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Demus v. Rankins

United States District Court, Ninth Circuit

December 12, 2013

DEVOREAUX Z. DEMUS, Plaintiff,
v.
OFFICER K. RANKINS, et al., Defendants.

LAW OFFICES OF JEFF D. PRICE, Jeff D. Price, Esq., Attorneys for Plaintiff. DEVOREAUX DEMUS

CAL. P. SAUNDERS, Esq., (SBN 63497) TAUFIKI D. JOSHUA, Esq., OFFICE OF THE CITY ATTORNEY, CITY OF INGLEWOOD, Inglewood, California. Attorneys for Defendants, CITY OF INGLEWOOD, INGLEWOOD POLICE DEPARTMENT, SAMUEL BAILEY, KEITH RANKINS, GABRIELA GARCIA, and JACQUELINE SEABROOKS

GEORGE L. MALLORY, JR. & ASSOCIATES Taufiki D. Joshua, Esq., Attorneys for Defendants. CITY OF INGLEWOOD, INGLEWOOD POLICE DEPARTMENT, KEITH RANKINS, SAMUEL BAILEY, GABRIELA GARCIA, JACQUELINE SEABROOKS

STIPULATION AND PROTECTIVE ORDER

JACQUELINE CHOOLJIAN, Magistrate Judge.

The parties have discussed the privileged nature of the Inglewood Police Department Internal Affairs materials regarding the investigation of the subject March 31, 2011 incident, which is the basis of the instant lawsuit, along with other instances of Internal Affairs investigations of personnel complaints made against the individually named Defendants in the instant litigation.

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. One (1) page of four photographs depicting Devoreaux Demus on March 31, 2011;
2. One (1) page Inter-Departmental Communication from Chief of Police to Internal Affairs Division Commander Re Miscellaneous Inquiry 2011-M-002 dated February 22, 2012;
3. Two (2) page Inter-Departmental Communication from Sergeant Iguchi to Chief of Police Re Citizen Personnel Complaint dated March 31, 2011;
4. Two (2) page Inglewood Police Department Personnel Complaint Form completed by Devoreaux Demus dated March 31, 2011;
5. Ten (10) page Inter-Departmental Communication from Sergeant Richmond to Chief of Police Re Personnel Complaint #11M-002 dated February 21, 2012;
6. Two (2) page Inter-Departmental Communication from Sergeant Iguchi to Chief of Police Re Citizen Personnel Complaint dated March 31, 2011;
7. Two (2) page Inglewood Police Department Personnel Complaint Form completed by Devoreaux Demus dated March 31, 2011;
8. Two (2) pages of Inglewood Police Department Internal Affairs Division Investigative Notes;
9. One (1) page Inter-Departmental Communication from Internal Affairs Division to Officer Samuel Bailey Re Administrative Investigation;
10. One (1) page Inter-Departmental Communication from Internal Affairs Division to Officer Keith Rankins Re Administrative Investigation;
11. Two (2) pages of Inglewood Police Department Internal Affairs Division Investigative Notes;
12. One (1) page Inter-Departmental Communication from the City Clerk to Cal Saunders Re Tort Claim Notice;
13. Seventeen (17) page Tort Claim Notice of Devoreaux Demus;
14. Seven (7) page Inglewood Police Department Crime/Arrest Report DR# 11-3057;
15. One (1) page Inter-Departmental Communication from the City Clerk to Cynthia Stuart Re Tort Claim Notice;
16. One (1) page Inter-Departmental Communication from Internal Affairs Division to Officer Samuel Bailey Re Administrative Investigation;
17. One (1) page Inter-Departmental Communication from Internal Affairs Division to Officer Keith Rankins Re Administrative Investigation;
18. Three (3) pages of email correspondence between Jeff Price and Sergeant Robert Richmond;
19. One (1) page letter from Sergeant Robert Richmond to Devoreaux Demus dated January 2, 2012;
20. Four (4) pages of emails from Sergeant Robert Richmond to Jeff Price;
21. One (1) page State Bar of California Attorney Search Results Re Attorney Daniel Sharpe;
22. Two (2) pages of email correspondence between Sergeant Robert Richmond and Jeff Price;
23. One (1) page of email correspondence between Sergeant Robert Richmond and Derald Brenneman;
24. One (1) page email from Sergeant Robert Richmond to Jeff Price;
25. Eight (8) page Inter-Departmental Communication from Chief of Police to Citizen Police Oversight Commission Re Summary of CPOC Complaint 11M-002 dated February 21, 2012;
26. One (1) page letter from Chief of Police to Devoreaux Demus Re Internal Affairs Case #2011-M-002 dated February 22, 2012;
27. One (1) page of four photographs depicting Plaintiff Devoreaux Demus on March 31, 2011;
28. One (1) page containing a photocopy of Devoreaux Demus' California Drivers License;
29. One (1) page Inglewood Public Safety System Officer Roster Snapshot;
30. One (1) page Inglewood Public Safety System Incident Detail;
31. One (1) page Inglewood Public Safety System Police Unit Log;
32. One (1) page Inglewood Public Safety System Police Unit History;
33. One (1) page Inglewood Public Safety System Police Unit Log;
34. One (1) page Inglewood Public Safety System Police Unit History;
35. Two (2) page Inglewood Public Safety System Police Unit Log;
36. Three (3) page Inglewood Public Safety System Police Unit History;
37. Two (2) page Inglewood Public Safety System Police Unit Log;
38. Two (2) page Inglewood Public Safety System ...

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