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

Document 96

Filed 03/24/2008

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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

12 FOR THE EASTERN DISTRICT OF CALIFORNIA 13 14 DAVID F. JADWIN, D.O., 15 Plaintiff, 16 v. 17 18 19 20 21 22 DATE CLEARED WITH CRD 23 24 TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD: 25 PLEASE TAKE NOTICE that on April 14, 2008 at 9:30 a.m., or as soon thereafter as the matter 26 can be heard, Plaintiff DAVID F. JADWIN (Plaintiff) will and hereby does move this Court for an order 27 compelling defendant COUNTY OF KERN (Defendant) to further respond to plaintiff’s interrogatories, 28 COUNTY OF KERN; et al. Defendants. Date: April 14, 2008 Time: 9:30 a.m. Place: U.S. District Court, Bankruptcy Courtroom 1300 18th St., Bakersfield, CA Date Action Filed: Date Set for Trial: January 6, 2007 December 3, 2008 NOTICE OF MOTION AND MOTION TO COMPEL PRODUCTION AND FURTHER RESPONSES BY DEFENDANT COUNTY OF KERN TO PLAINTIFF’S INTERROGATORIES, SET ONE Case No. 1:07-cv-00026-OWW-TAG

NOTICE OF MOTION AND MOTION TO COMPEL FURTHER RESPONSES BY DEFENDANT COUNTY OF KERN TO PLAINTIFF’S INTERROGATORIES, SET ONE 1

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

Document 96

Filed 03/24/2008

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set one. The factual and legal bases for this motion will be set forth more fully in the parties’ Joint Statement regarding this discovery dispute, which will be filed on or before April 9, 2008. After Defendant served initial responses to Plaintiff’s interrogatories, Plaintiff met and conferred with Defendant in an attempt to resolve discovery disputes without having to burden this Court. Defendant served supplemented responses to Plaintiff’s interrogatories which resolved some issues but refused to address others. Plaintiff therefore was left no choice but to bring this motion to compel.

Pursuant to Eastern District Local Rule 37-251, this motion will be based on the Joint Statement to be submitted by Plaintiff DAVID F. JADWIN after meeting and conferring with Defendant COUNTY OF KERN in this case on or before April 9, 2008.

Respectfully submitted on March 24, 2008.

/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 Attorneys for Plaintiff DAVID F. JADWIN, D.O.

NOTICE OF MOTION AND MOTION TO COMPEL FURTHER RESPONSES BY DEFENDANT COUNTY OF KERN TO PLAINTIFF’S INTERROGATORIES, SET ONE 2


				
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.