Kayleigh Slusher et al v. City of Napa et al

Filing 106

ORDER For Exchange of Documents and Information Pursuant to Protective Order. Signed by Chief Magistrate Judge Joseph C.Spero on 7/29/16. (klhS, COURT STAFF) (Filed on 8/1/2016)

1
2
3
4
5
6
7
8

MICHAEL J. HADDAD (State Bar No. 189114)
JULIA SHERWIN (State Bar No. 189268)
T. KENNEDY HELM (State Bar No. 282319)
MAYA SORENSEN (State Bar No. 250722)
HADDAD & SHERWIN LLP
505 Seventeenth Street
Oakland, California 94612
Telephone: [phone]
Facsimile: [phone]
Attorneys for Plaintiffs
KAYLEIGH SLUSHER, Dec., JASON SLUSHER,
ROBIN SLUSHER and BENNY SLUSHER

9

UNITED STATES DISTRICT COURT

10

NORTHERN DISTRICT OF CALIFORNIA

11
12
13
14

KAYLEIGH SLUSHER, Deceased, THROUGH
HER SUCCESSOR IN INTEREST JASON
SLUSHER; JASON SLUSHER, Individually;
ROBIN SLUSHER, Individually; and BENNY
SLUSHER, Individually,
Plaintiffs,

15
vs.
16
17
18
19
20
21
22
23
24

CITY OF NAPA, a public entity; NAPA POLICE
OFFICER GARRETT WADE, Individually;
NAPA POLICE OFFICER DEGUILIO,
Individually; NAPA CHIEF OF POLICE
RICHARD MELTON, Individually and in his
Official Capacity; COUNTY OF NAPA, a public
entity; NAPA COUNTY CHILD WELFARE
SERVICES SOCIAL WORKER NANCY
LEFLER, Individually; NAPA COUNTY CHILD
WELFARE SERVICES WORKER ROCIO
DIAZ-LARA, Individually; and DOES 1–50,
Jointly and Severally
Defendants.

)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)

Case No. 4:15-cv-02394-SBA (JCS)
Hon. Saundra Brown Armstrong
Hon. Joseph C. Spero
(PROPOSED) ORDER FOR
EXCHANGE OF DOCUMENTS
AND INFORMATION
PURSUANT TO PROTECTIVE
ORDER

25
26
27
28
Case No. 4:15-cv-02394-SBA (JCS): (PROPOSED) ORDER FOR DOCUMENT EXCHANGE

1

The Court, having reviewed Plaintiffs’ Notice Re: Denial of County Defendants’ Motion to

2

Stay, the Court’s Order Denying County Defendants’ Motion to Stay (Dkt. 99), and the record in

3

this matter, and good cause appearing, this Court hereby Orders as follows:

4
5

1)

All parties shall receive a complete copy of all Coroner’s, Autopsy, and Toxicology reports;

6

complete Coroner’s Office investigative files related to the death of Kayleigh Slusher; all

7

photographs of any kind related to the death of Kayleigh Slusher, including but not limited to all

8

autopsy photographs; all recordings, whether by audio or video, related to the death of Kayleigh

9

Slusher; and all statements, interviews, notes, correspondence, or records of any kind related to the

10

death of Kayleigh Slusher.

11

2)

12

information in the possession, custody, or control of A) the City of Napa and its police department,

13

concerning Kayleigh Slusher’s death and the claims and defenses made in this case, regardless of

14

the source; B) the City of Napa and its police department, concerning all calls for service to

15

Kayleigh Slusher’s apartment (2060 Wilkins Avenue, Apt. 7, Napa, CA) prior to February 3, 2014,

16

regardless of the source; C) Napa County concerning Kayleigh Slusher’s death and the claims and

17

defenses made in this case, regardless of the source; and D) Plaintiffs, concerning Kayleigh

18

Slusher’s death and the claims and defenses made in this case, regardless of the source.

19

3)

No party waives any legal right to assert appropriate privileges, with a privilege log.

20

4)

All documents and information produced pursuant to this Order shall be deemed

21

confidential and subject to the Protective Order in this matter. (Dkt. 33).

22

5)

23

this Order in court during the pendency of criminal proceedings against Sara Krueger or Ryan

24

Warner, that party shall file the documents and information under seal.

25

6)

26

within ten days of this Court’s Order. The City of Napa Defendants shall produce the documents

27

and information no later than August 15, 2016, given their counsel’s travel outside the country.

The documents and information to be produced specifically includes all records and

Should any party need to file any of the documents and information produced pursuant to

Plaintiffs and the Napa County Defendants shall produce the documents and information

28
Case No. 4:15-cv-02394-SBA (JCS): (PROPOSED) ORDER FOR DOCUMENT EXCHANGE

1

1
2

FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.

3
4

S

R NIA

FO

H

ER

LI

RT

9

______________________________
Spero
seph C.
Judge Jo
Chief United States Magistrate Judge
NO

8

S DISTRICT
TE
C
TA

A

7

HONORABLE JOSEPH C. SPERO
RT
U
O

6

7/29/16
Dated: ________________

UNIT
ED

5

N

F
D IS T IC T O
R

C

10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
Case No. 4:15-cv-02394-SBA (JCS): (PROPOSED) ORDER FOR DOCUMENT EXCHANGE

2