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   State Courts - California - April 22, 2008
  
Zanone v. City of Whittier, B189567, COURT OF APPEAL OF CALIFORNIA, SECOND APPELLATE DISTRICT, DIVISION SEVEN, April 22, 2008, Filed
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Overview: Former police officer's failure to file a Pitchess motion seeking disclosure of a memorandum written by chief of police did not preclude officer's use of it to impeach chief's testimony because memorandum did not fall within Pen. Code, ? 832.8's definition of "personnel records," even if it could have been found in another officer's personnel file.

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