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80 Order Extending Deadlines SIGNED

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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 80

Filed 11/20/2007

Page 1 of 3

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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@markwasser.com Bernard C. Barman, Sr. KERN COUNTY COUNSEL Mark Nations, Chief Deputy 1115 Truxtun Avenue, Fourth Floor Bakersfield, CA 93301 Phone: (661) 868-3800 Fax: (661) 868-3805 E-mail: mnations@co.kern.ca.us Attorneys for Defendants County of Kern, Peter Bryan, Irwin Harris, Eugene Kercher, Jennifer Abraham, Scott Ragland, Toni Smith and William Roy Eugene D. Lee SB# 236812 LAW OFFICES OF EUGENE LEE 555West Fifth Street, Suite 3100 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@baelo.com Of Counsel to LAW OFFICE OF EUGENE LEE Attorneys for Plaintiff DAVID F. JADWIN, D.O. UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA DAVID F. JADWIN, D.O. Plaintiff, vs. COUNTY OF KERN, et al., Defendants. ) ) ) ) ) ) ) ) ) ) 1
STIPULATION TO CONTINUE TRIAL AND PRE-TRIAL DATES AND ORDER

Case No.: 1:07-cv-00026 OWW TAG STIPULATION TO CONTINUE TRIAL AND PRE-TRIAL DATES AND ORDER Complaint Filed: January 5, 2007 Trial Date: August 26, 2008 Note: Dates on last page have been changed

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

Document 80

Filed 11/20/2007

Page 2 of 3

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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 parties’ planned discovery will not be completed by the current discovery cut-off; and WHEREAS the parties believe the discovery cut-off should be extended approximately three months and that trial and the other pre-trial dates should be continued accordingly; NOW THEREFORE IT IS HEREBY STIPULATED, by and between the parties hereto through their respective counsel, that trial, the pre-trial conference, the settlement conference, the 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

By:

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

Dated: November 15, 2007

LAW OFFICE OF EUGENE LEE

By:

/s/ Eugene D. Lee (as authorized on 11/15/07) 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

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

Document 80

Filed 11/20/2007

Page 3 of 3

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Dated: November 17 , 2007

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: Non-Dispositive Motion Hearing: Dispositive Motion Cut-Off: Dispositive Motion Hearing: Settlement Conference: Pre-Trial Conference: Trial : [May 5, 2008] [June 4, 2008] [July 7, 2008] [July 21, 2008] [August 22, 2008] [August 4, 2008] [September 8, 2008] [May 7, 2008] [October 14, 2008] [December 3, 2008]

No further continuances will be granted (oww)

UNITED STATES DISTRICT COURT By:/s/ OLIVER W. WANGER The Honorable Oliver W. Wanger United States District Judge

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STIPULATION TO CONTINUE TRIAL AND PRE-TRIAL DATES AND ORDER

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