36 MTS - Request for Judicial Notice

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					Case 1:07-cv-00026-OWW-TAG

Document 36

Filed 07/11/2007

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Eugene D. Lee SB# 236812 LAW OFFICE OF EUGENE LEE 555 West Fifth Street, Suite 3100 Los Angeles, California 90013 Telephone: (213) 992-3299 Facsimile: (213) 596-0487 Email: elee@LOEL.com Joan Herrington, SB# 178988 BAY AREA EMPLOYMENT LAW OFFICE 5032 Woodminster Lane Oakland, CA 94602-2614 Telephone: (510) 530-4078 Facsimile: (510) 530-4725 Email: jh@baelo.com Of Counsel to LAW OFFICE OF EUGENE LEE Attorneys for Plaintiff DAVID F. JADWIN, D.O. UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF CALIFORNIA FRESNO DIVISION DAVID F. JADWIN, D.O., Case No. 1:07-cv-00026-OWW-TAG PLAINTIFF’S REQUEST FOR JUDICIAL NOTICE IN SUPPORT OF PLAINTIFF’S MOTION TO STRIKE DEFENDANTS’ FIFTH AFFIRMATIVE DEFENSE AND FOR SANCTIONS [F.R.C.P. RULES 12(f) AND 11(c)]

15 Plaintiff, 16 v. 17 18 19 20 21 22 23 24 TO THE COURT, ALL PARTIES AND THEIR ATTORNEYS OF RECORD, PLEASE TAKE 25 NOTICE that Plaintiff DAVID F. JADWIN requests that the Court take judicial notice of the following 26 facts, pursuant to Federal Rules of Evidence, Rule 201: 27 28 1. The fee of $500 per hour which Joan E. Herrington, co-counsel for Plaintiff, charges for regular services is the customary fee charged for such matters by an attorney of her
PLAINTIFF’S REQUEST FOR JUDICIAL NOTICE IN SUPPORT OF MOTION TO STRIKE AND FOR ATTORNEY FEES

COUNTY OF KERN; et al. Defendants. Date: August 13, 2007 Time: 9:30 a.m. Place: U.S. Bankruptcy Courtroom, Bakersfield Courtroom 8 Date Action Filed: Date Set for Trial: January 6, 2007 August 26, 2008

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Case 1:07-cv-00026-OWW-TAG

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Filed 07/11/2007

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experience, reputation and ability in the Baltimore-Washington area according to the Laffey Matrix, a copy of which is attached to the Declaration of Joan E. Herrington as Exhibit 1. 2. The fee of $400 per hour which Eugene D. Lee, counsel for Plaintiff, charges for regular services is the customary fee charged for such matters by an attorney of his experience, reputation and ability in the Baltimore-Washington area according to the Laffey Matrix, a copy of which is attached to the Declaration of Joan E. Herrington as Exhibit 1.. RESPECTFULLY SUBMITTED on July 11, 2007.

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PLAINTIFF’S REQUEST FOR JUDICIAL NOTICE IN SUPPORT OF MOTION TO STRIKE AND FOR ATTORNEY FEES

/s/ Eugene D. Lee SB# 236812 LAW OFFICE OF EUGENE LEE 555 West Fifth Street, Suite 3100 Los Angeles, California 90013 Telephone: (213) 992-3299 Facsimile: (213) 596-0487 Email: elee@LOEL.com /s/ Joan Herrington, SB# 178988 (as authorized on 7/10/07) BAY AREA EMPLOYMENT LAW OFFICE 5032 Woodminster Lane Oakland, CA 94602-2614 Telephone: (510) 530-4078 Facsimile: (510) 530-4725 Email: jh@baelo.com Of Counsel to LAW OFFICE OF EUGENE LEE Attorneys for Plaintiff DAVID F. JADWIN, D.O.

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DOCUMENT INFO
Description: David F. Jadwin v. Kern County: 1:07-cv-26 in the United Stated District Court for the Eastern District of California, Fresno Division before Judge Oliver W. Wanger. This was a 2009 federal employment lawsuit that went to a bench and jury trial resulting in a unanimous verdict and significant judgment for the plaintiff employee. Issues involved violations of medical leave and disability discrimination laws, as well as 42 U.S.C. 1983 procedural due process violation. Plaintiff was represented by Eugene Lee, a Los Angeles, California employment lawyer.