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PROTECTIVE ORDER 

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BRUCE A. KILDAY, ESQ., SBN. 66415 (SPACE BELOW FOR FILING STAMP ONLY)

SUSAN A. DENARDO, ESQ., SBN. 235166 

ANGELO, KILDAY & KILDUFF 

Attorneys at Law 

601 University Avenue, Suite 150 

Sacramento, CA 95825 

Telephone: (916) 564-6100 

Telecopier: (916) 564-6263 

Attorneys for Defendants 

CITY OF DIXON, MAYOR MARY ANN COURVILLE, 

VICE-MAYOR GIL VEGA, COUNCILMAN LOREN FERRERO, 

COUNCILWOMAN JILL DISNEY ORR, CITY MANAGER 

WARREN SALMONS, DIXON POLICE DEPARTMENT, 

POLICE CHIEF DON MORT AND POLICE CAPTAIN LOU KALISH 

UNITED STATES DISTRICT COURT 

EASTERN DISTRICT OF CALIFORNIA 

MICHAEL CEREMELLO, 

 Plaintiff, 

 vs. 

CITY OF DIXON, et al., 

 Defendants. 

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Case No.: CIV S-04-1423 DFL EFB 

PROTECTIVE ORDER 

The parties, through their respective counsel, hereby agree to the following protective 

order: 

1. Whereas the City of Dixon has agreed to produce a copy of written reports and tapes 

(if available) of an internal investigation conducted by Sgt. Lance Thelen of a citizen’s 

complaint, and these reports are numbered P.83 to P.283; 

2. Whereas the confidential investigation by Sgt. Thelen was prepared at the request of, 

and submitted to, City Manager Warren Salmons on June 6, 2003; 

3. Whereas the investigation into a citizen’s complaint is confidential pursuant to 

California Penal Code § 832.7, 

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Case 2:04-cv-01423-JAM-EFB Document 63 Filed 10/18/06 Page 1 of 3
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PROTECTIVE ORDER 

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The parties hereby agree: 

1. Plaintiff Michael Ceremello and his attorney will not duplicate the investigation or 

any portion thereof, with the sole exception of copies for use in an official submission to the 

court; 

2. The documents will not be disclosed to any person, other than plaintiff Michael 

Ceremello and his attorney. The parties specifically agree that the documents, and their contents, 

will not be disclosed in any manner to any other persons, including John Grahl, Byron Chapman, 

and Roberta Lee. 

3. Plaintiff Michael Ceremello and his attorney will use the documents exclusively in 

connection with the litigation of Ceremello v. City of Dixon, et al., Civ. S 04-1423 DFL EJB. 

4. Plaintiff Michael Ceremello and his attorney agree to return all documents and tape 

recordings to counsel for the City of Dixon at the conclusion of said litigation. 

Dated: ______________________ /s/ William C. Collier 

 By:____________________________ 

 WILLIAM C. COLLIER 

 Attorneys for Plaintiff 

MICHAEL CEREMELLO 

 Dated: October 11, 2006 ANGELO, KILDAY & KILDUFF 

 

/s/ Bruce A. Kilday 

By:_________________________________ 

 BRUCE A. KILDAY 

Attorneys for Defendants 

CITY OF DIXON, MAYOR MARY 

ANN COURVILLE, VICE-MAYOR 

GIL VEGA, COUNCILMAN LOREN 

FERRERO, COUNCILWOMAN JILL 

DISNEY ORR, CITY MANAGER 

WARREN SALMONS, DIXON 

POLICE DEPARTMENT, POLICE 

CHIEF DON MORT AND POLICE 

CAPTAIN LOU KALISH 

Case 2:04-cv-01423-JAM-EFB Document 63 Filed 10/18/06 Page 2 of 3
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PROTECTIVE ORDER 

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ORDER

The above stipulation is approved and so ordered. However, paragraph 2 regarding 

disclosure is subject to subsequent orders the court might enter should any documents, tapes or 

other information from the investigation files be offered into evidence in this case. A party 

offering such evidence shall provide 10 days advance notice to the opposing party to enable that 

party the opportunity to seek a further protective order. 

Dated: October 18, 2006 

 EDMUND F. BRENNAN 

UNITED STATES MAGISTRATE JUDGE 

 

 

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