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Ce aan ke 10 uw 12 13 14 15 16 7 18 19 20 21 2 24 25 26 27 28 | RICHARD A. LEVINE, ESQ. (SBN 91671) conrs FP JACOB A. KALINSKI, ESQ. (SBN 233709) 8 sre Galore | BRIAN?. ROSS, ESQ. (SBN 273991) i Beat ee SILVER, HADDEN, SILVER & LEVINE FEB 17 2015 1428 Second Street, Suite 200 P.O. Box 2161 sve OffcerCherk Santa Monica, CA 90407-2161 Sheri R, Carter, Execu | 310) 393-1486 (Telephone) By T, Batoy, Deputy G10) 395-3801 (Fax) | Attomeys for Plaintiff Los Angeles Police Protective League SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF LOS ANGELES LOS ANGELES POLICE PROTECTIVE Case No. BC 481380, LEAGUE, Assigned to Department 62 Plaintiff, Honorable Michel L. Stem [PRORESED| JUDGMENT AND PERMANENT INJUNCTION CITY OF LOS ANGELES, 2 municipal corporation, CHARLES BECK, Chief of Police, City of Los Angeles, and DOES 1 through 20, inclusive, Defendants, On January 12, 2015, Plaintiff Los Angeles Police Protective League's Motion for ‘Summary Judgment, or in the altemative, Summary Adjudication against Defendants City of Los Angeles and Charles Beck, Chief of Police, came on for hearing in Department 62 of the above-entitled Court before the Honorable Michael L. Stern. Brian Ross, Esq. and Jacob PROPOSED] JUDGMENT AND PERMANENT INJUNCTION Kalinski, Esq., appeared on behalf of Plaintiff Los Angeles Police Protective League. Deputy City Attorney Douglas Lyon appeared on behalf of Defendants City of Los Angeles and Charles Beck, Chief of Police. ‘The Court, having considered Plaintiff’'s Motion for Summary Judgment and supporting papers, the Opposition of Defendants and supporting papers, Plaintiff's Reply and supporting papers, and oral argument, and having found no triable issue of any material fact and concluding that the moving party is entitled to a judgment as a matter of law, granted Plaintiff's Motion for Summary Judgment. THEREFORE, IT IS ADJUDGED THAT: 1. The Plaintiff-Los Angeles Police Protective League is entitled to Judgment in its favor and against Defendants City of Los Angeles and Charlie Beck, Chief of Police for the City of Los Angeles on the First and Second Causes of Action in the Plaintiff's Complaint for Injunctive Relief and Declaratory Relief, 2. Defendants City of Los Angeles and Charlie Beck, Chief of Police for the City of Los Angeles and their employees and agents are hereby permanently enjoined from imposing or utilizing, against Plaintiff Los Angeles Police Protective League’s represented employees, involuntary Conditional Official Reprimands containing a predetermined minimum disciplinary penalty to be imposed in the event of a future commission by an employee of the same or similar alleged misconduct, 3, Plaintiff Los Angeles Police Protective League is entitled to a declaratory |) adjudication that Defendants, including the Chief of Police may not, consistent with procedural due process, Los Angeles City Charter Section 1070 and/or the Board of Rights Manual or applicable law, impose involuntary Conditional Official Reprimands which predetermine the ‘minimum disciplinary penalty against an officer in the event of a future commission of the same or similar alleged misconduct by such officer. td uw sd TFROFOSEDI JUDGMENT AND PERMANENT INJUNCTION wk en 10 I 12 3B 4 15 16 17 18 19 20 a 2 23 24 25 | 26 27 28 | 4, Plaintiff Los Angeles Police Protective League is entitled to costs incurred in prosecuting this action in the amount of. ‘oon FEB TNS ICHAEL LL STERN Honorable Michael L, Stem Judge of the Superior Court TFROFOSEDI JODGMENT AND PERMANENT INFUNCTION ea aw AYN © 10 il 12 1B 14 15 16 7 18 19 20 2 2 B 24 25 26 27 28 PR¢ \F SERVICE STATE OF CALIFORNIA, COUNTY OF LOS ANGEL! Tam employed in the County of Los Angeles, State of California. 1am over the age of 18 and not a party to the within action; my business address is 1428 Second Street, P.O. Box 2161, Santa Monica, California 90407-2161. On January 27, 2015, I served the foregoing document described as [PROPOSED] JUDGMENT AND PERMANENT INJUNCTION con the parties in this action by placing a true copy thereof enclosed in a sealed envelope addressed as follows: ‘Michael N. Feuer, City Attomey Thomas H. Peters, Chief Assistant City Attomey Wayne H. Song, Managing Assistant City Attorney Douglas Lyon, Deputy City Attorney 200 N, Main Street 7 Floor, City Hall East Los Angeles CA 90012 dlyon@lacity org Tele: (213) 978-8291 Fax: (213) 978-8216 [1] [By Personal Service - via Action Messenger] I caused the above document to be personally delivered to the party represented by an attomey. Delivery was made to the attomey or at the attorney’s office by leaving the document, in an envelope or package clearly labeled to identify the attomey being served, with a receptionist or an individual in charge of the office. [X] [By Electronic Mail] | transmitted the document(s) to the addressee(s) via electronic ‘mail at the address listed above. L ] [By Overnight Mail - Federal Express|__I delivered said documents to an authorized courier or driver authorized to receive documents, in an envelope or package designated by the express service carrier with delivery fees paid or provided for, addressed to the person on whom itis to be served for delivery on the next business day. X__ STATE [declare under penalty of perjury under the laws of the State of California that the above is tre and correct, Executed on January 27, 2015, at Santa Monica, California. MICHELE R. HENGESBACH of / huod tobl, ataoh/