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78 Stipulation - Extend Deadlines

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

Document 78

Filed 11/15/2007

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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: mwasser@markwasseLcom

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Bernard C. Barman, Sr. KERN COUNTY COUNSEL 6 Mark Nations, Chief Deputy 1115 Truxtun Avenue, Fourth Floor 7 Bakersfield. CA 93301 Phone: (661) 868-3800 8 I, Fax: (661) 868-3805 E-mail: mnations@co.kern.ca.us 9 Attorneys for Defendants County of Kern, Peter Bryan, Irwin Harris, Eugene Kercher, ~ Jennifer Abraham, Scott Ragland, Toni Smith and William Roy

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LEE 12 13 14 15 16 17 18 19 20 21 22 23
DAVID F. JADWIN, D.O.

555West Street, Los Angeles, CA 90013 Phone: (213) 992-3299 Fax: (213) 596-0487 E-mail: elee@LOEL.com Joan Herrington SB# 178988 BAY AREA EMPLOYMENT LAW OFFICE 5032 Woodminister Lane Oakland, CA 94602 Phone: (510) 530-4078 Fax: (510) 530-4725 E-mail: jh(a)baelo.com Of Counsef to LAW OFFICE OF EUGENE Attorneys for PlaintitI DAVID F. JADWIN, D.O.
UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA
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Case No.: I :07-cv-00026 OWW TAG
STIPULATION TO CONTINUE TRIAL AND PRE-TRIAL DATES AND ORDER

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Plaintiff,

COUNTY OF KERN, et aI.,

Complaint Filed: January 5, 2007 Trial Date: August 26, 2008

Defendants.

STIPULATION TO CONTlNUE TRIAL AND PRE-TRIAL DATES AND ORDER

Case 1:07-cv-00026-OWW-TAG
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Document 78

Filed 11/15/2007

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WHEREAS discovery is taking substantially longer than the parties anticipated because the collection, duplication, redaction and production of medical records and other documents within Kern Medical Center in response to Plaintiff s request for the production of documents is taking considerable time; and WHEREAS the parties are working together in good faith to address discovery issues as they arise; and WHEREAS it has become evident that the partios' planned discovery will not be

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current "rm;;prv cut-ott; and WHEREAS the parties believe the discovery cut-off should be extended approximately months and that trial other pre-trial dates should be eontinued accordingly; HEREB Y by and conference,
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settlement conference, thel
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through

deadline for filing dispositive and non-dispositive motions, the expert and supplemental expert disclosure deadlines, and the discovery cut-off should all be extended approximately three months.

Dated: November 15, 2007

LAW OFFICES OF MARK A. WASSER

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19 20 21 22 Dated: November 15,2007 LAW OFFICE OF EUGENE LEE Mark A. Wasser Attorney for Defendants, County of Kern, et al.

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24 25 By:_.-i!-",s!-,E",u""",e",n",e"",D"",.,-,L""e""e,-,-"a,,-s",a""ut",h",o""ri",z",ed"-"o,,,n"",1-'.1",!l",5cc:!0""7'-'--_-1 Eugene D. Lee Attorney for Plaintiff, David F. Jadwin, D.O.

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STIPULATION TO CONTINUE TRIAL AND PRE-TRIAL DATES AND ORDER

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

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Filed 11/15/2007

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ORDER
The parties having stipulated as hereinabove set forth and good cause appearing therefor; IT IS HEREBY ORDERED, that the scheduling conference order be amended and that the dates of trial, pre-trial conference, settlement conference, dispositive motion cut-off, nondispositive motion cut-off and discovery be vacated and that new dates be set as follows: Expert Disclosure: Supplemental Expert Disclosure: Discovery Cut-Off: Non-Dispositive Motion Cut-Off: Dispositive Motion Cut-Off: Dispositive Motion Hearing: Settlement Conference: Pre-Tria] Confererlce: [May 5, 2008] [June 4, 2008] [July 7, 2008] [July 21, 2008] [August 20081 [August 2008] [September 8, 20081 [May 7, 2008] [October I 2008] [December 3,

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Dated: November _ , 2007 UNITED STATES DISTRICT COURT By: _ The Honorable Oliver W. Wanger United States Distriet Judge

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STIPULATION TO CONTINUE TRIAL AND PRE-TRIAL DATES AND ORDER


				
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.