106 Motion - KC MPO DFJ Dec Joint STMT - 080423

Case 1:07-cv-00026-OWW-TAG Document 106 Filed 04/23/2008 Page 1 of 22
1 Eugene D. Lee SB#: 236812

LAW OFFICE OF EUGENE LEE
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 DAVID F. JADWIN, D.O., Civil Action No. 1:07-cv-00026 OWW TAG
10 Plaintiff, DECLARATION OF EUGENE D. LEE re:
v. INABILITY TO SECURE COOPERATION
11 OF DEFENDANTS’ COUNSEL TO
COUNTY OF KERN, et al., PREPARE AND EXECUTE JOINT
12 STATEMENT re: MOTION FOR
Defendants. PROTECTIVE ORDER re: FURTHER
13 INTERROGATORIES
14 Date: April 28, 2008
Time: 9:30 a.m.
15 Place: U.S. District Court, Bankruptcy Courtroom
1300 18th St., Bakersfield, CA
16
Date Action Filed: January 6, 2007
17 Date Set for Trial: December 3, 2008
18
Plaintiff submits this Declaration of Eugene D. Lee pursuant to Local Rule 37-251(d) in lieu of a
19
joint statement re discovery disagreement.
20
I, Eugene D. Lee, declare as follows:
21
1. I am counsel of record for Plaintiff. I have personal knowledge of the matters set forth
22
below and I could and would competently testify thereto if called as a witness in this matter.
23
2. On April 2, 2008, defendants filed their Notice of Motion and Motion for a Protective
24
Order re: Further Interrogatories by Plaintiff (Doc. 97). In the motion, defendants stated “Pursuant to
25
Local Rule 37-251, Defendants will prepare, submit to Plaintiff and file a Joint Statement re Discovery
26
Disagreement on or before April 23, 2008.” (Doc. 97, 2:11-12).
27
3. To date, defendants have neither submitted to plaintiff nor filed such a joint statement. As
28
DECLARATION OF EUGENE D. LEE re: INABILITY TO SECURE COOPERATION OF
DEFENDANTS’ COUNSEL TO PREPARE AND EXECUTE JOINT STATEMENT re: MOTION
FOR PROTECTIVE ORDER re: FURTHER INTERROGATORIES 1
1 such, defendants are in clear violation of Local Rule 37-251. In contrast, plaintiff had sent both draft
2 joint statements for its pending motion to compel interrogatory responses and for protective order re
3 depositions to defendant by both mail and fax a full week prior to today’s deadline. Even so, defense
4 counsel manages to complain that plaintiff has somehow ambushed him. Defendants’ violation of Rule
5 37-251 justifies entry of an order adverse to defendants or their counsel
6 4. The Scheduling Order issued by Judge Wanger in this action states: “Given the number
7 of Defendants and witnesses and the number and complexity of the issues, Plaintiff anticipates needing
8 relief from the discovery limitations of Federal Rule of Civil Procedure 30(a)(2)(A) (10 depositions per
9 side) and Rule 33(a) (no more than 25 interrogatories per party). Defendants do not object to granting
10 Plaintiff relief from that limitation.” (Doc. 29, 14:23 – 15:1). So long as plaintiff is not abusive in
11 propounding interrogatories, there is no mention in the Scheduling Order that plaintiff will be
12 constrained to some arbitrary number of interrogatories.
13 5. That did not stop defendants from attempting to impose an arbitrary ceiling on plaintiff’s
14 interrogatories, anyway. Finally, in a phone call on February 21, 2008, plaintiff and defendants
15 expressly agreed that “Plaintiff and Defendants will continue to honor the stipulations lifting certain
16 discovery restrictions as explicitly and fully set forth in the Joint Scheduling Order. As such, Plaintiff is
17 not obligated to agree on or observe a limit on the number of interrogatories permitted to be propounded
18 unless otherwise expressly agreed to in writing. Likewise, Defendant will be permitted to depose Dr.
19 Jadwin for a total of 21 hours.” (See Exhibit 1 attached hereto). Based on this agreement which was
20 memorialized in Exhibit 1, plaintiff permitted defendants to depose plaintiff for 4 full days, which
21 defendants proceeded to do. This is undisputed.
22 6. Immediately after completing their deposition of plaintiff and benefiting from the “quid”
23 of the parties’ quid pro quo, defendants then withheld the “quo” from plaintiff and resumed disputing
24 the agreement memorialized in Exhibit 1. Defendants have made a habit of breaking commitments –
25 even written ones – reached with plaintiff as soon as it is to their advantage to do so.
26 7. Finally, the parties negotiated a new agreement. On April 21, 2008, plaintiff emailed
27 defendants a proposed written stipulation which would deem documents produced in discovery
28
1 authenticated and business records, as well as limit plaintiff’s interrogatories. (See Exhibit 2 attached
2 hereto).
3 8. Defendant then sent a fax to plaintiff on April 23, 2008, claiming to memorialize only the
4 agreement as to limitation of plaintiff’s interrogatories, without mentioning the other agreements which
5 plaintiff sought. (See Exhibit 3 attached hereto). Thus, yet again, defendants sought to circumvent the
6 quid pro quo process by taking the “quid” but not giving the “quo.” This echoed what defendant had
7 done previously when they deposed plaintiff for 4 full days and then reneged on their commitment not to
8 limit plaintiff’s interrogatories.
9 9. When plaintiff informed defendants that this fax was jumping the gun and requested
10 defendants review and sign the previously-provided stipulation in its entirety, defendants refused. (See
11 Exhibit 4 attached hereto).
12 10. Plaintiff is an individual with limited resources. As Judge Wanger’s Scheduling Order
13 notes, plaintiff’s complaint comprises 11 causes of action – ranging from defamation to procedural due
14 process violation, whistleblower retaliation, medical leave violation and retaliation, etc. – against 8
15 defendants and spans more 6 years. The discovery required to substantiate these complex causes of
16 action necessitates larger scope than usual. Plaintiff has already attempted to secure discovery via
17 depositions of witnesses. However, after having conducted depositions of more than 13 witnesses,
18 plaintiff remains frustrated due to defendants’ obstructive conduct in depositions. Consequently,
19 plaintiff has not been able to efficiently obtain discovery through depositions, though it will continue to
20 attempt to do so.
21 11. However, at this juncture, with only 2 months remaining before the July 7 discovery
22 cutoff, interrogatories represent the most time-efficient and cost-effective means for plaintiff to obtain
23 the evidence needed to prosecute its claims.
24 12. Defendants now bring a blanket motion for protective order, refusing to respond to
25 plaintiff’s interrogatories, set two, unless and until plaintiff acknowledges an arbitrary limit on the
26 number of interrogatories plaintiff may propound, proper or not. Plaintiff challenges defendants to
27 make a showing that individual interrogatories which plaintiff has thus far propounded are in any
28
1 way improper or abusive. The parties have already met and conferred at length with regard to sets 1
2 and 2 of plaintiff’s interrogatories and successfully reached accord on responding to or withdrawing
3 interrogatories. Such an accord would never have been possible had plaintiff’s interrogatories been in
4 any way abusive. The interrogatories plaintiff has propounded and will propound do not impose an
5 undue burden or expense on defendants.
6 13. As defendant well knows, plaintiff has NOT propounded 91 interrogatories to date.
7 Plaintiff has explained to defendants numerous times that subparts do not constitute separate
8 interrogatories under FRCP Rule 33 unless they are so logically discrete from the main inquiry as to
9 constitute a separate inquiry. See Safeco of America v. Rawstrom (CD CA 1998) 181 FRD 441, 445
10 (“subparts count as one interrogatory ‘if they are logically or factually subsumed within and necessarily
11 related to’ primary question”). Nevertheless, defendants continue to count sub-parts in plaintiff’s
12 interrogatories as separate interrogatories so as to insinuate that plaintiff is somehow being abusive in
13 propounding “91 interrogatories”. Nothing could be further from the truth.
14 14. Despite the foregoing, in an earnest attempt to reach a compromise that would avert
15 having to disturb this Court, plaintiff expressed its willingness to stipulate to a limitation in the number
16 of interrogatories it may propound in the future, provided defendants also stipulate to deem documents
17 thus far produced in discovery to be authentic and business records under the FRE. Defendants agreed
18 but then refused to negotiate or sign the draft stipulation which plaintiff emailed to defendants.
19 Plaintiff’s last email to defendants stated: “Mark, What’s your resistance to the stipulation? I believe it
20 addresses all the concerns in your motion for protective order. I sent it to you previously. I drafted it to
21 be as neutral and fair as possible. If you have revisions, simply make them. True to form, you remain
22 all-too-eager to escalate issues to the Court rather than trying to work them out among ourselves.”
23 15. Plaintiff seeks sanctions in reimbursement of $400 of the costs and fees incurred by
24 plaintiff in connection with this motion. (See Exhibit 5).
25
26 I declare under penalty of perjury under the laws of the State of California and the United States
27 that the foregoing is true and correct.
28
1
2
Executed on: April 23, 2008
3
4
5 /s/ Eugene D. Lee
6 EUGENE D. LEE
Declarant
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27 EXHIBIT 1
28
Eugene D. Lee
From: Eugene D. Lee [elee@LOEL.com]
Sent: Thursday, February 21, 2008 12:30 PM
To: 'mwasser@markwasser.com'
Subject: Jadwin/KC: Followup re DFJ Depo
Follow Up Flag: Follow up

Flag Status: Completed
Mark,
It was a pleasure speaking with you this morning.
I just wanted to recap what we discussed today. Plaintiff and Defendants will continue to honor the stipulations
lifting certain discovery restrictions as explicitly and fully set forth in the Joint Scheduling Order. As such, Plaintiff
is not obligated to agree on or observe a limit on the number of interrogatories permitted to be propounded unless
otherwise expressly agreed to in writing. Likewise, Defendant will be permitted to depose Dr. Jadwin for a total of
21 hours.
We further agreed that Defendants would resume their deposition of Dr. Jadwin beginning March 11, 2008. Dr.
Jadwin is getting back to me with his availability for that week.
If you have any questions, please feel free to contact me.
Sincerely,
Gene Lee

~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~
EMPLOYMENT LAW
555 WEST FIFTH ST., STE. 3100
LOS ANGELES, CA 90013
Tel: (213)992-3299
Fax: (213)596-0487
E - m a i l : elee@LOEL.com
W e b s i t e : www.LOEL.com
B l o g : www.CaLaborLaw.com

~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~
This message is sent by a law firm and may contain information that is privileged or confidential. If you received this
transmission in error, please notify the sender by reply e-mail and delete the message and any attachments.

1
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27 EXHIBIT 2
28
Eugene D. Lee
Sent: Monday, April 21, 2008 8:49 PM
Subject: Stipulation - Auth-Biz Recs-Rogs_080423
Attachments: Stipulation - Auth-Biz Recs-Rogs_080423.doc
Mark,
Attached is a draft stipulation & order regarding the things we had discussed: authentication, business records
hearsay exception and limit on plaintiff’s interrogatories. I’m still revising it so it remains subject to change, but
I thought I would get the ball rolling sooner rather than later.
Please take a look and let me know your thoughts.
Sincerely,
Gene Lee

~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~
EMPLOYMENT LAW
Tel: (213)992-3299
Fax: (213)596-0487

~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~

1
1 Eugene D. Lee SB# 236812

LAW OFFICES OF EUGENE LEE
2 555West Fifth Street, Suite 3100
3 Phone: (213) 992-3299
Fax: (213) 596-0487
4 E-mail: elee@LOEL.com
5 Attorneys for Plaintiff
DAVID F. JADWIN, D.O.
6
Mark A. Wasser CA SB #060160
7 LAW OFFICES OF MARK A. WASSER
400 Capitol Mall, Suite 1100
8 Sacramento, CA 95814
Phone: (916) 444-6400
9 Fax: (916) 444-6405
E-mail: mwasser@markwasser.com
10
Bernard C. Barman, Sr.
11 KERN COUNTY COUNSEL
Mark Nations, Chief Deputy
12 1115 Truxtun Avenue, Fourth Floor
Bakersfield, CA 93301
13 Phone: (661) 868-3800
Fax: (661) 868-3805
14 E-mail: mnations@co.kern.ca.us
15 Attorneys for Defendants County of Kern, Peter Bryan, Irwin Harris, Eugene Kercher,
Jennifer Abraham, Scott Ragland, Toni Smith and William Roy
16
19
DAVID F. JADWIN, D.O. ) Case No.: 1:07-cv-00026 OWW TAG
20 )
Plaintiff, ) STIPULATION TO AUTHENTICATE
21 ) DOCUMENTS, DEEM AS BUSINESS
vs. ) RECORDS & TO LIMIT
22 ) INTERROGATORIES; & ORDER
COUNTY OF KERN, et al., ) THEREON
23 )
Defendants. ) Complaint Filed: January 5, 2007
24 ) Trial Date: December 3, 2008
25
IT IS HEREBY STIPULATED, by and among the parties hereto through their respective
26
counsel, that any and all documents in the Categories specified below which are produced by
27
plaintiff and/or by each of the defendants, or any of them, in the Initial Disclosures, supplemental
28
STIPULATION & ORDER THEREON 1

1 disclosures, or pursuant to discovery requests or procedures in this action shall be deemed

2 authentic under Federal Rule of Evidence 901.
3 IT IS HEREBY FURTHER STIPULATED, that any and all documents in the Categories
4 specified below which are produced by plaintiff and/or by each of the defendants, or any of
5 them, in the Initial Disclosures, supplemental disclosures, or pursuant to discovery requests or
6 procedures in this action shall be deemed business records under Federal Rule of Evidence
7 803(6).
8 CATEGORIES:
9 • E-mails to, from and/or carbon-copied to any of plaintiff, defendants and/or any
10 contractor, employee or ex-employee of a defendant, as well as any of their officers,
11 directors, agents, representatives and affiliates (including but not limited to the Kern
12 County Board of Supervisors, UMPK and FPP), etc. (“Witnesses”).
13 • Internal memoranda to, from and/or carbon-copied to any Witness or Witnesses.
14 • Executed letters to, from and/or carbon-copied to any Witness or Witnesses.
15 • Handwritten notes and/or markings by any Witness.
16 • Pathology reports, placental evaluation reports, surgical reports, operating reports and/or
17 other medical records.
18 • Reports and presentations authored and/or issued by outside consultants and/or experts,
19 including but not limited to Macias Group, Camden Group, David Lieu, William
20 Colburn, Parakrama Chandrasoma, Stacey Garry, ProPay, Jonathan Epstein, Richard
21 Kempson, etc.
22 • Policies, regulations and statutes, and excerpts thereof, including but not limited to Kern
23 County Civil Service Commission Rules, Kern County Employee Handbook, KMC
24 Bylaws, KMC Organization and Functions Manual, KMC Faculty Practice Board
25 Compensation Policy, KMC Medical Staff Rules & Regulations, KMC Corrective Action
26 and Termination Review Process, KMC Faculty Practice Plan Bylaws, University
27 Multispecialty Physicians of Kern Bylaws, etc.
28 • Personnel files and/or credential files of any Witness.

1 • Executed employment and/or independent contractor agreements by, between or among

2 any Witness.
3 • Meeting minutes of any committee or sub-committee, division, department or group of
4 any Witness.
5 • Timesheets of any Witness.
6 • Forms executed by any Witness, including but not limited to FMLA/CFRA medical leave
7 application forms.
8 IT IS HEREBY FURTHER STIPULATED, that Plaintiff will not propound any
9 additional interrogatories (excluding supplemental interrogatories) after the date hereof.
10 Defendant will fully respond and/or object to plaintiff’s interrogatories, set two, by May 8, 2008.
11 Accordingly, defendant will withdraw their motion for protective order ( Doc. No. 97)
12
13 Dated: April , 2008 LAW OFFICE OF EUGENE LEE
14
15 By: Eugene D. Lee
Eugene D. Lee
16 Attorney for Plaintiff, David F. Jadwin, D.O.
17
18 Dated: April , 2008 LAW OFFICES OF MARK A. WASSER
19
20 By: Mark A. Wasser (as authorized on )
Mark A. Wasser
21 Attorney for Defendants, County of Kern, et al.
22
23
24
25
26
27
28

1 ORDER
2 The parties having stipulated as hereinabove set forth and good cause appearing therefor;
3
IT IS HEREBY ORDERED, that that any and all documents produced by plaintiff and/or
4 by each of the defendants, or any of them, in the Initial Disclosures, supplemental disclosures or
pursuant to discovery requests or procedures in this action shall be deemed authentic under
5 Federal Rule of Evidence 901, provided however that documents generated by third parties shall
6 not be included in this stipulation.
7 Dated: December , 2007 UNITED STATES DISTRICT COURT
8
By:
9 The Honorable Theresa A. Goldner
10 United States District Judge
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26 EXHIBIT 3
27
28
Apr 23 08 12:39p Mark Wasser 916-444-6405 p.1

The Law Offices of Mark A. Wasser
Sacramento, California 95814
Office: 916-444-6400
Fax: 916-444-6405
Fax
To: Eugene Lee From: Mark A. 'Wasser
Fax: (213) 596-0487 Pages: 2 (including cover page)
Phone: (213) 992-3299 Date: 4123/08
Re: Jadwin v. County of Kern CC:
o Urgent 0 For Review 0 Please Comment 0 Please Reply 0 Please Recycle
-Comments:
Please see attached letter.

Apr
Apr 23
23 08
08 12:39p
12:39p Mark Wasser 916-444-6405 p.2
p.2

Law omces of
MARK A. WASSER
Sacramento, California 95814
Office: 916-444-6400 Fax: 916-444-6405
mwasser@markwasser,com
April 23, 2008
VIA FACSIMILE AND FIRST CLASS MAIL
Eugene Lee
Law Offices of Eugene Lee
555 West Fifth Street. Suite 3100
Los Angeles, California 90013-1010
Re: Jadwin v. County ofKern, et al.
Dear Gene:
This will confirm our agreement that the Plaintiff will not serve any more
interrogatories and the Defendants will respond to Plaintiff s second set of interrogatories
on or before May 8. As we discussed on the telephone, the Defendants may object to
specific interrogatories but they will not object to the entire set and will provide good
faith responses. In light of this agreement, the Defendants will take their motion for
protective order off calendar.
Thank you.
Very Truly Yours,
Mark A. Wasser
cc: Karen Barnes (via facsimile)

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27 EXHIBIT 4
28
DECLARATION OF EUGENE D. LEE IN SUPPORT OF DECLARATION re: INABILITY TO
SECURE COOPERATION TO PREPARE AND EXECUTE JOINT STATEMENT re: MOTION FOR
PROTECTIVE ORDER 1
Eugene D. Lee
Sent: Wednesday, April 23, 2008 1:24 PM
Subject: RE: Limitation on Rogs
Mark,
What’s your resistance to the stipulation? I believe it addresses all the concerns in your motion for protective
order. I sent it to you previously. I drafted it to be as neutral and fair as possible. If you have revisions, simply
make them.
True to form, you remain all-too-eager to escalate issues to the Court rather than trying to work them out among
ourselves.
Sincerely,
Gene Lee

~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~
EMPLOYMENT LAW
Tel: (213)992-3299
Fax: (213)596-0487

~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~

From: Mark Wasser [mailto:mwasser@markwasser.com]

To: elee@LOEL.com
Subject: RE: Limitation on Rogs
Oh. Well, then our motion for protective order will remain on calendar. Fine.
From: Eugene D. Lee [mailto:elee@LOEL.com]

To: mwasser@markwasser.com
Subject: Limitation on Rogs
Mark,
1
I just received your fax of today. We have not reached any such agreement to limit plaintiff’s interrogatories. I
emailed you a draft stipulation and order addressing the limitation of rogs, authentication, business records, etc.
Until that is negotiated, signed and filed, I regret to say that there is no agreement between us.
I believe the solution is for you to sign the stipulation and return it to me immediately.
Sincerely,
Gene Lee

~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~
EMPLOYMENT LAW
Tel: (213)992-3299
Fax: (213)596-0487

~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~

2
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27 EXHIBIT 5
28
PROTECTIVE ORDER 2
1 Eugene D. Lee SB#: 236812

2 555 West Fifth Street, Suite 3100
3 Phone: (213) 992-3299
Fax: (213) 596-0487
4 email: elee@LOEL.com
5 Attorneys for Plaintiff DAVID F. JADWIN, D.O.
6
9 DAVID F. JADWIN, D.O., Civil Action No. 1:07-cv-00026 OWW TAG
10 Plaintiff, DECLARATION OF EUGENE D. LEE IN
v. SUPPORT OF DECLARATION re:
11 INABILITY TO SECURE COOPERATION
COUNTY OF KERN, et al., OF DEFENDANTS’ COUNSEL TO
12 PREPARE AND EXECUTE JOINT
Defendants. STATEMENT re: MOTION FOR
13 PROTECTIVE ORDER
14 Date: April 28, 2008
Time: 9:30 a.m.
15 Place: U.S. District Court, Bankruptcy Courtroom
1300 18th St., Bakersfield, CA
16
Date Action Filed: January 6, 2007
17 Date Set for Trial: December 3, 2008
18
I, Eugene D. Lee, declare as follows:
19
1. I am an attorney at law duly licensed to practice before the Federal and State Courts of
20
California and admitted to practice before the U.S.D.C. for the Eastern District of California. I am
21
counsel of record for Plaintiff David F. Jadwin in this matter.
22
2. I am making this declaration in support of plaintiff’s motion to compel responses to
23
interrogatories. I have personal knowledge of the matters set forth below and I could and would
24
competently testify thereto if called as a witness in this matter.
25
3. I have spent and anticipate spending substantially in excess of 1.5 hours researching and
26
drafting these moving papers and attending the motion hearing in Bakersfield, CA.
27
4. My regular rate for legal services is $400 per hour.
28
PROTECTIVE ORDER 1
1 5. My rate is consistent with those charged in the Los Angeles area by attorneys of similar
2 skill and experience. I received my B.A. with honors from Harvard University in 1991 and my J.D. with
3 honors from the University of Michigan Law School in 1995. I was admitted to the New York State Bar
4 in 1996 and worked as an associate in the New York office of Shearman & Sterling from 1995 to 1996. I
5 worked as an associate in the New York office of Sullivan & Cromwell from 1996 to 1997. After a brief
6 leave of absence from practicing law from 1997 to 1999, I returned to active practice as the General
7 Counsel of Tcom America, Inc., a technology venture in Silicon Valley from 1999 to 2002. From 2002
8 to 2004, I worked as a senior associate for Kim & Chang, a law firm located in Seoul, Korea. In 2005, I
9 was admitted to the California Bar. I have been the principal of Law Office of Eugene Lee since 2005.
10 6. I attempted several times to secure local counsel to prosecute Plaintiff’s suit but was
11 ultimately unsuccessful. On September 18, 2006, I sent an email to over 600 members of the California
12 Employment Lawyers Association seeking co-counsel. No attorneys from Fresno responded. On
13 February 28, 2007, I called Andrew Jones, Esq. in Fresno, CA, requesting his involvement as local
14 counsel in this action. Mr. Jones declined.
15
16 I declare under penalty of perjury under the laws of the State of California and the United States
17 that the foregoing is true and correct.
18
Executed on: April 23, 2008
19
20
21 /s/ Eugene D. Lee
22 EUGENE D. LEE
Declarant
23
24
25
26
27
28
PROTECTIVE ORDER 2

106 Motion - KC MPO DFJ Dec Joint STMT - 080423

Enviado por

Dados do documento

Descrição original:

Título original

Direitos autorais

Formatos disponíveis

Compartilhar este documento

Compartilhar ou incorporar documento

Opções de compartilhamento

Você considera este documento útil?

Este conteúdo é inapropriado?

Direitos autorais:

Formatos disponíveis

106 Motion - KC MPO DFJ Dec Joint STMT - 080423

Enviado por

Direitos autorais:

Formatos disponíveis

Case 1:07-cv-00026-OWW-TAG Document 106 Filed 04/23/2008 Page 1 of 22

1 Eugene D. Lee SB#: 236812

Follow Up Flag: Follow up

It was a pleasure speaking with you this morning.

If you have any questions, please feel free to contact me.

Please take a look and let me know your thoughts.

1 Eugene D. Lee SB# 236812

STIPULATION & ORDER THEREON 1

1 disclosures, or pursuant to discovery requests or procedures in this action shall be deemed

STIPULATION & ORDER THEREON 2

1 • Executed employment and/or independent contractor agreements by, between or among

STIPULATION & ORDER THEREON 3

7 Dated: December , 2007 UNITED STATES DISTRICT COURT

STIPULATION & ORDER THEREON 4

Case 1:07-cv-00026-OWW-TAG Document 106 Filed 04/23/2008 Page 15 of 22

Fax: (213) 596-0487 Pages: 2 (including cover page)

Phone: (213) 992-3299 Date: 4123/08

Re: Jadwin v. County of Kern CC:

o Urgent 0 For Review 0 Please Comment 0 Please Reply 0 Please Recycle

Please see attached letter.

Case 1:07-cv-00026-OWW-TAG Document 106 Filed 04/23/2008 Page 16 of 22

April 23, 2008

VIA FACSIMILE AND FIRST CLASS MAIL

Re: Jadwin v. County ofKern, et al.

Very Truly Yours,

cc: Karen Barnes (via facsimile)

From: Mark Wasser [mailto:mwasser@markwasser.com]

From: Eugene D. Lee [mailto:elee@LOEL.com]

1 Eugene D. Lee SB#: 236812

Você também pode gostar