOHN EKIMYAN, Opposition - OPPOSITION TO PLAINTIFFS NOTICE OF MOTION AND PITCHESS MOTION FOR DISCOVERY OF POLICE OFFICER RECORDS, Reply - REPLY IN SUPPORT OF PLAINTIFF'S PITCHESS MOTION FOR DISCOVERY OF POLICE OFFICER RECORDS, Declaration - DECLARATION OF ANTHONY M. DEMARCO IN SUPPORT OF PLAINTIFF'S REPLY OF PITCHESS MOTION FOR DISCOVERY OF POLICE OFFICER RECORDS, Reply - REPLY PLAINTIFF JANE DOE C.M.A.
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