County of Los Angeles v. Superior Court

This proceeding arises from a discovery dispute in which respondent court granted petitioners’ motion to compel production of documents listed in a third party deposition subpoena (Code Civ. Proc., § 2020, subd. (d)(1)) directed to the District Attorney of Los Angeles County. The district attorney had conducted an investigation into whether the Los Angeles Board of Supervisors (Board) violated the Ralph M. Brown Act (Gov. Code, § 54950 et seq.) (Brown Act), California’s open meeting law, during two closed sessions in September 2004. Respondent court ordered the district attorney to produce redacted copies of the closed session minutes as well as two letters from the district attorney’s investigation file. The documents are not discoverable because closed session minutes are specifically exempt from disclosure by Government Code section 54957.2, and the letters are exempt from disclosure under Government Code sections 6254, subdivision (f) and 6254.5, subdivision (e). We therefore hold that respondent court erred when it granted petitioners’ discovery motion.

FACTS AND PROCEDURAL HISTORY

In 2003, the Martin Luther King, Jr./Drew Medical Center (King/Drew) was under…