PETITIONER'S REPLY BRIEF: CITY OF CARMEL-BY-THE-SEA, Moving Party, v. MONTEREY COUNTY CIVIL GRAND JURY, Respondent. Case NoM131242, SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF MONTEREY

ABSTRACT:  Don G. Freeman, City Attorney, City of Carmel-by-the-Sea, submitted PETITIONER'S REPLY BRIEF in CITY OF CARMEL-BY-THE-SEA, Moving Party, v. MONTEREY COUNTY CIVIL GRAND JURY, Respondent. Case No. M131242, to SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF MONTEREY on March 17, 2015. Reply Brief includes Penal Code 925a Does Not Permit the Disclosure Of Constitutionally Protected Personnel Records, Enforcing The Subpoena Would Deny Due Process, Enforcing the Subpoena Would Deny Privacy Rights, Woodlake is Confined to Police Records and A Protective Order Would Be Required if the Court Orders Disclosure of Personnel Files. Conclusion The core issue remains one of privacy. These personnel records are confidential. Special attention is demanded whenever confidential records are being divulged. See White v. Davis, (1975) 13 Cal. 3d 757, 774, 120 Cal. Rptr. 94, 105. The PETITIONER'S REPLY BRIEF document is embedded.

Petitioner's Reply Brief (m131242)

PETITIONER'S REPLY BRIEF
CITY OF CARMEL-BY-THE-SEA, Petitioner, v. 2014-2015 MONTEREY COUNTY CIVIL GRAND JURY, Respondent.
Case No. M131242
SUPERIOR COURT OF CALIFORNIA
COUNTY OF MONTEREY