Hon. Judge: Otis D. Wright, II
The opinion of the court was delivered by: Honorable VICTOR B. Kenton United States Magistrate Judge Central District of California
CAL P. SAUNDERS, Esq., (SBN 63497) TAUFIKI D. JOSHUA, Esq., (SBN 207636) OFFICE OF THE CITY ATTORNEY CITY OF INGLEWOOD One Manchester Boulevard, Suite 860 Inglewood, California 90301 Telephone: (310) 412-5372 Facsimile: (310) 412-8865 firstname.lastname@example.org email@example.com Attorneys for Defendants, CITY OF INGLEWOOD, OFFICER OSWALDO FIGUEROA and OFFICER ALVARO RUIZ
STIPULATION AND PROTECTIVE ORDER
Complaint Filed: June 4, 2010 Trial Date: September 13, 2011
The parties have discussed the privileged nature of the Inglewood Police Department Internal Affairs materials regarding the investigation of the subject July 1, 2008 incident, which is the basis of the instant lawsuit.
Such confidential materials kept by Defendants are governmental documents that contain official information. Such confidential material has been maintained by Defendants in confidence and contains sensitive and private information.
Defendants are extremely concerned that dissemination of subject information, documents, and materials related to the incident, relevant personnel, and other confidential internal investigations could compromise the efficacy of such undertaking in the future and act to discourage cooperation from the public. Further, disclosure of which without a protective order may compromise the safety of the subject peace officers and their families and third parties.
These materials are subject to various privileges including Evidence Code §§ 1040, 1043, et seq., Government Code § 3300, et seq. and/or the official information privilege. Further, such material also contains private and confidential third-party information. The materials include but are not limited to the following documents:
1. Six (6) page Inglewood Police Department Incident Report re Incident No. 08-7666;
2. Six (6) page Inglewood Police Department Incident Report re Incident No. 08-7666;
3. Four (4) page Inglewood Police Department Incident Report/Arrest Report re Incident no. 08-7666;
4. Transcript of the July 2, 2008 interview of Officer Alvaro Ruiz;
5. Transcript of the July 17, 2008 interview of Officer Alvaro Ruiz;
6. Transcript of the July 2, 2008 interview of Officer Oswaldo Figueroa.
7. Transcript of the July 17, 2008 interview of Officer Oswaldo Figueroa;
8. Transcript of the July 1, 2008 interview of Donnell Hawkins.
9. Transcript of July 2, 2008 interview of Otis Virgil;
10. Transcript of the interview of Christopher Perry;
11. Transcript of the July 7, 2008 Interview of Robin Virgil;
12. One (1) page Shift Roster;
13. Thirty-five (35) page Call ...