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  • MARLENE GARCIA ET AL VS ROBERT J OWIECKI ET AL Intentional Bodily Injury/Property Damage/Wrongful Death (e.g., assault, vandalism, etc.) (General Jurisdiction) document preview
  • MARLENE GARCIA ET AL VS ROBERT J OWIECKI ET AL Intentional Bodily Injury/Property Damage/Wrongful Death (e.g., assault, vandalism, etc.) (General Jurisdiction) document preview
						
                                

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Electronically FILED by Superior Court of California, County of Los Angeles on 03/23/2020 03:48 PM Sherri R. Carter, Executive Officer/Clerk of Court, by C. Cappadona,Deputy Clerk 1 TERESA LI (SBN 278779) LAW OFFICES OF TERESA LI, PC 2 5674 Stoneridge Drive, Suite 107 Pleasanton, CA 94588 3 Telephone: (415) 423-3377 Facsimile: (888) 646-5493 4 Email: teresa@lawofficesofteresali.com 5 Attorneys for Plaintiffs MARLENE GARCIA and J.J. 6 7 8 SUPERIOR COURT - STATE OF CALIFORNIA 9 COUNTY OF LOS ANGELES - UNLIMITED JURISDICTION 10 MARLENE GARCIA, and J.J., a minor, by ) Case No. BC679114 11 and through his guardian ad litem, ) MARLENE GARCIA ) PLAINTIFFS’ OPPOSITION TO 12 ) DEFENDANT WHITTIER CITY Plaintiffs, ) SCHOOL DISTRICT’S MOTION TO 13 ) SEAL EXHIBIT “G” SUBMITTED IN v. ) SUPPORT OF THE DISTRICT’S 14 ) MOTION FOR SUMMARY ROBERT J. OWIECKI, WHITTIER CITY ) ADJUDICATION 15 SCHOOL DISTRICT, and DOES 1 - 20, ) ) Date: April 7, 2020 16 Defendants. ) Time: 1:30 p.m. ) Department: C 17 ) Reservation ID: 110868558518 ) 18 ) Complaint Filed: October 11, 2017 _____________________________________) Trial Date: August 24, 2020 19 I. LEGAL ARGUMENT 20 A. The Court Should Deny the Motion Because Otherwise, It Violates the Public’s 21 First Amendment Right of Public Access and Exhibit G Was First Produced by the Police Department Without Designation of Confidential 22 “Unless confidentiality is required by law, court records are presumed to be open.” (Cal. 23 R. Court R. 2.550(c).) “The court may order that a record be filed under seal only if it expressly 24 finds that establish: (1) There exists an overriding interest that overcomes the right of public 25 access to the record; (2) The overriding interest supports sealing the record; (3) A substantial 26 probability exists that the overriding interest will be prejudiced if the records is not seals; (4) The 27 proposed sealing is narrowly tailed; and (5) No less restrictive means exist to achieve the 28 2020-03-23 - Opposition to Motion to Seal.docx 1 PLAINTIFFS’ OPPOSITION TO DEFENDANT WHITTIER CITY SCHOOL DISTRICT’S MOTION TO SEAL EXHIBIT “G” SUBMITTED IN SUPPORT OF THE DISTRICT’S MOTION FOR SUMMARY ADJUDICATION