247 P Request for MSJ Page Limit Relief

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					Case 1:07-cv-00026-OWW-TAG
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Document 247

Filed 11/05/2008

Page 1 of 1
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L E E

O F

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November 5, 2008 VIA CM/ECF Hon. Oliver W. Wanger United States District Judge United States District Court Eastern District of California 2500 Tulare St, Crtrm. 3 Fresno, California Re: Relief from 25-Page Limitation on Motions for Summary Judgment Jadwin v County of Kern, et al. (1:07-cv-26-OWW-TAG) 100011.001

To the Honorable Court: Pursuant to Rule 3 of the “Standing Order in All Civil Cases Assigned to U.S. District Judge Oliver W. Wanger”, Plaintiff requests leave of the Court to submit a motion for summary judgment brief in excess of 25 pages. The dispositive motion deadline is November 13, 2008. This action involves no less than 11 causes of action alleged by Plaintiff and 10 affirmative defenses alleged by two individual defendants and one public entity defendant. The events relevant to this action span the entire 7-year employment tenure of Plaintiff. Discovery in this action has led to the production of almost 40,000 pages of documents, over 50 depositions and 4 sets of written discovery. Plaintiff seeks to file a motion for summary judgment that encompasses most, if not all, of the 11 causes of action and 10 affirmative defenses. Under the current 25-page limit, Plaintiff simply will not be able to competently address all of the above in his motion for summary judgment brief. Plaintiff respectfully requests an increase in the page limit to 50 pages. Respectfully,

EUGENE D. LEE cc: Mark A. Wasser


				
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.