On September 23, 2019 a
Motion-Secondary
was filed
involving a dispute between
Filed By: Ridge, David,
Ridge, David,
and
Does 1-100,
The California Highway Patrol,
for (Other Employment Complaint Case)
in the District Court of Sacramento County.
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1 ROB BONTA
Attorney General of California
2 KRISTIN M . DAILY
Supervising Deputy Attorney General
3 JAMES F. CURRAN
Deputy Attorney General
4 State Bar No. 142041
1300 I Street, Suite 125
5 P.O. Box 944255
Sacramento, CA 94244-2550
6 Telephone: (916)210-6113
Fax: (916)324-5567
7 E-mail: James.Curran@doj.ca.gov
Attorneys for Defendant
8 California Highway Patrol
9 SUPERIOR COURT OF THE STATE OF CALIFORNIA
10 COUNTY OF SACRAMENTO
12
13
DAVID RIDGE, Case No. 34-2019-00265393
14
Plaintiff, [PROPOSED] PROTECTIVE ORDER RE
15 DISCLOSURE OF PEACE OFFICER
PERSONNEL RECORDS
16
Date: July 20, 2022
17 THE CALIFORNIA HIGHWAY PATROL; Time: 1:30 p.m.
and DOES 1-100, inclusive. Dept: 53
18 Judge: Hon. Richard K. Sueyoshi
Defendants. Trial Date: April 3, 2023
19 Action Filed: September 23, 2019
20
21 Defendant David Ridge's "Motion for Discovery Pursuant to penal Code Section 832.7 and
22 Evidence Code Section 1043" (Pitchess) came before this Court on July 20, 2022, at
23 approximately 1:30 p.m. in Department 53.
24 This Court, having ordered disclosure of the records and other information enumerated in
25 its Order for Discovery Pursuant to Evidence Code Section 1043, issues the following protective
26 order:
27
28
1
[Proposed] Protective Order Re Disclosure of Peace Officer Personnel Records (34-2019-00265393)
1 1. No information disclosed pursuant to this Court's order shall be used to oppress,
2 embarrass, or annoy the California Highway Patrol (CHP) officers whose records were the
3 subject of this motion.
4 2. The information ordered disclosed pursuant to this Court's order shall be used for no
5 purpose other than to contact the officers whose records this Cbiirt has ordered disclosed to ask
6 those officers the following questions:
7
8
9
10
11
12 3. In no event shall the information ordered disclosed pursuant to this Court's order be
13 used for any purpose other than a court proceeding pursuant to applicable law; and
14 4. Upon conclusion of the instant action, the original documents and all photocopies of
15 the records and information disclosed pursuant to this Court's order shall be returned to the Office
16 of the Attorney General, attention: Deputy Attorney General James F. Curran, 1300 I Street,
17 Sacramento, CA 95814.
18 DATED: / /2022
19
JUDGE OF THE SUPERIOR COURT
20
21 SA2019106238
3627791 l.docx
22
23
24
25
26
27
28
[Proposed] Protective Order Re Disclosure of Peace Officer Personnel Records (34-2019-00265393)
DECLARATION OF SERVICE BY E-MAIL
Case Name: David Ridge v. CHP
No.: 34-2019-00265393
I declare:
1 am employed in the Office of the Attorney General, which is the office of a member of the
California State Bar, at which member's direction this service is made. 1 am 18 years of age or
older and not a party to this matter. 1 am familiar with the business practice at the Office of the
Attorney General for collection and processing of correspondence for mailing with the United
States Postal Service. In accordance with that practice, correspondence placed in the internal
mail collection system at the Office of the Attorney General is deposited with the United States
Postal Service with postage thereon fully prepaid that same day in the ordinary course of
business.
On July 7, 2022,1 served the attached [PROPOSED] PROTECTIVE ORDER RE
DISCLOSURE OF PEACE OFFICER PERSONNEL RECORDS by transmitting a true
copy via electronic mail addressed as follows:
John P. Briscoe
Mayall Hurley P.C.
E-mail Address:
ibriscoe@mavallaw.com
]riley@,mavallaw.com
I declare under penalty of perjury under the laws of the State of California and the United States
of America the foregoing is true and correct and that this declaration was executed on Jj^iy 7,
2022, at Sacramento, California.
Christopher R. Irby
Declarant
SA20I9I06238
36345366.docx
Document Filed Date
July 07, 2022
Case Filing Date
September 23, 2019
Category
(Other Employment Complaint Case)
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1 ROB BONTA Attorney General of California 2 KRISTIN M . DAILY Supervising Deputy Attorney General 3 JAMES F. CURRAN Deputy Attorney General 4 State Bar No. 142041 1300 I Street, Suite 125 5 P.O. Box 944255 Sacramento, CA 94244-2550 6 Telephone: (916)210-6113 Fax: (916)324-5567 7 E-mail: James.Curran@doj.ca.gov Attorneys for Defendant 8 California Highway Patrol 9 SUPERIOR COURT OF THE STATE OF CALIFORNIA 10 COUNTY OF SACRAMENTO 12 13 DAVID RIDGE, Case No. 34-2019-00265393 14 Plaintiff, [PROPOSED] PROTECTIVE ORDER RE 15 DISCLOSURE OF PEACE OFFICER PERSONNEL RECORDS 16 Date: July 20, 2022 17 THE CALIFORNIA HIGHWAY PATROL; Time: 1:30 p.m. and DOES 1-100, inclusive. Dept: 53 18 Judge: Hon. Richard K. Sueyoshi Defendants. Trial Date: April 3, 2023 19 Action Filed: September 23, 2019 20 21 Defendant David Ridge's "Motion for Discovery Pursuant to penal Code Section 832.7 and 22 Evidence Code Section 1043" (Pitchess) came before this Court on July 20, 2022, at 23 approximately 1:30 p.m. in Department 53. 24 This Court, having ordered disclosure of the records and other information enumerated in 25 its Order for Discovery Pursuant to Evidence Code Section 1043, issues the following protective 26 order: 27 28 1 [Proposed] Protective Order Re Disclosure of Peace Officer Personnel Records (34-2019-00265393) 1 1. No information disclosed pursuant to this Court's order shall be used to oppress, 2 embarrass, or annoy the California Highway Patrol (CHP) officers whose records were the 3 subject of this motion. 4 2. The information ordered disclosed pursuant to this Court's order shall be used for no 5 purpose other than to contact the officers whose records this Cbiirt has ordered disclosed to ask 6 those officers the following questions: 7 8 9 10 11 12 3. In no event shall the information ordered disclosed pursuant to this Court's order be 13 used for any purpose other than a court proceeding pursuant to applicable law; and 14 4. Upon conclusion of the instant action, the original documents and all photocopies of 15 the records and information disclosed pursuant to this Court's order shall be returned to the Office 16 of the Attorney General, attention: Deputy Attorney General James F. Curran, 1300 I Street, 17 Sacramento, CA 95814. 18 DATED: / /2022 19 JUDGE OF THE SUPERIOR COURT 20 21 SA2019106238 3627791 l.docx 22 23 24 25 26 27 28 [Proposed] Protective Order Re Disclosure of Peace Officer Personnel Records (34-2019-00265393) DECLARATION OF SERVICE BY E-MAIL Case Name: David Ridge v. CHP No.: 34-2019-00265393 I declare: 1 am employed in the Office of the Attorney General, which is the office of a member of the California State Bar, at which member's direction this service is made. 1 am 18 years of age or older and not a party to this matter. 1 am familiar with the business practice at the Office of the Attorney General for collection and processing of correspondence for mailing with the United States Postal Service. In accordance with that practice, correspondence placed in the internal mail collection system at the Office of the Attorney General is deposited with the United States Postal Service with postage thereon fully prepaid that same day in the ordinary course of business. On July 7, 2022,1 served the attached [PROPOSED] PROTECTIVE ORDER RE DISCLOSURE OF PEACE OFFICER PERSONNEL RECORDS by transmitting a true copy via electronic mail addressed as follows: John P. Briscoe Mayall Hurley P.C. E-mail Address: ibriscoe@mavallaw.com ]riley@,mavallaw.com I declare under penalty of perjury under the laws of the State of California and the United States of America the foregoing is true and correct and that this declaration was executed on Jj^iy 7, 2022, at Sacramento, California. Christopher R. Irby Declarant SA20I9I06238 36345366.docx