Counsel for Defendant stated that his hourly rate for this case is $205. at p. 18-19.) All rights reserved. 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. Code, 1043, subd. (Evid. In chambers examination of the documents requested is continued to August 8, 2022. Further, Plaintiffs Proof of Service demonstrates Defendant City has been properly served. Code 1045, subd. UniCourt uses cookies to improve your online experience, for more information please see our Privacy Policy. Code, 1043, subd. (a).). (See Mot., at p. Official police records are subject to a privilege against disclosure that is held by both the officer and the department. # # # # Media Contact Sergeant Diego Cornejo , Public Information Officer Phone ( 626 ) 430 - 2244 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. Code, 832.8, subd. It should not take 13.8 hours to prepare a straightforward motion relating to one interrogatory. (b)(3); City of Santa Cruz, supra, 49 Cal.3d at p. (Evid. Officers were dispatched to Wymount Terrace, on a suspicious rattle at the door. (b)(3); City of Santa Cruz v. Municipal Court (1989) 49 Cal.3d 74, 90, quoting Black's Law Dict. 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. 8, 9, and 10, Defendant Camacho merely provided boilerplate objections, and failed to provide a substantive responses. 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. ), 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. (Id., rule 3.1345, subd. A Provo police officer watches as participants of the Cougar Pride Center march along Center Street in Provo on Saturday, April 29, 2023. 2023-01-03, Los Angeles County Superior Courts | Personal Injury | Code, 1043, subd. Personnel records as defined by Penal Code section 832.8 include, the following: (1) personal data, including marital status, family members, educational and employment history, home addresses, or similar information,; (2) Medical history, (3) Election of employee benefits, (4) Employee advancement, appraisal, or discipline, (5) Complaints, or investigations of complaints, concerning an event or transaction in which he or she participated, or which he or she perceived, and pertaining to the manner in which he or she performed his or her duties, and (5) Any other information the disclosure of which would constitute an unwarranted invasion of personal privacy. (Pen. 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. 8, 9, and 10, on February 4, 2022. Proc., 2031.010, subd. (Opp., at p. 1:27-2:17 [representing to this Court that Plaintiff requests the Court order the City to provide specific information not maintained in Office Camachos personnel file, including the external litigation documents arising from the Chavez action].) 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. (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. Finally, one place to get all the court documents we need. (b)(2).) 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. 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. BYU MBA at the Marriott School of Business. By MARK ARAX. Plaintiffs Motion is based upon the ground that, in response to Request Nos. 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. The objects and categories of information sought by Plaintiff do not constitute records, as defined within Penal Code section 832.8. (a) Categories of Records Requested for Production. (Plaintiff) initiated the present action by filing a Complaint against City of Irwindale (erroneously sued additionally as Irwindale Police Department), Mario Camacho, and Does 1 through 100 (collectively, Defendants). finds relevant news, identifies important training information, 1 and 2, Plaintiff moves for the production of documents which identify all persons who have personal knowledge of the two incidents of sexual harassment and assault which are the subject of the Plaintiffs Complaint and involve Plaintiff and Defendant Camacho. A rescue effort at Weber River has now turned to a recovery effort following reports of someone screaming in the water and a woman in her 20's missing in the area. 1 and 2 fall outside of the scope of the present Pitchess Motion. 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. All social distancing protocols will be observed at the Courthouse and in the courtrooms. Moreover, counsel for Defendant Camacho tried on several occasions to meet and confer with Plaintiffs counsel to no avail. Provo police and fire medics responded to the Class Ropes Course area at 3606 W Center Street, CPR was administered. (i) Requests for Records and Information, Category Nos. He decided to Get Gephardt, who explores what those signs really mean. Win a $50 gift card to Twohey's Restaurant! 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. 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 . The motion must describe the type of records or information sought. 9:9-10:6. WebEmergency: Call 911 Non-Emergency Dispatch Center - (801) 852-6210 Provo City Hall - 445 W. Center St. Suite 130, Provo, Utah 84601. Specifically, Plaintiff seeks to hold Defendant City liable for the acts of Defendant Camacho pursuant to a theory of vicarious liability. Defendant Camachos request for sanctions is GRANTED in the reduced amount of $1,025.00, for 5 hours. 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. 3 at p. 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. USC, Childrens Hospital will use gift to expand research projects, UCLA gifted $20M to establish center for study of microbial organisms, City of Hope awarded $8M for prostate cancer research, SpaceX, NASA launch astronauts to International Space Station, Hundreds Walk to End Genocide in Fairfax area awareness event, May Day rallies planned for DTLA, Little Tokyo, Boyle Heights, Hundreds gather for rallies commemorating Armenian Genocide, Panels of AIDS Quilt on display Saturday and Sunday in Hollywood, LA County implements food ware law aimed to reduce fossil fuels, Rethinking urban plantings to survive climate change, LA area to celebrate Earth Day with cleanups, educational events, LA, OC transit agencies offer free rides on Saturday for Earth Day, Desert X hosts artist-led weekend As exhibition closes, Fun things to do in SoCal this week: April 28 May 4, Fun things to do in SoCal this week: April 21-27, LACMA, Pomona, Harvey Mudd colleges awarded humanities grants, Fun things to do in SoCal this week: April 14-20, Highest-rated Chinese restaurants in Los Angeles, according to Tripadvisor, Gay Disney executive drops disparate treatment suit, On This Side of the World musical tells Filipino immigrant stories, Knotts Berry Farm to reinstate chaperone policy, Fun things to do in SoCal this week: March 17-23, Fun things to do in SoCal this week: March 10-16, K-pop star, Arcadia High alumnus Mark Tuan gives back to alma mater, From design to landfill: Lifecycle of your $3 Shein shirt, Fun things to do in SoCal this week: April 7-13, Palm Springs Chamber tribute concert series wraps up Wednesday, Kane Brown to headline 2nd night of Stagecoach festival, Luke Bryan to headline 1st night of Stagecoach country music fest, A Noise Within stages Metamorphoses to end its 30th anniversary season, Return from the Wings: The Robey Theatre Company, Return from the Wings San Gabriel Valley Sierra Madre Playhouse, L.A. 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Movie still bests box office with $58M weekend, Metro approves $20M to extend its GoPass program, LA Metro seeks court order directing return of rail cars from repairer, SoCal transportation projects receive millions in state grants, Irwindale PD: Texas man shot at cars on freeway, held paramedics hostage. Brian Huston, CE and Anthony Perkins, BICSI. Anyone with information about the case Cameron Police Department. 5, 6, and 7, Plaintiff requests Defendant Citys production of all documents served on Defendant in the Chavez action, all documents served by Defendant in the Chavez action, and all deposition transcripts taken as part of the Chavez action. Read about the history of Lighting Design, a family-owned and operated business that paved the way for the lighting industry in Utah. 7.) Police are searching for an SUV driver who struck and killed a man in Irwindale on Saturday afternoon, April 29, 2023. 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. According to Provo Police Department, a family was Why is this public record being published online? at 1043, subd. In a short time you can create new ones in seconds. The department provides law enforcement and substance abuse services for the city of Irwindale. Plaintiff requests the production of the following categories of records from Defendant Camacho only: (1). Proc., 2031.310, subd. WebThe Irwindale Police Department believes strongly in our mission to provide excellent service in policing by partnering with the community to enhance the quality of life. 4.-6.) (Id. 5, 6, and 7 are statutorily inappropriate and outside the scope of the records which may be produced pursuant to a Pitchess Motion. He has spent the past seven years as the 657.) On today's show, the overlooked force motivating police departments to reform bad behavior not protests and picket signs, but spreadsheets and actuaries. In contrast, Defendant Camachos supplemental responses do not merely assert objections, but provide averments that the relevant documents are no longer in the possession of Defendant. (Plaintiff) filed a Complaint against City of Irwindale (erroneously sued additionally as Irwindale Police Department), Mario Camacho, and Does 1 through 100 (collectively, Defendants). (, Before the Court, are two motions filed by Plaintiff: (A) Plaintiffs, Pitchess Motion For Discovery of Police Officer Records. Salt Lake City police officers responded to a call at 2:41 a.m. about a stabbing at 32 E. Exchange Place. 657. ), 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. A.) Defendant Camacho, then, followed Plaintiff home and prompted her to send him sexually explicit photographs. 2:22-23, 8:19-9:2.) Have YOU OR ANYONE ACTING ON YOUR BEHALF interviewed any individual concerning the INCIDENT? 2015-04-10, Los Angeles County Superior Courts | Labor | (Id. 7.) Editors note: This article has been edited following a correction from the Provo Police Department about the childs age. The child was found a short time later in a small area of standing water. It is enough that the moving partys belief be premised upon a rational inference from known or reasonably assumed facts. (Evid. (Id. According to county jail records, Gomez was arrested at 6:48 a.m., 11 minutes after the alleged extended crime spree was first reported. Take this quiz before you apply to see if it will help you meet your goals. 90. Get the most out of your investment. Rules of Court, Rule 3.1345, the responding party has the burden of establishing a valid objection, including any claim of privilege. "We feel so blessed that 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. 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. (Id. 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. Defendant Camachos objection to Plaintiffs untimely Opposition will not be considered because Plaintiff has not filed an Opposition with the Court. Defendant requests that Plaintiff be ordered to provide a further response to interrogatory 12.2. (b)(3).) However, Evidence Code section 1045, subdivision (b)(1) does not operate as a bar to finding good cause with respect to a Pitchess motion. 2023-03-08, Los Angeles County Superior Courts | Personal Injury | Approximately one month later, on August 25, 2019, Plaintiff alleges she was subject to a second episode of Defendant Camachos sexual harassment, which, on this occasion, grew to sexual assault. 658.) A demanding partys motion for an order compelling a further response must, additionally, be accompanied by a separate statement. WebIrwindale Police Department - Irwindale, California. (Warrick v. Superior Court (2005) 35 Cal.4th 1011, 1016, quoting City of Santa Cruz, supra, 49 Cal.3d at p. The Court ORDERS that any and all discoverable information eventually produced as a result of Plaintiffs. #SoCalTelevision #Alert >> Authorities with the Irwindale Police Department are seeking the publics help after a man and woman were found dead in a Police Beat 04/27/2023. 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. 6.) By continuing to use this website, you agree to UniCourts General Disclaimer, Terms of Service, 2016-06-13, Los Angeles County Superior Courts | Personal Injury | 1-4 and 8-11. (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.) WI - Apr 08, 2023. The officers were forced to physically detain the suspect, during which an electro-muscular disruption technology (EMDT) device was successfully deployed. In response to Plaintiffs Requests for Production of Documents, Set Two, Defendant has objected to the production of the external litigation documents on the ground such documents are contained in internal affairs documents or peace officer personnel files, and thus, Plaintiff may only obtain such records pursuant to the filing of a Pitchess Motion. Therefore, the motion is Moot as to interrogatories 6.2 and 6.3. Defendant Camacho also filed an Objection to Plaintiffs untimely opposition to Defendants motion. Plaintiffs Pitchess Motion for Discovery of Police Records is GRANTED, with respect to the following categories of information sought from Defendant CityCategory Nos. Code, 1045.) You can find more information about our Terms of Service and Privacy Policy, Enter your phone number to be notified if you win. The Court finds the description of the records requested is sufficient. Times Staff Writer. May 18, 1986 12 AM PT. (DeMarco Decl., 7, Ex. (Evid. As Defendant Camacho has served supplemental responses, Plaintiffs present Motion is aimed at discovery responses which have been superseded by Defendants supplemental responses. 4-6.) (b)(3). (Id. Phone: 626-430-2244. (CCP 2030.290(c), 2030.300(d), 2031.300(c), 2031.310(h).) 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. Plaintiffs Pitchess Motion for Discovery of Police Officer Records was granted on April 22, 2022. (Evid. (Evid. (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.].). Police are searching for an SUV driver who struck and killed a man in Irwindale on Saturday afternoon, April 29, 2023. Before the Court, are two motions filed by Plaintiff: (A) Plaintiffs Pitchess Motion for Discovery of Police Officer Records, and (B) Plaintiffs Motion to Compel Further Responses to Request for Production of Documents, Set One from Defendant Mario Camacho. (b)(1).) Irwindale Police Department According to a statement from Irwindale Police Department, officers were dispatched to the 5000 block of Azusa Canyon Road after Estimated read time: 1-2 minutes. (Ekimyan Decl. This case was filed in Los Angeles County Superior Courts, Stanley Mosk Courthouse located in Los Angeles, California. And the best part of all, documents in their CrowdSourced Library are FREE! Such information would undoubtedly be included within the personnel records of Defendant Camacho, or in other official records of the Defendant City. (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. All rights reserved. (Id. A structured cabling system benefits businesses by giving you faster processing speeds and making your network more efficient and reliable. Lexipol. Accordingly, the Court finds Plaintiff has proffered sufficient evidence demonstrating good cause pursuant to the requirements outlined in Evidence Code section 1043. Proc., 2031.210, subd. This website uses cookies so that we can provide you with the best user experience possible. In one instance, the suspect fired upon a disabled motorist, forcing him to run across the freeway and in another instance, the suspect fired into an occupied vehicle, striking the vehicle with gunfire.. 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. Plaintiffs Motion is based upon the ground that, in response to Request Nos. 2020-01-10, Los Angeles County Superior Courts | Personal Injury | Our officers responded to Live Oak Avenue and Baldwin Park Boulevard last night for an injury traffic collision that left a big mess in the intersection. 5, 6, and 7. Fraijo was fired from the Irwindale Police Department in February, according to Chief Anthony Miranda. WI - Apr 08, 2023. On March 30, 2021, Plaintiff additionally filed a Pitchess Motion for Discovery of Police Officer Records. Lexipol. 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. In his Separate Statement, Defendant Camacho outlines why the question is relevant, probative, and likely to lead to discoverable evidence. Based on the foregoing, Plaintiffs Motion to Compel Further Responses to Request for Production of Documents Set One from Defendant Camacho is DENIED as MOOT. Harrison Epstein, Daily Herald WebPaul has worked his way up the ranks of the Lehi Police Department, spending time as a patrol officer, detective, and sergeant. Further, Defendant Camachos supplemental responses are materially different than those responses upon which Plaintiffs Motion is currently based. (Evid. The Court next addresses Defendants opposing arguments which the Court finds unpersuasive. (CCP 2030.300(a).). 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. (Pitchess v. Superior Court (1974) 11 Cal.3d 531, 536-37.) Nor does the statute require the declarants personal knowledge. (Id. The ambulance crew informed arriving officers that the suspect fled the scene in a 2015 Peterbilt tractor-trailer. ), 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. Defendant Camacho submitted the Declaration of Artak Mamikony attesting to the defense counsels efforts to meet and confer with Plaintiff. The Court ORDERS Defendant City to produce the categories of documents for an in chambers examination by this Court which shall take place on June 29, 2022, at 9 a.m. On February 4, 2022, Defendant Camacho served responses to Plaintiffs Requests for Production, Set One. For interrogatories, each answer in the response must be as complete and straightforward as the information reasonably available to the responding party permits.