Qqreveal Informant Confidential NXT 2final

1 JULIUS JOHNSON
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2 LAW OFFICES OF JULIUS JOHNSON
2476 North Lake Avenue
3 Altadena, CA 91001
Telephone: (626) 622-2434
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Attorney for Defendant
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UNIFIED COURTS OF THE STATE OF CALIFORNIA,
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COUNTY OF LOS ANGELES, CENTRAL JUDICIAL DISTRICT
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PEOPLE OF THE STATE OF CALIFORNIA, ) Case No. BA419302 and BA 419285 _
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Plaintiff, ) ________
12 ) NOTICE OF MOTION AND MOTION
vs. ) TO DISCLOSE IDENTITY OF
13 )
MIGUEL HURTADO, ) INFORMANT; MEMORANDUM OF
14 ) POINTS AND AUTHORITIES AND
Defendant. ) DECLARATION OF JULIUS
15 )
) JOHNSON IN SUPPORT THEREOF
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) Date :
17 ) Time :
) Dept :
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)
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20 To the HONORABLE JUDGE OF THE LOS ANGELES COUNTY SUPERIOR
21 COURT and TO JACKIE LACEY, THE LOS ANGELES COUNTY DISTRICT
22 ATTORNEY, and/or her REPRESENTATIVE:
23 PLEASE TAKE NOTICE that on ____________, 2014 at ____ AM. in Division
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“____“ of the above entitled court, located at 210 West Temple Street, Los Angeles,
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California, defendant HURTADO will move the Court, through his attorney, for an Order
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directing law enforcement personnel who have assisted or are assisting in the
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investigation and prosecution of the above entitled action, including but not limited to the
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NOTICE OF MOTION AND MOTION TO DISCLOSE IDENTITY OF INFORMANT; MEMORANDUM OF

POINTS AND AUTHORITIES; DECLARATION OF JULIUS JOHNSON IN SUPPORT THEREOF; AND ORDER
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Los Angeles City Police Department (hereinafter referred to as the “People”) to disclose
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the identity of the confidential informant(s) used in this case; the present resident address,
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business address, and all other information regarding the present location of said
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police informant; disclosure of all inducement, benefits, promises, rewards, payments,
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6 credits, etc. provided to the informant, for his/her information in this case, or for his/her
7 combined corporation in this case and other cases, and disclosure of any and all bias or
8 personal enmity towards defendants.
9 Said motion will be based on the California Constitution, the United States
10 constitution, in particular the Due Process Clause of the Fifth Amendment; the records,
11 papers, and the files in the above-entitled cause, the attached Memorandum f Points
12 and Authorities; the Declaration of Julius Johnson; and such oral and/or documentary
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evidence as maybe adduced at the hearing of said motion.
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Dated: ______________________
15 Julius Johnson
16 Attorney for Defendant
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5 REQUESTED DISCLOSURE AND DISCOVERY
6 A. Defendant hereby requests that the Court to order the People to produce
7 and disclose the name and identity of any informant utilized in the investigation of
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this case. Defendant specifically requests the following information be provided:
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1. The name and identity of the police informants used in this case;
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11 2. The present resident address, business address, and all other
12 information regarding the present location of said informant;
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3. Information concerning what inquiries and arrangements have been
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made by the People to keep in touch and locate said informants;
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4. The dates and times the informants made their observations;
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17 5. The information provided by the informants;
18 6. All reports, records, memoranda and notes regarding any information
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furnished by the informants, and the dates on which the informants provided
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information to any police department, to any multi-lurisdictional gang or narcotics
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22 investigation, or to the Los Angeles County Sheriffs Department, United States
23 Customs, the Internal Revenue Service, the Federal Bureau of Investigation, the
24 Drug Enforcement Administration, the California Bureau of Narcotic Enforcement,
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or any other law enforcement agency;
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7. All reports evidencing the unreliability of the informants, including the
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28 providing of incorrect information by the informants, or information which did
29 not lead to the arrest(s), “street gang” infiltration or seizure(s);

1 8. All reports and notes indicating the manner, date, time, and place of
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receipt of the integration of from the informants, whether by telephone, written,
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orally, or in meetings.
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6 B. Defendant requests that the Court order the prosecution to produce and
7 disclose all inducement, promises, or benefits provided to the informants for his/her
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information and this case, for his/her cooperation in this case, or for his/her combined
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corporation in this case and other cases. Defendant specifically requests the following
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11 information be provided:
12 1. All pay vouchers of payments made for compensation or expenses to the
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informants for information supplied herein;
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2. All promises, representations or assurances whether or not reduced to
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writing, given in exchange for information supplied by the informants herein;
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17 3. All “recommendations” for sentencing that the People may request at the
18 “sentencing” of the informants;
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4. All agreements to accept a plea to “reduced” offense to, in effect, limit
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the amount of incarceration or other penalty of the informants;
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22 5. A list of all crimes that the People agreed to either cease investigating, or
23 not prosecute, or not to refer for filing against the informants;

24 6. A list of all offenses that the People have learned of subsequent to any
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agreement with the informants, that the People will not now investigate or
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prosecute because of its prior agreement with the informants;
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28 7. A list of the “investigations” that had been commenced or continued
29 based upon information from the informant in the instant matter;

1 8. A list of all offenses known by the People to be committed by the
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informants in the instant matter and subsequent to his/her original agreement to
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cooperate with the People in this matter, if any;
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5 9. Any other ‘inducements”, “rewards”, or “benefits” that have been directly
6 or indirectly provided to the informants in this matter for his or her cooperation in
7 this case, or any other case;
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10. All reports and notes regarding the information furnished by the
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informants in the eighteen (18) months prior to the instant mailer which has led to
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11 the arrest of the persons or the seizure of drugs;
12 11. All reports regarding the infiltration, undermining of and disbandment of
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“street gangs” which resulted from the informants information;
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12. Police reports of any cases pending against the informants at the time
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when the information about defendant was given.
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18 C. Defendant hereby requests that the Court order the prosecution to
19 produce and disclose the extent of the investigating officer’s investigation of specific
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facts which bear adversely on the informants’ accuracy. Defendant specifically
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requests the following information be provided:
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23 1. The nature and extent of any personal bias of the informants toward the
24 defendant.
25 2. All statements or reasons given by the informants for their assistance in
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this particular investigation.
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It is requested that the Order Allowing Discovery of the aforementioned
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1 information be a Continuing Order requiring the People to disclose any and all
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information that It learns of up to and including the termination of trial In the Instant
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matter. Further, defendant requests that any disputed discovery items be viewed by
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5 :he court in camera to determine their materiality and/or those portions of the materials
6 that reveal the informant’s identity.

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8 DATED: ____________________
Julius Johnson
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MEMORANDUM OF POINTS AND AUTHORITIES
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19 I.
WHERE THE INFORMANT IS A MATERIAL WITNESS ON THE ISSUE OF
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DEFENDANT’S GUILT, THE PEOPLE MUST DISCLOSE THE INFORMANT’S
21 IDENTITY OR INCUR A DISMISSAL
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23 Under the pretrial discovery procedure, it has been held that prior to the trial, the
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accused may compel the prosecution to produce in court the identity of any police
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informant who was a material witness, including all information necessary to find and
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27 locate said informant, including the inquiries and arrangements made by the
28 prosecution pursuant to their duty of good faith in trying to locate him. (Eleazer v.
29 Superior Court (1970) 1 Cal.3d 847; Honore v. Superior Court (1969) 60 Cal.2d 162;

1 People v. Goliday (1973) 8 Cal3d 771; Twiops v. Superior Court (1983) 34 Cal.3d
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360, 365-68.)
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A defendant need not prove that an informer could give testimony favorable to
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5 him in order to compel disclosure, nor that the informant was a participant in or an
6 eyewitness to the crime. The defendant need only demonstrate a reasonable possibility
7 that the informant could give evidence on the issue of guilt which might
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result in the defendant’s exoneration. (People v. Garcia (1967) 67 Cal.2d 830; Price v.
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Superior Court (1970) 1 Cal.3d 836, 843; People v. Borunda (1974) 11 Cal. 3d 523.
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11 527.)
12 The basic issue underlying the disclosure standard is constitutional due
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process. (People v. Goliday, supra, at 775, n.6; People v. Garcia, supra, at 842;
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Peoe v. Kiihoa (1960) 53 Cal.2d 748.) An informant is necessarily a material witness
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to the crime of possession for sale when the possession of a controlled substance is
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17 circumstantial and the evidence shows that the informant had a vantage point from
18 which he viewed the antecedents of the alleged crime prior to the execution of the
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search warrant. (Williams v. Superior Court (1974)38 Cal. App. 3d 412; People v.
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Meiia (1976) 57 Cal. App.3d 574; People v. Tolliver (1975) 53 Cal. App. 3d 1036;
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22 People v. Coleman (1977) 72. Cal. App. 3d 289, 294-98.)
23 In Williams, the defendant denied that she had any actual or constructive
24 possession of the contraband, or that she knew of its presence and nature, or that she had
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the requisite intent to sell, and contended proof of her possession was
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circumstantial (i.e., imputed from the presence of the contraband in her drawer among
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28 her underclothes). According to the affiant police officer, the informant had seen the
29 defendant and another person selling and packaging heroin prior to the search

1 warrant’s execution. The facts of Williams are parallel to the case at hand wherein the
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affiant police officer indicates a telephone call was received from a confidential
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informant with familiarity regarding the “Gerraty Street Gang” and the gang member
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5 participants in the “fire-fight” with the officers in the present case. Further the informant
6 claimed knowledge of the possessor of the contraband (gun, etc.) and the secreted
7 location of the contraband.
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Under such circumstances, as in Williams, the court upheld the defendants
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contention of a reasonable possibility that the informer might testify that the defendant
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11 was merely present when he was at the residence, and that the heroin was sold,
12 packaged and controlled by the other person. The Court stated that from such
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testimony, the trier of fact might infer that the defendant had no control or right to the
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heroin later found in the dresser, and that she herself had no intent to sell contraband.
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The Court issued a writ of mandate to the Superior Court directing disclosure of the
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17 informer on penalty of dismissal if not complied with.
18 The Court in Williams, supra, at 422, reasoned:
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“[W]hen contraband is found in a place to which a defendant and others have access and
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which none has exclusive control ‘no sharp line be drawn to distinguish the congeries of
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22 facts which will and that which will not constitute sufficient evidence of the defendant’s
23 knowledge of the presence of a narcotic... “(Citation.) “(P)roof of the opportunity of

24 access to a place where narcotics are found, without more, will not support a finding of
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unlawful possession. “(Eople v. Redrick. 55 Cal.2d 282, 285 (1961).)
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Where possession of contraband is among the elements of the crime charged
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28 and It Is Imputed to the defendant by the reason or the location In which the contraband is
29 discovered by the police and where such discovery stems in whole or

1 part of from an informer’s very recent observations of contraband on those same
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premises, the Supreme Court has compelled the disclosure of the informer’s identity if
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the evidence shows that persons other than the defendant were on the premises when the
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5 informer observed the contraband and that the defendant was not then present or
6 may not have been present (People v. Garcia, supra, 76 Cal.2d 830...) (Citations), or if
7 the record is silent as to whether the defendant was present (Citations).
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[T]he evidentiary showing required... is not as to the exculpatory nature of the
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informer’s potential testimony but merely as to what the quality of the vantage point
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11 from which the informer viewed either the commission or the immediate antecedents
12 of the alleged crime. The noted Supreme Court cases ask, in effect, ‘What was the
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informer in a posftion to perceive?” If the evidence shows that the informer had a
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sufficiently proximate vintage point, those Supreme Court decisions simply speculate
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concerning the informer’s potential testimony and hold that the defendant has
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17 demonstrated a reasonable possibility that the informant could give evidence which
18 might result in the defendant’s exoneration. (Emphasis added.)
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The court in People v. Tolliver, supra, commented on the necessity for
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disclosure of the informant when there is no evidence of dominion and control over the
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22 specific narcotics where there is a joint control over the premises searched:
23 But the people misconceive the thrust of defendant Calep’s argument. Calep’s point as to
24 materially of the informant’s testimony is exactly the same as that of
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defendant Tolliver. The contention may be advanced by both defendants that the
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informer might testify that neither Calep nor Tolliver was in possession of any
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28 contraband found in various places on the premises that the contraband which
29 defendant Calep sold to the informant in the past came from a third person in the

1 premises who was in control of the contraband and that in the case of defendant
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Toiliver’s sale of narcotics to the informant in the past, the contraband also came from
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a third person present on the premises who was in control of such contraband.
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5 The record reveals that the informant did not tell Officer Gilbert that he saw, prior
6 to any sale transaction with defendant Calep or defendant Tolliver, where either
7 defendant obtained the contraband, whether from the other, whether for the
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defendant’s person, or whether from a specific area in the premises such as a
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cupboard in the kitchen, a drawer or chest of drawers, or a suitcase from under a bed.
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11 (Emphasis added). 53 Cal. App. 3d at 1046.
12 After summarizing the facts and holdings in Williams v. SuDerior Court, the
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Tolliver court concluded:
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In the case at bench, as in Williams, the undisclosed informer might have given
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testimony In favor of defendant HURTADO, or In favor of no-defendant, which
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17 would throw the onus of control or right to control the contraband (guns, etc.) found
18 on some third person present in the residence when the informer was there. (Emphasis
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added)J4., at 1049.
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In sum, if it appears that there is a reasonable possibihty that an informant may
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22 aid in the defense he must be produced or the case dismissed. (Honore v. Superior
23 Court, supra; People v. Borunda, supra; Williams v. Superior Court, supra.)

24 In Williams, the court stated:
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The rationale of the ruling requiring disclosure “is that the defendant, through
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the testimony of the informer when his identity is made known, might be able to rebut a
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28 material element of the prosecution’s case and thereby prove his innocence. The
29 denial by the prosecution of an opportunity for a defendant to seek out the informer

1 and to defend by these means, where the testimony of the informer would be material
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to the issues, is unfair and oppressive to the defendant, and deprives him of due
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process of law.” (PeoDle V. Kiihoa, supra, 53 Cal. 2d at 752). (Italics added). “The
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5 defendant is entitled as a matter of due process of law to be allowed to interview and
6 produce any witness who might give evidence favorable to his defense . (People V.
7 Castial, supra, 153 Cal. App. 2d at 657). 38 Cal. App. 3d at 419. In Peoole v Garcia,
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supra, at 840, The Supreme Court stressed that: No one knows what the undisclosed
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informer, if produced, might testify. He might contradict or persuasively explain away the
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11 prosecutor’s evidence. It is the deprival of the defendants of the opportunity of producing
12 evidence which might result in their exoneration which constitutes the error of this case,
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and we cannot assume because the prosecution evidence may seem strong that the
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undisclosed evidence might not prove sufficient to overcome it in the minds of the jurors.
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(People v. Castial, (1957)153 Cal. App. 2d 653, 659 f315 P.2d 791.) California courts
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17 have long held that the identity of the informant must be disclosed if there is a
18 “possibility” that the unnamed informant is a material witness.
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The Courts have also allowed some “speculation” by the defense in determining if
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this possibility exists. (People v. Hunt, (1971) 4 Cal. 3d 231, 240; Price v. Superior Court
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22 (1970)1 CaI.3d 836, 843.) Here, although differing from as in Williams and Tolliver, yet
23 parallel in nature, defendant HURTADO is charged with being in possession of a firearm

24 and using the firearm to attempt to murder to Sheriffs deputies with the gun which was
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seized from a location where the public and others had access.
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The evidence herein was allegedly seized from various locations; including
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28 public locations, which are openly accessible to numerous other persons.
29 The Informant referred to in the police reports allegedly had current information

1 regarding the defendants’ violent gang activity (including shooting at sheriffs deputies)
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and had information as to police having arrested the wrong individual for crimes the
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informant alleges were committed by HURTADO and others; specifically, the
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5 attempted murder of- the officers in this case. The informant claimed personal
6 knowledge and familiarity with the “Gerraty” street gang members and activities.
7 Further, the informant claimed knowledge as to the location of and description of
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evidence in this case.
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A defendant is not required to demonstrate what the informant has perceived nor
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11 what he will testify concerning such perception; he need only demonstrate that the
12 informant was in a position to perceive either the commission or the immediate
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antecedents of the alleged crime. (People v. Williams (1958) 51 Cal. 2d 355, 359;
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People v. Perez (1965) 62 Cal. 2d 769, 733; Honore v. SuDerior Court (1969) 70 Cal.
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2d 162, 168-1 69; People v. Biouin (1976) 80 Cal. App. 2d 269, 287-88; People v. Lynn
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17 (1969) 271 Cal. App. 2d 670, 673. See People v. lnQram (1978) 85 Cal. App. 3d 744;
18 People v. Coleman (1977) 72 Cal. App. 3d 287; (Informant held to be percipient
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witness as to possession between co-defendants); and People v. Lee (1985) Cal. App.
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3d 830-35-36. See People v. Borunda (1974)11 Cal. 3d 523, 527 (the informant could
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22 testify that the balloon of heroin which was delivered to the officer after visiting
23 defendant’s apartment was green rather than red as the officer claimed); People v.
24 McShann (1958) 50 CaI.2d 602, 808 (testimony of an eyewitness non-participant
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informer that would vindicate the innocence of the accused or lessen the risk of false
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testimony would obviously be relevant and helpful to the defense and essential to a
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28 fair determination of the cause (narcotics sale count) or the informer might have
29 testified that no telephone call was made, that it was not defendant who received the

1 call, that someone else was called, or that there was entrapment (possession count));
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People v. Williams (1958) 51 Cal.2d 255, 359-60 (eyewitness could controvert officer’s
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testimony that the defendant was the seller of the narcotics); People v. Frohner (1976)
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5 65 Cal. App. 3d 94, 1 04-106; (informant could testify to defendant’s theory of
6 entrapment); PeoPle v. Kiihoa, (1960) 53 Cal.2d 748, 751 (informer’s testimony could
7 reflect on officer’s testimony).)
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Particularly apposite to the instant case is the statement of our Supreme Court
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in Peoole v. Hunt, supra, 4 Cal.3d at 240, where the court noted “in Garcia (67 Cal.2d
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11 830) we could only speculate that he had such information. “ Yet in Garcia, the court
12 held that the informant’s testimony was material and disclosure was required.
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Accordingly, the identities of the informants in this case must also be disclose
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UNDER THE UNITED STATES CONSTITUTION AN INFORMANT’S
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17 IDENTITYMUST BE DISCLOSED WHEN HIS TESTIMONY MAY BE
18 RELEVANT AND HELPFUL TO THE DEFENSE
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The leading federal case on disclosure of informant’s identity provides that
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whenever the informant’s testimony may be relevant and helpful to the accused’s
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22 defense, his identity must be revealed. (Rovario v. United States (1957) 353 U.S. 53,
23 77 S. Ct. 623, 1 L.Ed.2d 639) The general standard for disclosure was set forth in
24 Rovarlo v. United States, supra, 353 U.S. at p. 60-61, as follows:
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‘Where the disclosure of the informant’s identity or the contents of his
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communications is relevant and helpful to the defense of the accused, or is essential
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28 to the fair determination of the cause, the privilege must be waived. In •these
29 situations, the trial court may require disclosure and if the government withholds the

1 information, dismissed the action.”
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The Rovario Court continued, “th[at} while there is no fixed rule with respect to
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disclosure, four considerations are relevant. These are (1) “The crime charged, “(2)
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5 “The possible defenses, “(3) “The possible significance of the informant’s testimony,
6 and (4) “Other relevant factors.” The “relevant and helpful” language of Rovario has been
7 interpreted by the Ninth Circuit to require disclosure of the identity of an informant when
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he is a percipient witness.
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Thus, in United stated v. Cervantes (9th Cir. 1976) 542 F.2d 773, 775 (en banc),
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11 the court stated: “The government acknowledges that the informant DUQUE was a
12 percipient witness to the transaction. It therefore supplied Cervantes with the informant’s
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identity. See Rovario v. United States...”
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The court in Cervantes, therefore, recognized that a “percipient witness” must
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be disclosed. The same result was reached in United States v. Hemandez (9th Cir.
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17 1979) 608 F.2d 741, 744-45: in light of [the informant’s] rote in the narcotics transaction
18 with which appellants were charged, it cannot be said that disclosure of Smith’s identity
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would not have been ‘relevant or helpful’ to the appellant’s defense... Because [the
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informant] was a participant in the events that were critical to the prosecution’s case, no
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22 claim could be raised under Rovario, nor was it raised, that [the informant’s] identity
23 could be lawfully withheld from the appellants. “(Citation omitted.) See also United
24 States V. Maramon (9th Cir. 1971) 443 F.2d 361, 362.
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The law is also clear that where an informant’s testimony is essential to a fair
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determination, the prosecution may be required to disclose his identity and address, if
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28 any. (United States v. Roberts(2d Cir. 1968) 338 F.2d 646. galso, United States v.
29 Anderson (9th Cir. 1975) 509 F.2d 724 (within the Court’s discretion to compel

1 disclosure even when use of the informant goes only to probable cause).)
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Further, the defense is entitled to a revelation of the informants’ whereabouts
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and addresses prior to trial so that sufficient investigation into his background can be
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5 made.
6 ‘We recognize that the address of the principle witness, as Ithe informant] most
7 assuredly was, is an integral element of the identity for without such information, little
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meaningful inquiry can be made into the background information affecting credibility.
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(United States v. Hernandez, supra, 608 F.2d at 745.)
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11 Any assertion that there is some unspecified danger to the informant is
12 insufficient to justify withholding information concerning his whereabouts. As
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Hernandez makes clear, the decision concerning potential “danger’ must be made
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only after an evidentiary hearing. (Hernandez, supra 608 F.2d at the 745 & fn. 3.)
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Finally, the prosecutor’s obligation is not fully satisfied by disclosing the identity
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17 and location of the informants.
18 The defense here specifically requests that theinformants be produced on the g
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rounds that his or her testimony is essential to a fair determination at trial. The prosecutor
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has an obligation to accomplish this or show that, despite reasonable efforts, it was not
21
th
22 able to do so. (United States v. Hart (9 Cir. 1976) 546 F.2d 798,799, (en banc); See also
23 United States V. Cervantes, supra; Velarde-VilIa Real v. United States (9th Cir. 1965) 354.
24 F.2d 9.)
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III.
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CONCLUSION
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28 For the reasons cited above, it is respectfully submitted that the identity of each
29 informant be disclosed and the requested discovery provided.

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DATED: ____________________
3 Julius Johnson
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DECLARATION OF JULIUS JOHNSON IN SUPPORT OF DISCLOSING
IDENTITY OF THE CONFIDENTIAL OINFOPRMANT(S)
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I, Julius Johnson, declare and say as follows:
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1. I am an attorney at law duly licensed to practice before all the courts in
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1 the State of California, and I am the attorney for defendant MIGUEL HURTADO, herein.
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2. I am informed and believe that investigation of the charges alleged
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against defendant have been made by officers or agents of the District Attorney of the
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5 county Los Angeles and law enforcement agencies which are mentioned in the
6 defendant’s motion for discovery and disclosure of the informant’s identity attached to
7 hereto.
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3. I am informed and believe that some or all said officers or agencies have
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in their possession, or under their control, some or all of said the information and
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11 materials described in said motion, or they can obtain some of or all of said information
12 and material by communication with other agencies within the criminal justice system.
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4. It is necessary that such information and material be made available to
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defendant’s attorney in order that he may properly prepare said case.
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5. That the information and material requested is material and relevant to
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17 this action and that some of said information is solely under the control of the People
18 and is not known by or otherwise readily available to defendant or his counsel.
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6. That defendant’s case will be fatally prejudiced absent an order by this
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court to reveal the identity of the informants herein.
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22 7. It is counsel’s belief that testimony from the informants in this case will
23 reveal (1) bias and prejudice on the part of the informants utilized herein; (2) that the
24 informant’s participation and knowledge herein exceeds that information which has
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been revealed through the investigating officers; and further (3) that the additional
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knowledge held by the informants herein will serve to exonerate defendant ________ of
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28 the crimes alleged herein. And finally, (4) that the information held by the informants
29 herein was gained as a result of the informant’s being percipient witnesses or

1 participants to the crimes alleged.
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I declare under penalty per jury that the foregoing is true and correct.
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DATED: ____________________
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Julius Johnson
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DECLARATION OF MAILING
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I, the undersigned, declare:
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I am over the age of 18 years and not a party to the above-entitled matter. My
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6 business address is _______________________________________________________.
7 On the date given below, I served the within NOTICE OF MOTION TO VACATE
8 PLEA OF GUILTY; MEMORANDUM OF POINTS AND AUTHORITIES; EXHIBITS

9 IN SUPPORT in this matter on each of the parties indicated herein in said action by
10 placing a true copy thereof enclosed in a sealed envelope with postage thereon fully
11 prepaid, in the United States Mail in Pasadena, California, addressed as follows:
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I declare under penalty of perjury that the foregoing is true and correct, and that
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this declaration was executed on October ___, 2014, at PASADENA, California.
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________________________
22 Declarant
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JULIUS JOHNSON
4 LAW OFFICES OF JULIUS JOHNSON
5 2476 North Lake Avenue
Altadena, CA 91001
6 Telephone: (626) 622-2434

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UNIFIED COURTS OF THE STATE OF CALIFORNIA,
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COUNTY OF LOS ANGELES, CENTRAL JUDICIAL DISTRICT
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PEOPLE OF THE STATE OF CALIFORNIA, ) Case No. _
12 )
Plaintiff, ) ________
13 ) ORDER ON MOTION TO DISCLOSE
vs. ) IDENTITY OF INFORMANT
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MIGUEL HURTADO, )
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Defendant. )
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TO THE PEOPLE OF THE STATE OF CALIFORNIA AND THEIR
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23 ATTORNEYS HEREIN, AND TO THE LOS ANGLES CITY POLICE DEPARTMENT:
24 PLEASE TAKE NOTICE THAT this court orders the following items listed in the
25 attached “Requested Disclosure and Discovery” be revealed to the attorney for MIGUEL
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HURTADO herein as soon as reasonably practicable, but in no case later than two weeks
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subsequent to this order absent further court order.
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29 Such is the order of this court.

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DATED:
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Judge of the Superior Court
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Qqreveal Informant Confidential NXT 2final

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1 JULIUS JOHNSON

NOTICE OF MOTION AND MOTION TO DISCLOSE IDENTITY OF INFORMANT; MEMORANDUM OF

NOTICE OF MOTION AND MOTION TO DISCLOSE IDENTITY OF INFORMANT; MEMORANDUM OF

29 not lead to the arrest(s), “street gang” infiltration or seizure(s);

NOTICE OF MOTION AND MOTION TO DISCLOSE IDENTITY OF INFORMANT; MEMORANDUM OF

23 not prosecute, or not to refer for filing against the informants;

29 based upon information from the informant in the instant matter;

NOTICE OF MOTION AND MOTION TO DISCLOSE IDENTITY OF INFORMANT; MEMORANDUM OF

NOTICE OF MOTION AND MOTION TO DISCLOSE IDENTITY OF INFORMANT; MEMORANDUM OF

6 that reveal the informant’s identity.

NOTICE OF MOTION AND MOTION TO DISCLOSE IDENTITY OF INFORMANT; MEMORANDUM OF

NOTICE OF MOTION AND MOTION TO DISCLOSE IDENTITY OF INFORMANT; MEMORANDUM OF

23 knowledge of the presence of a narcotic... “(Citation.) “(P)roof of the opportunity of

29 discovered by the police and where such discovery stems in whole or

NOTICE OF MOTION AND MOTION TO DISCLOSE IDENTITY OF INFORMANT; MEMORANDUM OF

NOTICE OF MOTION AND MOTION TO DISCLOSE IDENTITY OF INFORMANT; MEMORANDUM OF

23 Court, supra; People v. Borunda, supra; Williams v. Superior Court, supra.)

NOTICE OF MOTION AND MOTION TO DISCLOSE IDENTITY OF INFORMANT; MEMORANDUM OF

23 parallel in nature, defendant HURTADO is charged with being in possession of a firearm

NOTICE OF MOTION AND MOTION TO DISCLOSE IDENTITY OF INFORMANT; MEMORANDUM OF

NOTICE OF MOTION AND MOTION TO DISCLOSE IDENTITY OF INFORMANT; MEMORANDUM OF

NOTICE OF MOTION AND MOTION TO DISCLOSE IDENTITY OF INFORMANT; MEMORANDUM OF

NOTICE OF MOTION AND MOTION TO DISCLOSE IDENTITY OF INFORMANT; MEMORANDUM OF

29 informant be disclosed and the requested discovery provided.

NOTICE OF MOTION AND MOTION TO DISCLOSE IDENTITY OF INFORMANT; MEMORANDUM OF

NOTICE OF MOTION AND MOTION TO DISCLOSE IDENTITY OF INFORMANT; MEMORANDUM OF

29 herein was gained as a result of the informant’s being percipient witnesses or

NOTICE OF MOTION AND MOTION TO DISCLOSE IDENTITY OF INFORMANT; MEMORANDUM OF

NOTICE OF MOTION AND MOTION TO DISCLOSE IDENTITY OF INFORMANT; MEMORANDUM OF

8 PLEA OF GUILTY; MEMORANDUM OF POINTS AND AUTHORITIES; EXHIBITS

NOTICE OF MOTION AND MOTION TO DISCLOSE IDENTITY OF INFORMANT; MEMORANDUM OF

7 Attorney for Defendant

NOTICE OF MOTION AND MOTION TO DISCLOSE IDENTITY OF INFORMANT; MEMORANDUM OF

NOTICE OF MOTION AND MOTION TO DISCLOSE IDENTITY OF INFORMANT; MEMORANDUM OF

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