Case 1:07-cv-00026-OWW-TAG Document 215 Filed 09/01/2008 Page 1 of 2

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 Attorney for Plaintiff
DAVID F. JADWIN, D.O.
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8 UNITED STATES DISTRICT COURT
9 EASTERN DISTRICT OF CALIFORNIA
10 FRESNO DIVISION
11 DAVID F. JADWIN, D.O., Civil Action No. 1:07-cv-00026 OWW TAG
12 Plaintiff, PLAINTIFF'S NOTICE OF MOTION AND
MOTION TO COMPEL FURTHER
13 v. PRODUCTION OF DOCUMENTS
14 COUNTY OF KERN, et al., Date: September 26, 2008
Time: 9:30 a.m.
15 Defendants. Place: U.S. District Court, Bankruptcy Courtroom
1300 18th St., Bakersfield, CA
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Date Action Filed: January 6, 2007
17 Discovery Cut-off: August 17, 2008
Date Set for Trial: December 2, 2008
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21 TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD:
22 Please take notice that on September 26, 2008, at 9:30 a.m., or as soon thereafter as the parties
23 may be heard, Plaintiff DAVID F. JADWIN, D.O. will and hereby does move this Court, at the U.S.
24 Dist. Ct., Bankr. Crtrm., 1300 18th St., Bakersfield, CA, for an order compelling defendant COUNTY
25 OF KERN (Defendant) to further respond to Plaintiff's Request for Production of Documents (Sets One
26 and Three).
27 After Defendant served initial responses and produced documents in response to Plaintiff’s
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PLAINTIFF'S NOTICE OF MOTION AND MOTION TO COMPEL FURTHER PRODUCTION OF DOCUMENTS 1

 Case 1:07-cv-00026-OWW-TAG Document 215 Filed 09/01/2008 Page 2 of 2

1 Request of Production, Sets One and Three, Plaintiff met and conferred with Defendant in an attempt to
2 resolve discovery disputes without having to burden this Court.
3 Defendant then produced further documents which resolved some issues but failed to resolve
4 others. Plaintiff therefore was left no choice but to bring this motion to compel.
5 Pursuant to Eastern District Local Rule 37-251, this motion will be based on the Joint Statement
6 to be submitted by Plaintiff DAVID F. JADWIN after meeting and conferring with Defendant
7 COUNTY OF KERN in this case on or before September 23, 2008. The factual and legal bases for this
8 motion will be set forth more fully therein.
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10 RESPECTFULLY SUBMITTED on September 2, 2008.
11 /s/ Eugene D. Lee
LAW OFFICE OF EUGENE LEE
12 555 West Fifth Street, Suite 3100
Los Angeles, CA 90013
13 Phone: (213) 992-3299
Fax: (213) 596-0487
14 email: elee@LOEL.com
Attorney for Plaintiff DAVID F. JADWIN, D.O.
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PLAINTIFF'S NOTICE OF MOTION AND MOTION TO COMPEL FURTHER PRODUCTION OF DOCUMENTS 2