Proc., 2031.210, subd. May 18, 1986 12 AM PT. Code, 1043, subd. 658.) When they arrived, they found a large crowd leaving the area Anyone with information about the case 7.) On July 20, 2021, Jane Doe C.M.A. 13.8 hours were spent preparing this motion and anticipates spending an additional 1.0 hour reviewing the opposition and 6.0 hours preparing a reply. Plaintiff opposes the interrogatory on the grounds that it seeks attorney work-product, seeks information subject to sexual assault counselor privilege, and psychotherapist privilege. Read about the history of Lighting Design, a family-owned and operated business that paved the way for the lighting industry in Utah. Link: Police Department Page. (Evid. However, Defendant City does not contend it did not receive notice of Plaintiffs Motion and, indeed, has filed an opposition to the same. Ex. The driver of a pickup truck who police say hit and killed a man while on a dirt road in Utah County on Friday night is now facing criminal charges. (CRC, rule 3.1345(a)(3), (c).). All social distancing protocols will be observed at the Courthouse and in the courtrooms. The extended incident began Wednesday at 6:37 a.m., when law enforcement received a report of a suspect holding two ambulance members at gunpoint on the 600 block of Live Oak Avenue in Irwindale, according to Irwindale PD. Such information would undoubtedly be included within the personnel records of Defendant Camacho, or in other official records of the Defendant City. CITY OF IRWINDALE, a municipal corporation; and MARIO CAMACHO, individually and as Lieutenant for the Irwindale Police Department, MEMORANDUM* Defendants - Appellees. Lafourche Parish Sheriff's Office. (DeMarco Decl., Ex. 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. If so, for each individual state: a) The name, ADDRESS, and telephone number of the individual interviewed; c) The name, ADDRESS, and telephone number of the PERSON who conducted the interview.. (DeMarco Decl., 5.) According to Provo Police Department, a family was (a).). Learn how you can create strong passwords that are actually easy to remember! California 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. (Id. 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. 7.) 2023-03-08, Los Angeles County Superior Courts | Personal Injury | Accordingly, the arguments advanced in Plaintiffs Motion and Separate Statement are superseded and would not operate to compel a further response from Defendant Camacho. 1-4 and 8-11. It's the most comprehensive and trusted online destination for law enforcement agencies and police departments worldwide. A motion to compel further responses must be accompanied by a separate statement listing each discovery request to which a further response is requested, the responses given, and the factual and legal reasons for compelling it. Specifically, pursuant to Category Nos. Plaintiff moves for an Order requiring Defendant City of Irwindales (Defendant City) and Defendant Mario Camachos (Defendant Camacho) production of documents for an in-camera review by this Court, pursuant to the procedures set forth within Evidence Code 1043 and 1045. (a)(3).) WebCity Of Irwindale Police Department. MARIELA ISABEL AVILA VS CITY OF IRWINDALE, A CALIFORNIA MUNICIPALITY, ET AL. (Id. Preliminary, the Court notes that Plaintiff does not solely request the production of records from Defendant City, but requests documents and physical objects within Defendant Camachos possession. (Mot., at pp. Since Plaintiff failed to do so, the response is insufficient. 10/7/2022: Request for Dismissal - REQUEST FOR DISMISSAL - NOT ENTERED 10/07/2022, 3/30/2022: Motion for Discovery of Peace Officer Personnel Records (Pitchess Motion), 3/30/2022: Declaration - DECLARATION OF ANTHONY M. DEMARCO IN SUPPORT OF PLAINTIFF JANE DOE CMA'S PITCHESS MOTION FOR DISCOVERY OF POLICE OFFICER RECORDS, 4/11/2022: Opposition - OPPOSITION TO PLAINTIFFS MOTION AND PITCHESS MOTION FOR DISCOVERY OF POLICE OFFICER RECORDS; MEMORANDUM OF POINTS AND AUTHORITIES, 4/11/2022: Opposition - OPPOSITION TO PLAINTIFFS MOTION TO COMPEL FURTHER RESPONSES TO REQUEST FOR PRODUCTION OF DOCUMENTS, SET ONE, 4/11/2022: Declaration - DECLARATION OF JOHN EKIMYAN, 4/11/2022: Opposition - OPPOSITION TO PLAINTIFFS NOTICE OF MOTION AND PITCHESS MOTION FOR DISCOVERY OF POLICE OFFICER RECORDS, 4/15/2022: Reply - REPLY IN SUPPORT OF PLAINTIFF'S PITCHESS MOTION FOR DISCOVERY OF POLICE OFFICER RECORDS, 4/15/2022: Declaration - DECLARATION OF ANTHONY M. DEMARCO IN SUPPORT OF PLAINTIFF'S REPLY OF PITCHESS MOTION FOR DISCOVERY OF POLICE OFFICER RECORDS, 4/15/2022: Reply - REPLY PLAINTIFF JANE DOE C.M.A. Following a review of the applicable statutory scheme, as articulated in Evidence Code sections 1043 and 1045, the Court finds the categories of documents sought exclusively from Defendant Camacho do not constitute records which may be disclosed pursuant to a, Requests for Records and Information, Category Nos. (Plaintiff) filed a Complaint against City of Irwindale (erroneously sued additionally as Irwindale Police Department), Mario Camacho, and Does 1 through 100 (collectively, Defendants). Your subscription has been confirmed. Phone: 626-430-2244. 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. (a). spokesman for the Irwindale Police Department. (Id. The moving party will have sufficiently made a showing of good cause when two elements are satisfied. (c).) Irwindale, CA 91706. The parties are strongly encouraged to use LACourtConnect for all their matters. Categories of Records Requested for Production, Requests for Records and Information from Defendant City and Defendant Camacho. Two people were injured Monday night following a shooting at 17th South River Park in Salt Lake City. He was set to appear in Citrus Municipal Court at 8:30 a.m. Friday. South end of Great Salt Lake up nearly 4 feet since berm raised in February, Channel opened on Weber River as flood watch begins, Spanish Fork girl killed after being run over by landscaping equipment, Gwyneth Paltrow denied attorneys' fees in ski crash lawsuit, Garden City officials declare state of emergency due to flooding, Flood watches and advisories in effect across Utah; US 89 closed at US 6/Thistle Junction. (Min. '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. (Ekimyan Decl., Ex. On July 20, 2021, Jane Doe C.M.A. WebChetek Police Department. Estimated read time: 1-2 minutes. Plaintiffs Complaint arises from the alleged sexual harassment and assault endured by Plaintiff at the hands of Defendant Camacho, while Defendant was a sworn police officer for Defendant City. Police1 is revolutionizing the way the law enforcement community 4-6.) (CCP 2030.300(c).) Ex. (b)(3).) Plaintiffs Complaint alleges the following causes of action: (1) Sexual Assault under Color of Authority; (2) Negligence; and (3) Bane Civil Rights Act. (e) [The court shall, in any case or proceeding permitting the disclosure or discovery of any peace or custodial officer records requested pursuant to Section 1043 , order that the records disclosed or discovered may not be used for any purpose other than a court proceeding pursuant to applicable law.].). What are the rules & your rights when No Soliciting signs dont keep salespeople at bay? All rights reserved. 2015-04-10, Los Angeles County Superior Courts | Labor | . Win a $50 gift card to Twohey's Restaurant! 6.) (Evid. How to Choose What MBA Program is Right for You: Take this Quiz Before You Apply! 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. A motion to compel further responses to form or specially prepared interrogatories may be brought if the responses contain: (1) answers that are evasive or incomplete; (2) an unwarranted or insufficiently specific exercise of an option to produce documents in lieu of a substantive response; or (3) unmerited or overly generalized objections. 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. The Court finds the description of the records requested is sufficient. Defendant asserts that if there are no interviews other than privileged interviews, then the plaintiff is required to answer None after asserting her objections. 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 . Plaintiff alleges that during this traffic stop, Defendant Camacho ordered Plaintiff to give him her phone, and proceeded to view sexually explicit photographs and videos Plaintiff had taken of herself. Code, 832.8, subd. . (See Proof of Service, filed April 1, 2022.). 1-4 and 8-11 each request information relating to the specific acts of Defendant Camacho during his work shift on the dates of the subject incidents, and, further, requests information about Defendant Camachos sexual harassment and/or assault against members of the public, as well as Defendant Citys knowledge of such harassment and/or assault. # # # # Media Contact Sergeant Diego Cornejo , Public Information Officer Phone ( 626 ) 430 - 2244 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. (Cal. The suspect immediately got out of the semi-truck and began to flee on foot, ignoring the officers commands. 'S REPLY IN SUPPORT OF MOTION TO COMPEL FURTHER RESPONSES TO REQUEST FOR PRODUCTION SET ONE FROM DEFENDANT MARIO CAMACHO, 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, Minute Order - MINUTE ORDER (HEARING ON MOTION TO COMPEL FURTHER DISCOVERY RESPONSES TO RE), Brief - BRIEF PLAINTIFF JANE DOE C.M.A'S SUPPLEMENTAL BRIEF FOR IN CAMERA REVIEW OF PITCHESS MATERIALS, Notice of Lodging - NOTICE OF LODGING OF (PROPOSED) PROTECTIVE ORDER REGARDING DEFENDANT CITY OF IRWINDALE DOCUMENTS AND PERSONNEL FILES INFORMATION, Cases involving other civil rights and constitutional questions not classified elsewhere, 440, 444, 1440, 1444, 2440, 2444, 3440, 3444, 4440, 4444, 5950. (Id. While it appears that Plaintiff served an Opposition to this Motion, Plaintiff did not filed any Opposition with the Court. (b)(2).) ), 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. 84. Effective July 20, 2020, all matters will be scheduled virtually and/or with audio through the Courts LACourtConnect technology. Times Staff Writer. C, D, E, F, H, and J.). According to Provo Police Department, a family was in the area of the ropes course Saturday when their toddler wandered away from the group. (a). 8, 9, and 10, Defendant Camacho merely provided boilerplate objections, and failed to provide a substantive responses. The statutory good faith requirement is thus a two-pronged inquiry: (1) is the information being sought material to the proceeding; and (2) does the declarant state his reasonable belief that the agency has the type of information being sought. JANE DOE C.M.A VS IRWINDALE POLICE DEPARTMENT, ET AL. Presently, Plaintiffs Separate Statement only recites the text of Defendants original response, served on February 4, 2022, and fails to include the text of Defendants further responses, served on March 28, 2022 and April 8, 2022, respectively. Code, 1043, subd. Pursuant to Category Nos. Plaintiffs Motion is based upon the ground that, in response to Request Nos. Spring run-off/swift-water was not a factor.. 658.). C, D, E, F, H and J.) . 12.2 is GRANTED. ), Upon the courts determination that a movant has presented good cause for his Pitchess motion, the Court shall conduct an in-camera review of the evidence pursued by said motion, accompanied only by the person authorized to claim privilege on behalf of the government. Emergency Phone: 911. 90-91.) 8, 9, and 10. (Source: Irwindale Police Department @IrwindalePolice/Twitter) Plaintiffs Pitchess Motion for Discovery of Police Officer Records was granted on April 22, 2022. (a).) Plaintiffs Motion is based upon the ground that, in response to Request Nos. 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. Find out more or adjust your settings. (b)(2) [The motion shall include all of the following: (2) A description of the type of records or information sought.].) (Evid. Your request has been confirmed! 01 May 2023 14:15:01 Code, 1043, subd. In conjunction with the Courts finding above, the Court makes the following observation. He was then arrested without further incident, read the Irwindale PD release on the incident. 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. Moreover, counsel for Defendant Camacho tried on several occasions to meet and confer with Plaintiffs counsel to no avail. 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. #SoCalTelevision #Alert >> Authorities with the Irwindale Police Department are seeking the publics help after a man and woman were found dead in a (b)(3); City of Santa Cruz v. Municipal Court (1989) 49 Cal.3d 74, 90, quoting Black's Law Dict. This may be called Tools or use an icon like the cog. 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. 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. Nothing may be incorporated by reference. ), The Court ORDERS that any and all discoverable information eventually produced as a result of Plaintiffs Pitchess motion shall be subject to a protective order. 4-5.) Do Not Sell My Personal Information, If you need further help setting your homepage, check your browsers Help menu, Open the tools menu in your browser. Please enable Essential Cookies first so that we can save your preferences! Code 1045, subd. Code, 1043, subd. 9:9-10:6. The objects and categories of information sought by Plaintiff do not constitute records, as defined within Penal Code section 832.8. Following a review of the parties moving, opposing, and reply arguments, as well as the relevant requirements codified within governing statutory scheme, the Court finds Plaintiff has established good cause to warrant the production of the remaining categories of documents from Defendant City for an in-camera review by this Court. Finally, one place to get all the court documents we need. 8, 9, and 10, on March 28, 2022 and April 8, 2022, respectively. Once documents are produced in chambers, the Court will exclude information consisting of complaints concerning conduct occurring more than five years before the event or transaction that is the subject of the litigation, pursuant to Evidence Code section 1045, subdivision (b)(1). 8, 9, and 10. WebEmergency: Call 911 Non-Emergency Dispatch Center - (801) 852-6210 Provo City Hall - 445 W. Center St. Suite 130, Provo, Utah 84601. ), 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. Second, the Court finds that Plaintiff has sufficiently declared that the categories of information requested are within Defendant Citys possession. As to civil proceedings, this procedure has been codified in Evidence Code sections 1043 and 1046. The ambulance crew informed arriving officers that the suspect fled the scene in a 2015 Peterbilt tractor-trailer. 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. (b)(3). (5th ed. Also, stay in the loop for SoCal news and updates. 12.) Further, Plaintiffs Proof of Service demonstrates Defendant City has been properly served. Why is this public record being published online? 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. (DeMarco Decl., Ex. at 1043, subd. The Court ORDERS that any and all discoverable information eventually produced as a result of Plaintiffs. (c). Plaintiffs Pitchess Motion for Discovery of Police Records is DENIED, with respect to the five categories of information and objects sought from Defendant Camacho only. ), First, Plaintiff has demonstrated that the information sought pursuant to Category Nos. Code, 1045.) Defendant Camachos Motion to Compel further responses to interrogatory 12.2 is GRANTED. A Baldwin Park man was arrested after he was involved in a fatal hit-and-run traffic collision on Saturday. (Mamikonyan Decl. "We feel so blessed that It is enough that the moving partys belief be premised upon a rational inference from known or reasonably assumed facts. (Evid. Copyright 2023 Try these old laptop upgrades before throwing it out to keep it running fast and efficient. Specifically, Plaintiff has identified the following categories of records for which production is sought, by virtue of an in-camera inspection and review, with respect to Defendant City and Defendant Camacho. The officers were forced to physically detain the suspect, during which an electro-muscular disruption technology (EMDT) device was successfully deployed. On July 7, 2022, Plaintiff served Further Responses to Form Interrogatories-General, Set One as to interrogatories 6.2 and 6.3. 18-19.) 1-4 and 8-11, Plaintiff moves to compel Defendants production of Defendant Camachos personnel records which would reveal the following information: (1) the identity of witnesses holding personal knowledge of the two occasions of sexual harassment alleged in Plaintiffs Complaint, (2) documents relating to Defendant Camachos work shift on the two days Plaintiff alleges she was sexually harassed and assaulted, (3) records pertaining to the prior incident of sexual assault involving Defendant Camacho and a co-worker, (4) former complaints of sexual harassment or assault made against Defendant Camacho, and (5) documents revealing Defendant Camachos current employment status with Defendant City. 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). (Id. Rules of Court, rule 3.1345, subd. A few minutes later, Defendant Camacho allowed Plaintiff to drive away. WebIrwindale Police Department - Irwindale, California. Boyle Heights Apr 18, 2022 Here, Plaintiff has failed to oppose Defendants motion or outline why the information Defendant Camacho seeks is privileged. ), Except as provided in subdivision (j), the court shall impose a monetary sanction under Chapter 7 (commencing with Section 2023.010) against any party, person, or attorney who unsuccessfully makes or opposes a motion to compel further response to a demand, unless it finds that the one subject to the sanction acted with substantial justification or that other circumstances make the imposition of the sanction unjust. (Code Civ. (Evid. A loaded handgun was allegedly found in Gomezs possession at the time of his arrest. Code, 1043, subd. 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 Plaintiffs Pitchess Motion for Discovery of Police Records is DENIED, with respect to the following categories of information sought from Defendant CityCategory Nos. 5, 6, and 7. Code, 1043, subd. PROVO, Utah A 20-month-old Members of the Provo City School District, Provo Police Department and the city as a whole were sent into a brief panic March 29 when a call was made to the police (Evid. 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. A Provo police officer watches as participants of the Cougar Pride Center march along Center Street in Provo on Saturday, April 29, 2023. Plaintiffs Complaint alleges that, on July 21, 2019, Defendant Camacho laid in wait in front of Plaintiffs workplace, an adult entertainment club, pulling Plaintiff over when she was driving home at approximately 2:30 a.m. Further, a demanding partys motion for an order compelling a further response must be accompanied by a meet and confer declaration under Section 2016.040. (Id., 2031.310, subd. After sweeping the area, officers found the suspect vehicle near the intersection of Longden Avenue and Myrtle Avenue in Irwindale. 1-4 and 8-11 are material to the subject matter of the present litigation. 19-20. WI - Apr 08, 2023. A man and a woman were found dead inside of a van that had been impounded in Irwindale on Wednesday, April 26, and their cause of death was under investigation. Any party may obtain discovery . (Ekimyan Decl., 4-5, Exs. 14.) May 1, 2023, 3:07 PM | Updated: 6:26 pm. First, Defendant Camacho argues that Plaintiffs Pitchess Motion must be denied because the Motion requests the production of documents and information consisting of complaints concerning conduct occurring more than five years before the event or transaction that is the subject of the litigation. This requirement is not disputed between the parties, and Defendant City has not represented it is not in possession of such records or information. (City of Santa Cruz, supra, 49 Cal.3d at pp. Code, 832.8, subd. 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 also San Diego Professional Ass'n v. Superior Court of San Diego County (1962) 58 Cal.2d 194, 204.) Or. (CCP 2030.300(a).). All rights reserved. Accordingly, the arguments advanced in Plaintiffs Motion and Separate Statement are superseded and would not operate to compel a further response from Defendant Camacho. The Court considers Plaintiffs Motions, in turn. Irwindale police got a call around 6:30 a.m. about an armed man holding ambulance crew members at gunpoint in the 600 block of Live Oak Avenue. (i) Requests for Records and Information, Category Nos. If you do not agree with these terms, then do not use our website and/or services. (i) Requests for Records and Information from Defendant City and Defendant Camacho, Plaintiff requests the production of the following categories of records from Defendant City as well as from Defendant Camacho: (1) Identify all person known by Defendant(s) to have personal knowledge of the facts relating to incident number 1 alleged in the Complaint in this action at page 2 line 14 to Page 4 line 3; (2) Identify all person known by Defendant(s) to have personal knowledge of the facts relating to incident number 2 alleged in the Complaint in this action at page 4 line 4 to Page 7 line 2; (3) All documents relating to Mario Camachos work shift on August 25, 2019; (4) All documents relating to Mario Camachos work shift on July 21, 2019; (5) All documents served on Defendant(s) as part of Los Angeles Superior Court case number KC065226; (6) All documents served by Defendant(s) in Los Angeles Superior Court case number KC065226; (7) All deposition transcripts taken as part of Los Angeles Superior Court case number KC065226; (8) All records pertaining to any complaints, reports or claims by Alma Chavez, the Plaintiff in Los Angeles Superior Court case number KC065226, any investigation conducted by the City of Irwindale regarding that complaint, and records of all employment actions taken by the City of Irwindale in response including but not limited to demotions, reprimands, changes of duties, increased supervision, additional training of Camacho; (9) All complaints of sexual harassment committed by Defendant Mario Camacho; (10) All complaints of sexual assault committed by Defendant Mario Camacho; and (11) All documents reflecting Mario Camachos current employment status with the City of Irwindale, including the dates when that status began.
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