56 KC Mx Protective Order

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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.

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

Document 56

Filed 10/12/2007

Page 1 of 2

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Mark A. Wasser CA SB #060160 LAW OFFICES OF MARK A. WASSER 400 Capitol Mall, Suite 1100 Sacramento, CA 95814 Phone: (916) 444-6400 Fax: (916) 444-6405 E-mail: mwasserlaimarkwasser.com Bernard C. Barmann, Sr. KERN COUNTY COUNSEL Mark Nations, Chief Deputy 1115 Truxton Avenue. Fourth Floor Bakersfield, CA 93301 Phone: (661) 868-3800 Fax: (661) 868-3805 E-maii: mnations@co.kern.ca.us

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Attorneys for Defendants County of Kem, Peter Bryan, Irwin Harris, Eugene Kercher, 11 IJennifer Abraham, Scott Ragland, Toni Smith 'and Rov 12

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

DAVID F. JADWIN, D.O. Plaintiff,

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Case No.: 1:07-cv-00026-0WW-TAG DEFENDANTS' NOTICE OF MOTION AND MOTION FOR A PROTECTIVE ORDER RE: EMPLOYEES' HOME ADDRESSES

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VS.

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COUNTY OF KERN, et Defendants.

Date: November 5, 2007 ) Time: 9:30 a.m. (date cleared by CRD) ) Place: U.S. Bankruptcy Courthouse, ) Bakersfield Courtroom 8
) Trial Date: August 26, 2008

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Date Action Filed: January 6, 2007

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TO PLAINTIFF AND HIS ATTORNEY OF RECORD: PLEASE TAKE NOTICE that, on November 5, 2007 at 9:30 a.m. or as soon thereafter as the matter can be heard in the courtroom of the above-referenced Court at 1300 18 Street, Bakersfield, Califomia, Defendants will, and hereby do, move the Court for a protective order
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DEFENDANTS' MOTION FOR PROTECTIVE ORDE RE: EMPLOYEES' HOME ADDRESSE

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Case 1:07-cv-00026-OWW-TAG
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Document 56

Filed 10/12/2007

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protecting Defendants' and Defendants' employees' home addresses from disclosure or discovery, The motion will be made on the grounds that disclosure or discovery of employee home addresses is unnecessary because Defendants have disclosed to Plaintiff full and complete individual addresses and telephone numbers for all employees who have been identified as potential witnesses and disclosure or discovery of home addresses would be prejudicial to Defendants and Defendants' employees, The motion will be based on this notice and motion, the memorandum of points and authorities and supporting declarations filed herewith and on hereafter submitted to the Court. Respectfully submitted, other materjials as be

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Datc,d: October 12,
lVlnlU,"

A WASSER

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DEFENDANTS' MOTION FOR PROTECTIVE ORDE RE: EMPLOYEES' HOME ADDRESSE
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By:_-,I-"s,-IMo=a",rk"'-'.cA,,-,-,W-,-a",s",s~er,--

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Mark A. Wasser Attorney for Defendants, County of Kern, et al.

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