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                          have a right to be free of adverse publicity. There was no inva-
                          sion of privacy where the facts at issue are already known.
                          Sipper v. Chronicle Publishing, 154 Cal.App.3d 1040, 1047, 201
                          Cal.Rptr. 665 (1984).
                          The Time Mirror further stated that in order to state an in-
                          vasion of privacy claim, it must also be proven that the facts
                          revealed were so offensive as to shock the community's no-
                          tion of decency. Briscoe v. Reader's Digest Assn. Inc., 4 Cal.3d
                          529, 541, 93 Cal.Rptr. 866 (1971).

                                  The People's (Garcetti and Sneddon) Response to
                          Defendant's Motion for Protective Order
                                  Gil Garcetti and Thomas Sneddon, the District Attorneys
                          from Los Angeles and Santa Barbara, jointly filed a response
                          to Mr. Cochran's motion for protective order. They wanted to
                          assure the Court that the progress of the child molestation in-
                          vestigation of Michael Jackson was not connected to, or dic-
                          tated by, the discovery process in the civil case. They stated
                          that they had no intention to slow or delay their investigation
                          for the purpose of obtaining information derived during the
                          Civil Discovery. They also confirmed that they had no inten-
                          tion to disclose any information they obtained during the
                          course of their investigation to anyone who was not in the law
                          enforcement agency.
                                   However, they felt strongly that they were entitled to ob-
                          tain all depositions, statements, and any documentary or de-
                          rivative information from any witness who had evidence re-
                          lating to their criminal investigation. Therefore, they required
                          access to all Civil Discovery because serious injuries deserve
                          to be fully investigated. Their position was that the law en-
                          forcement agency should not be precluded or restricted from
                          gathering any information which pertains to investigation
                          which is not privileged. They also addressed the fact that three
                          days before filing their papers, Michael Jackson's attorneys re-
                          quested an opportunity to present evidence which might im-
                          pact their filing decision. They stated, "how can they now ar-
                          gue fundamental fairness?" With boldness, they contended that






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