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TILED
NY
Superior Court of Calif
County of Placer =
KRW
AUG 21 2020
DH
opisalves, Deputy
AN
SUPERIOR COURT OF THE STATE OF CALIFORNIA
IN AND FOR THE COUNTY OF PLACER
Oo
OO
ROSEMARY FRIEBORN, Case No. S-CV-40153
YF
RE
NY
Petitioner, Ruling On Petitioner’s
EO
Request For Disclosure
VS. Of Records
BPW
RE
THE COUNTY OF PLACER, et al.,
RE
Respondents.
DH
RE
Petitioner Rosemary Frieborn moves the court for an order compelling
WAN
RR
respondent County of Placer to disclose certain documents in its possession
or control. Specifically, petitioner requests that respondent provide her with
O
NOR
DOD
copies of “(1) any and all correspondence, records, email messages, notes,
memos and/or files, relating to Rosemary Frieborn either held in or produced
FF
DN
by individuals in the Placer County District Attorney’s office; and (2) any and
NN
BPWN
all memos, notes, correspondence, documents and files constituting alleged
NN
Brady violations against Rosemary Frieborn by individuals in the Placer
NY
County District Attorney’s office.”
NY
DM
Since the original hearing date of March 6, 2020, the court has
NY
received several submissions of documents from respondent, which the
OnN
NN
parties stipulated could be reviewed by the court in camera. The court
received documents from respondent on April 27, 2020, May 8, 2020, June
4, 2020 and finally on July 27, 2020. The matter was deemed submitted for
DN
decision on July 27, 2020 upon the court’s receipt of respondent’s last
BW
submission of documents for review. The court has considered the moving
and opposing papers on file and the oral arguments of counsel. Having
DM
reviewed documents in camera, the court rules on petitioner’s motion as
follows:
AN
The court has reviewed all documents submitted by respondent to
determine whether they are subject to disclosure when considering
Oo
respondent’s various assertions of either attorney-client privilege, work
EL
OO
product privilege, or whether they are exempt from disclosure under either
Be
KH
the investigatory, official information or confidential materials exemptions
Be
BWN
under the California Public Records Act. Except as to several documents
He
listed below, the court finds that no further documents must be disclosed.
Bee
The court directs respondent to provide further information as to
DH
document numbers 263, 264, 265, 583, 879, 883, 885 and 888. Those
Be
documents are handwritten and the court is unable to discern the identity
DAN
BBB
and capacity of the author. Respondent is directed to submit a declaration
addressing those documents by August 31, 2020.
OO
So ordered.
NY NY
KRWNHH
Dated: 9 <2/-2o>e>
NY
Cc. ,
— Hon. Glenn M. Paley, Commissioner
NY
Placer County Superior Court
NN
ON
NM
A
NN
ON
SUPERIOR COURT OF CALIFORNIA
IN AND FOR THE COUNTY OF PLACER
CLERK’S CERTIFICATE OF MAILING (C.C.P. §1013a(4))
Case No.: S-CV-0040153
Case Name: Frieborn, Rosemary vs. The County of Placer
I,the undersigned, certify that I am the clerk of the Superior Court of California, County of
Placer, and I am not a party to this case.
I mailed copies of the documents(s) indicated below:
Order: Ruling on Submitted Matter
True copies of the documents were mailed following standard court practices in a sealed
envelope with postage fully prepaid, addressed as follows:
Julia Reeves Paul Boylan
175 Fulweiler Ave. PO Box 719
AUBURN, CA 95603 Davis, CA 95617
I am readily familiar with the court’s business practices for collecting and processing
correspondence for mailing; pursuant to those practices, these documents are delivered to
[Xx]the US Postal Service
[_] UPS
[_] FedEx
[_] Interoffice mail
[_] Other:
on in Placer County, California.
Dated:08/21/2020 JAKE CHATTERS
AN Court
by/__ | \/ ]} ZA
J.Go salves , Députy Cterk
Preview
TILED NY Superior Court of Calif County of Placer = KRW AUG 21 2020 DH opisalves, Deputy AN SUPERIOR COURT OF THE STATE OF CALIFORNIA IN AND FOR THE COUNTY OF PLACER Oo OO ROSEMARY FRIEBORN, Case No. S-CV-40153 YF RE NY Petitioner, Ruling On Petitioner’s EO Request For Disclosure VS. Of Records BPW RE THE COUNTY OF PLACER, et al., RE Respondents. DH RE Petitioner Rosemary Frieborn moves the court for an order compelling WAN RR respondent County of Placer to disclose certain documents in its possession or control. Specifically, petitioner requests that respondent provide her with O NOR DOD copies of “(1) any and all correspondence, records, email messages, notes, memos and/or files, relating to Rosemary Frieborn either held in or produced FF DN by individuals in the Placer County District Attorney’s office; and (2) any and NN BPWN all memos, notes, correspondence, documents and files constituting alleged NN Brady violations against Rosemary Frieborn by individuals in the Placer NY County District Attorney’s office.” NY DM Since the original hearing date of March 6, 2020, the court has NY received several submissions of documents from respondent, which the OnN NN parties stipulated could be reviewed by the court in camera. The court received documents from respondent on April 27, 2020, May 8, 2020, June 4, 2020 and finally on July 27, 2020. The matter was deemed submitted for DN decision on July 27, 2020 upon the court’s receipt of respondent’s last BW submission of documents for review. The court has considered the moving and opposing papers on file and the oral arguments of counsel. Having DM reviewed documents in camera, the court rules on petitioner’s motion as follows: AN The court has reviewed all documents submitted by respondent to determine whether they are subject to disclosure when considering Oo respondent’s various assertions of either attorney-client privilege, work EL OO product privilege, or whether they are exempt from disclosure under either Be KH the investigatory, official information or confidential materials exemptions Be BWN under the California Public Records Act. Except as to several documents He listed below, the court finds that no further documents must be disclosed. Bee The court directs respondent to provide further information as to DH document numbers 263, 264, 265, 583, 879, 883, 885 and 888. Those Be documents are handwritten and the court is unable to discern the identity DAN BBB and capacity of the author. Respondent is directed to submit a declaration addressing those documents by August 31, 2020. OO So ordered. NY NY KRWNHH Dated: 9 <2/-2o>e> NY Cc. , — Hon. Glenn M. Paley, Commissioner NY Placer County Superior Court NN ON NM A NN ON SUPERIOR COURT OF CALIFORNIA IN AND FOR THE COUNTY OF PLACER CLERK’S CERTIFICATE OF MAILING (C.C.P. §1013a(4)) Case No.: S-CV-0040153 Case Name: Frieborn, Rosemary vs. The County of Placer I,the undersigned, certify that I am the clerk of the Superior Court of California, County of Placer, and I am not a party to this case. I mailed copies of the documents(s) indicated below: Order: Ruling on Submitted Matter True copies of the documents were mailed following standard court practices in a sealed envelope with postage fully prepaid, addressed as follows: Julia Reeves Paul Boylan 175 Fulweiler Ave. PO Box 719 AUBURN, CA 95603 Davis, CA 95617 I am readily familiar with the court’s business practices for collecting and processing correspondence for mailing; pursuant to those practices, these documents are delivered to [Xx]the US Postal Service [_] UPS [_] FedEx [_] Interoffice mail [_] Other: on in Placer County, California. Dated:08/21/2020 JAKE CHATTERS AN Court by/__ | \/ ]} ZA J.Go salves , Députy Cterk