MOVING PARTY: Esperanza Velarde Sanchez, individually and as successor-in-interest to Jose Luis Osuna, deceased

OPPOSITION: Non-Party Los Angeles Police Department

On January 17, 2016, Jose Luis Osuna (“Decedent”), was driving northbound on State Route 110. While driving, Decedent was critically injured when a brick was thrown through a hole in the overpass fence by Rudy Simental, Jr., a homeless man. Decedent suffered severe head trauma and died on March 17, 2017. Simenthal was charged and convicted of the crime.

On September 19, 2019, Plaintiff Esperanza Velarde Sanchez (“Plaintiff”), individually and as successor-in-interest to Decedent, sued Defendant Department of Transportation. On September 19, 2019, Plaintiff served third-party Los Angeles Police Department (“LAPD”) with a Deposition Subpoena for Production of Business Records. The subpoena sought the production of any and all reports, audiotape interviews, video, and audio recordings, concerning the investigation of Simenth