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[PROPOSED] ORDER GRANTING PLAINTIFF’S MOTION TO COMPEL PRODUCTION OF DOCUMENTS 

FROM THE CONTRA COSTA COUNTY OFFICE OF THE SHERIFF-CORONER 

CASE NO. C-05-1858-MHP (PR) 434088.02 434236.01 

KEKER & VAN NEST, LLP 

ASHOK RAMANI - #200020 

BROOK DOOLEY - #230423 

JENNIFER A. HUBER - #250143 

710 Sansome Street 

San Francisco, CA 94111-1704 

Telephone: (415) 391-5400 

Facsimile: (415) 397-7188 

Attorneys for Plaintiff 

ZAMEER RIAZ AZAM 

UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF CALIFORNIA 

SAN FRANCISCO DIVISION 

ZAMEER RIAZ AZAM, 

Plaintiff, 

v. 

OFFICER M. JOHNSON, 

Defendant. 

 

Case No. C-05-1858-MHP (PR) 

[PROPOSED] ORDER GRANTING 

PLAINTIFF’S MOTION TO COMPEL 

PRODUCTION OF DOCUMENTS FROM 

THE CONTRA COSTA COUNTY 

OFFICE OF THE SHERIFF-CORONER 

Date: January 12, 2009 

Time: 2:00 p.m. 

Dept: Courtroom 15, 18th Floor 

Judge: Hon. Marilyn Hall Patel 

Trial Date: February 17, 2009 

Case 3:05-cv-01858-MHP Document 58 Filed 01/16/09 Page 1 of 2
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[PROPOSED] ORDER GRANTING PLAINTIFF’S MOTION TO COMPEL PRODUCTION OF DOCUMENTS 

FROM THE CONTRA COSTA COUNTY OFFICE OF THE SHERIFF-CORONER 

CASE NO. C-05-1858-MHP (PR) 434088.02 434236.01 

This matter came before the Court on Plaintiff Zameer Riaz Azam’s Motion to Compel 

Production of Documents from Contra Costa County Office of the Sheriff-Coroner. Having 

considered the papers, the declarations on file, the arguments of counsel, and the case record, the 

Court hereby ORDERS as follows: 

Pursuant to the Stipulated Protective Order filed November 19, 2008, the Contra Costa 

Office of the Sheriff-Coroner (“Sheriff”) is ordered to produce any and all records pertaining to 

complaints or issues of the credibility of Defendant Officer Mark Johnson, and Officers Martin 

Echelmeier and Allen Molien, including Internal Affairs records, personnel files, and testimony, 

going back not to exceed five years from October 29, 2003 and going forward from October 29, 

2003, to the present date. The term “credibility” is to be interpreted broadly. Where questions 

arise as to whether documents should be produced, the Sheriff will produce them. 

The Sheriff is further ordered to produce any and all records concerning Defendant 

Officer Mark Johnson pertaining to complaints or issues regarding his treatment of persons taken 

into custody, lawfulness of detentions or arrests, and protective orders or violations of protective 

orders, including Internal Affairs records and personnel files. The Sheriff shall produce all such 

records concerning Officer Johnson going back not to exceed five years from October 29, 2003, 

and going forward to the present date. 

The documents identified herein shall be produced on an Attorneys’ Eyes Only basis and 

shall governed by the November 19, 2008 Protective Order in this matter. Plaintiff’s counsel 

may further disclose these documents only to a single retained investigator subject to the 

Protective Order in this matter. 

Dated: January ___, 2009 

______________________________________

HON. MARILYN HALL PATEL 

UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF 

CALIFORNIA 

15

U

NITED STATES DISTRICT COURT

NORTHERN DISTRICT OF CALIFORNIA

IT IS SO ORDERED

Judge Marilyn H. Patel

Case 3:05-cv-01858-MHP Document 58 Filed 01/16/09 Page 2 of 2