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273 P Request for MSJ Opp Page Limit Relief

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					Case 1:07-cv-00026-OWW-TAG
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Document 273

Filed 11/24/2008

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L A W

E U G E N E

O F F I C E

L E E

O F

555 WEST FIFTH STREET, SUITE 3100 LOS ANGELES, CALIFORNIA 90013-1010

November 24, 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: 100011.001

Relief from 25-Page Limitation on Opposition to Motion for Summary Judgment Jadwin v County of Kern, et al. (1:07-cv-26-OWW-TAG)

To the Honorable Court: The Court previously granted Plaintiff’s and Defendants’ prior separate requests for relief from the page limit on dispositive motions, and increased the page limit to 35 pages. Plaintiff now requests parallel relief pursuant to Rule 3 of the “Standing Order in All Civil Cases Assigned to U.S. District Judge Oliver W. Wanger”; plaintiff seeks leave of the Court to submit an opposition to motion for summary judgment brief in excess of 25 pages. The opposition filing deadline is December 1, 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 an opposition to Defendants’ motion for summary judgment, which presently encompasses all of plaintiff’s causes of action. Under the current 25-page limit, Plaintiff simply will not be able to competently address all of the above in his opposition brief. Plaintiff respectfully requests an increase in the page limit to 35 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.