Ihab Karam v. John W. Hately, et al.

where officers had engaged in secondary employment at least four years ago "would increase the threat to officer safety presented by those with a generalized hostility toward law enforcement officers." (Id. at 303.)

By contrast, by virtue of the regulation of secondary employment under Penal Code Sec. 70, it is clear the public has an interest in learning about secondary employment of peace officers. The public has an interest in determining whether secondary employment contributes to fatigue of officers and interferes with the performance of their duties. The public may also be interested in knowing whether outside employment poses a conflict of interest.

Absent any particularized and concrete safety or privacy concern posed by the disclosure of the particular information that petitioner has conceded as warranting redaction, e.g., medical information, officer personal contact information, insurance information, etc. (see Reply at 1, 6), the public's interest in information concerning secondary employment by LAPD officers outweighs any general interest by the City and the officers in nondisclosure.

III. CONCLUSION

For the foregoing reasons, City having failed to demonstrate the application of any exemption, the Court finds that disclosure of denied applications and resulting appeals, as well as location information found in the records at issue, is warranted. The petition is GRANTED. Pursuant to Local Rule 3.231(n), petitioner shall prepare, serve, and ultimately file a proposed judgment and proposed writ of mandate in accordance herewith.

[1] As represented by City, records of film-location audits for 2019 have not been found. (Tu Decl. P. 14.)

[2] The Court likewise rejects City's claim that the privacy exemption and catch-all exemption in Government Code sections 7927.700 and 7922.000 apply to all denials and appeals therefrom because such records purportedly involve personnel material or negative evaluative determinations. (Opp. at 15:21-25.) Such records do not invariably contain protected information such that they are automatically given wholesale protection from disclosure irrespective of their actual content. Rather, as recognized by petitioner, certain denials or appeals based on officer-specific, protected information such as "[m]edical history" and "[c]omplaints, or investigations of complaints" (see Penal Code Sec. 832.8(a)(2), (5)), would warrant redaction of such particular information. (Reply at 9:2-11.)

[3] Ultimately, the City's argument meanders into the assertion that an officer's home address is not disclosable. (Opp. at 10:25-11:5.) While it is hard to quarrel with that assertion, petitioner is not requesting any such information.

RE: PRELIMINARY INJUNCTION Date: 8/25/26 (1:30 PM)

Case: Ihab Karam v. John W. Hately, et al. (26STCV23936)

TENTATIVE RULING: On 8/3/26, the Court issued an Order to Show Cause to defendant Wayne S. Bowman as to why Bowman should not be enjoined from interfering with plaintiff's access to his property via White Fox Lane and Castlehaven Road to Agua Dulce Canyon Road. That same date, the Court also issued a Temporary Restraining Order to enjoin Bowman from that same conduct pending the hearing on the Order to Show Cause. Plaintiff was ordered to serve defendant Bowman with the summons and complaint, moving papers for the requested preliminary injunction, and the OSC and TRO by 8/7/26. The Court also set a briefing schedule and scheduled the hearing for the OSC for 8/25/26.

There is no filed proof of service of any of the foregoing upon defendant Bowman. Accordingly, pursuant to CCP 527(d)(3), the temporary restraining order is hereby dissolved. Further, the Court hereby discharges its Order to Show Cause.

The Court notes the filing of a "Stipulation to Continue Hearing on Preliminary Injunction Scheduled for August 25, 2026 at 1:30 PM for Approximately 60 Day," but such stipulation is by and between plaintiff and the Murray Trust defendants, who are not subject to the OSC. The Court therefore disregards such stipulation. | Home -->)" -->