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

Document 215

Filed 09/01/2008

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LAW OFFICE OF EUGENE LEE Eugene D. Lee (SB#: 236812) 555 West Fifth Street, Suite 3100 Los Angeles, CA 90013 Phone: (213) 992-3299 Fax: (213) 596-0487 email: elee@LOEL.com Attorney for Plaintiff DAVID F. JADWIN, D.O.

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA FRESNO DIVISION DAVID F. JADWIN, D.O., Plaintiff, v. COUNTY OF KERN, et al., Defendants. Civil Action No. 1:07-cv-00026 OWW TAG PLAINTIFF'S NOTICE OF MOTION AND MOTION TO COMPEL FURTHER PRODUCTION OF DOCUMENTS Date: September 26, 2008 Time: 9:30 a.m. Place: U.S. District Court, Bankruptcy Courtroom 1300 18th St., Bakersfield, CA Date Action Filed: Discovery Cut-off: Date Set for Trial: January 6, 2007 August 17, 2008 December 2, 2008

TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD: Please take notice that on September 26, 2008, at 9:30 a.m., or as soon thereafter as the parties may be heard, Plaintiff DAVID F. JADWIN, D.O. will and hereby does move this Court, at the U.S. Dist. Ct., Bankr. Crtrm., 1300 18th St., Bakersfield, CA, for an order compelling defendant COUNTY OF KERN (Defendant) to further respond to Plaintiff's Request for Production of Documents (Sets One and Three). After Defendant served initial responses and produced documents in response to Plaintiff’s

PLAINTIFF'S NOTICE OF MOTION AND MOTION TO COMPEL FURTHER PRODUCTION OF DOCUMENTS

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

Document 215

Filed 09/01/2008

Page 2 of 2

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Request of Production, Sets One and Three, Plaintiff met and conferred with Defendant in an attempt to resolve discovery disputes without having to burden this Court. Defendant then produced further documents which resolved some issues but failed to resolve 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 September 23, 2008. The factual and legal bases for this motion will be set forth more fully therein.

RESPECTFULLY SUBMITTED on September 2, 2008. /s/ Eugene D. Lee LAW OFFICE OF EUGENE LEE 555 West Fifth Street, Suite 3100 Los Angeles, CA 90013 Phone: (213) 992-3299 Fax: (213) 596-0487 email: elee@LOEL.com Attorney for Plaintiff DAVID F. JADWIN, D.O.

PLAINTIFF'S NOTICE OF MOTION AND MOTION TO COMPEL FURTHER PRODUCTION OF DOCUMENTS

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