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1 LAW OFFICE OF EUGENE LEE

Eugene D. Lee (SB#: 236812)


2 555 West Fifth Street, Suite 3100
Los Angeles, CA 90013
3 Phone: (213) 992-3299
Fax: (213) 596-0487
4 email: elee@LOEL.com
5 Attorneys for Plaintiff
DAVID F. JADWIN, D.O.
6
7 UNITED STATES DISTRICT COURT
8 EASTERN DISTRICT OF CALIFORNIA
9 FRESNO DIVISION
10 DAVID F. JADWIN, D.O., Civil Action No. 1:07-cv-00026 OWW TAG
11 Plaintiff, NOTICE OF FILING PROOF OF SERVICE
OF THE SUMMONS AND COMPLAINT
12 v.
13 COUNTY OF KERN; et al.
14 Defendants.
TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD:
15
Please take notice that Plaintiff DAVID F. JADWIN, D.O. is hereby filing his Notice of Filing of
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Proof of Service of Summons and Complaint on Defendants IRWIN HARRIS, M.D; EUGENE
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KERCHER, M.D.; JENNIFER ABRAHAM, M.D.; SCOTT RAGLAND, M.D.; TONI SMITH; and
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WILLIAM ROY, M.D.in this action. Counsel of record for Defendants agreed to accept service on
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behalf of all Defendants on April 6, 2007. As of this filing, Plaintiff has served all Defendants with
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copies of the Court’s Order Setting Mandatory Scheduling Conference as well as the Standing Orders of
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Judge Wanger and Magistrate Judge Goldner.
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RESPECTFULLY SUBMITTED on April 11, 2007.
23
/s/ Eugene D. Lee
24 LAW OFFICE OF EUGENE LEE
555 West Fifth Street, Suite 3100
25 Los Angeles, CA 90013
Phone: (213) 992-3299
26 Fax: (213) 596-0487
email: elee@LOEL.com
27 Attorney for Plaintiff DAVID F. JADWIN, D.O.
28

NOTICE OF FILING OF PROOF OF SERVICE OF SUMMONS AND COMPLAINT 1


Apr 11 07 02:00p Mark Wasser 916-000-0000 p.2

1 Mark A. Wasser CA SB #060160


LAW OFFICES OF MARK A. WASSER
2 400 Capitol Mall, Suite 1100
Sacramento, CA 95814
3 Phone: (916) 444-6400
Fax: (916) 444-6405
4 E-mail: mwasseriW.markwasseLcom

5 Bernard C. Bannan, Sr.


KERN COlJ~TY COUNSEL
6 Mark Nations, Chief Deputy
IllS Truxton Avenue, Fourth Floor
7 Bakersfield, CA 93301
Phone: (661) 868-3800
8 Fax: (661) 868-3805
E-mail: mnations@co.kern.ca.us
9
10 Attorneys for Defendants County of Kern,
Peter Bryan, Irwin Harris, Eugene Kercher,
II Jennifer Abraham, Scott Ragland, Toni Smi1h
and William Roy
12

13 UNITED STATES DISTRICT COURT


14 EASTERN DISTRICT OF CALIFORNIA
15
16 DAVID F. JADWIN, D.O. ~ Case No.: 1:07-cv-26

17 Plaintiff, ) STIPULATION RE; SERVICE AND


) RESPONSE TO FIRST AMENDED
18 vs. ) COMPLAINT, SCHEDULIG OF RULE
) 26(1) CONFERENCE AND MANDATORY
19 COUNTY OF KERN, et aI., ) SCHEDULING CONFERENCE AND
) ORDER
20 Defendants. )
-------------.)
21
22 It is hereby stipulated by and between the parties hereto through their respective counsel

23 as follows:
24 1. There are multiple Defendants in this action and they were not all served on the same

25 date but they were all served by April 6,2007. Given the varying service dates, the parties agree
26 that all the Defendants may file an answer to the First Amended Complaint on or before April

27 30,2007. Plaintiff shall not be prejudiced with respect to the scheduling of discovery or trial.
28 ! !!
STIPULATION RE: SERVICE AND RESPONSE TO FIRST AMENDED COMPLAINT, SCHEDULING OF
RULE 26(f) CONFERENCE AND MANDATORY SCHEDULDlG CONFERENCE AND ORDER

1
Apr 11 07 02:00p Mark Wasser 916-000-0000 p.3

I 2. Plaintiff may supplement his First Amended Complaint by adding factual allegations

2 regarding a letter from the California Labor Commissioner and some other matters. The

3 supplement will be filed on or before April 24, 2007.


4 3. The parties will conduct the Rule 26(f) Conference on May 4,2007 at a mutually
5 agreeable time and location.
6 4. In order that the parties have sufficient time to prepare effective initial disclosures and

7 a discovery plan, the parties request that the Court re-schedule the Mandatory Scheduling
8 Conference to May 31, 2007.

9
10 Dated, AprilR, 2007 LAW OFFICES OF MARK A. WASSER

II

12

13 Mark A. Wasser
Attorney for Defendants, County of Kern, et aI.
14

15
Dated: April 11
_ _, 2007 LAW OFFICE OF EUGENE LEE
16

17 By:, _
18
Eugene D. Lee
19 Attorney for Plaintiff, David F. Jadwin, D.O.

20
ORDER
21
22 The parties having stipulated as hereinabove set forth and good cause appearing
therefore;
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IT IS SO ORDERED. The Mandatory Schednling Conference is reset to .
24
25 Dated: April _ _, 2007 UKITED STATES DISTRlCT COURT
26 By: _
27 The Honorable Oliver W. Wanger
28 United States District Court Judge

STIPULATlON RE: SERVICE AND RESPONSE TO FIRST AMENDED COMPLAINT, SCHEDULING OF


RULE 26(f) CONFERENCE AND MANDATORY SCHEDULING CONFERENCE AND ORDER

2
1 CERTIFICATE OF SERVICE
2 I, the undersigned, hereby declare:
3 I am a resident of Los Angeles in the State of California. I am over the age of 18 and not a party
to the action described herein. I am employed in the County of Los Angeles, California. My business
4 address is LAW OFFICE OF EUGENE LEE, 555 West Fifth Street, Suite 3100, Los Angeles, CA
90013. I served the following:
5
NOTICE OF FILING PROOF OF SERVICE OF THE SUMMONS AND COMPLAINT
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on the following parties in this action and/or their attorneys, who are not registered participants of the
7 CM/ECF System, addressed as follows:
8 Mark Wasser
Law Office of Mark Wasser
9 400 Capitol Mall Ste 1100
Sacramento, CA 95814
10
11
BY UNITED STATES MAIL: I enclosed the document(s) listed above in a sealed envelope
12 with postage thereon fully prepaid, addressed to the person(s) listed above, and deposited the sealed
envelope with the United States Postal Service at Los Angeles, California. I am aware that on motion of
13 the party served, service is presumed invalid if postal cancellation date or postage meter date is more
than one day after date of deposit for mailing in affidavit.
14
BY FACSIMILE: I transmitted via facsimile the document(s) listed above to the fax number(s)
15 set forth above on this date at approximately 4:00 p.m. The outgoing facsimile machine telephone
number in this office is (213) 596-0487. The facsimile service used in this office creates a transmission
16 report for each outgoing facsimile transmitted. A copy of the transmission report(s) for the service of
this document, properly issued by the facsimile service that transmitted this document and showing that
17 such transmission was (transmissions were) completed without error, is attached hereto.
18 FEDERAL: I declare under penalty of perjury under the laws of the United States of America
that the above is true and correct and that I took said actions at the direction of a licensed attorney
19 authorized to practice before this Federal Court.
20
21 Executed on April 11, 2007, at Los Angeles, California.
22
23 __________________________________
24 Eugene D. Lee
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26
27
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NOTICE OF FILING OF PROOF OF SERVICE OF SUMMONS AND COMPLAINT 2

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