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p0356 REVIEW DENIED Placement of written memoranda in the personnel files of police officers for consideration in future performance reviews is at such a low level of discipline that due process does not require the officers be given an opportunity to cross examine witnesses at an administrative evidentiary hearing held in connection with their challenge to the inclusion of those memoranda in their files.CitationJAMES v CITY OF CORONADO (Cross Examination) 106 CA4 905 [See: GovC 3300 etseq; Otto v LA USD 89 CA4 985, P/AT 3/03]
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