Case 1:07-cv-00026-OWW-TAG Document 164 Filed 07/14/2008 Page 1 of 3

Mark A. Wasser, CA SB #060160

1 LAW OFFICES OF MARK A. WASSER
400 Capitol Mall, Suite 2640
2 Sacramento, CA 95814
Phone: (916) 444-6400
3 Fax: (916) 444-6405
E-mail: mwasser@markwasser.com
4
Bernard C. Barmann, Sr. CA SB #60508
5 KERN COUNTY COUNSEL
Mark Nations, Chief Deputy CA SB #101838
6 1115 Truxtun Avenue, Fourth Floor
Bakersfield, CA 9330 I
7 Phone: (661) 868-3800
Fax: (661) 868-3805
8 E-mail: mnations@co.kern.ca.us
9 Attorneys for Defendants County of Kern,
Peter Bryan, Irwin Harris, Eugene Kercher,
10 Jennifer Abraham, Scott Ragland, Toni Smith
and William Roy
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UNITED STATES DISTRICT COURT
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EASTERN DISTRICT OF CALIFORNIA
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Case No.: 1:07-cv-00026-0WW-TAG
16 DAVID F. JADWIN, D.O.
DEFENDANTS' EX PARTE
17 Plaintiff, APPLICATION FOR ORDER
SHORTENING TIME FOR MOTION FOR
18 vs. PROTECTIVE ORDER RE: FURTHER
DEPOSITIONS AND INTERROGATORIES
19 COUNTY OF KERN, et aI., BY PLAINTIFF
20 Defendants.
Date:
21 Time:
Place: U.S. Bankruptcy Courthouse,
22 Bakersfield Courtroom 8
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Date Action Filed: January 6, 2007
24 Trial Date: December 2, 2008
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DEFENDANTS' EX PARTE APPLICATION FOR ORDER SHORTENING TIME FOR MOTION
FOR PROTECTIVE ORDER RE: FURTHER DEPOSITIONS AND INTERROGATORIES BY PLAINTIFF
 Case 1:07-cv-00026-OWW-TAG Document 164 Filed 07/14/2008 Page 2 of 3

1 TO THE COURT AND TO PLAINTIFF AND HIS ATTORNEY OF RECORD:

2 Defendants, County of Kern, et aI., ("Defendants") hereby move, ex-parte, for an order
3 shortening time for the hearing on their motion for a protective order re: further depositions and
4 interrogatories by Plaintiff.
5 In addition to the 16 depositions he has already taken, Plaintiff has noticed 17
6 depositions, the first which is set for July 15,2008. Plaintiff has also served a third set of written
7 interrogatories, bringing the total interrogatories served to date to 98. Defendants' responses to
8 Plaintiffs third set of interrogatories are due on August 7,2008.
9 Plaintiff has also noticed a motion to amend his complaint and add new theories of
10 recovery against the County. His motion to amend is set for September 8, 2008. Supplemental
11 expert disclosures are due on July 16,2008. Discovery closes on August 18,2008. It is
12 necessary that Defendants' motion for a protective order be heard on shortened time so that the
13 discovery dispute between the parties can be resolved promptly.
14 Defendants will also be filing a motion to amend the Scheduling Order and will set it for
15 hearing on September 8, 2008 so it can be considered at the same time as Plaintiffs motion to
16 amend his complaint.
17 The underlying motion for protective order is attached to the Declaration of Mark Wasser
18 as Exhibit F.
19 Defendants request the Court shorten time for the hearing and service on Defendants'
20 motion for protective order as follows:
21 Filing of the Motion for Protective Order: July 14, 2008.
22 Joint Statement Re Discovery Dispute or Declarations:
23 Other opposition, if any:
24 Hearing on Motion:
25 Pursuant to Local Rule 60 l44(c), Defendants met and conferred with Plaintiff s counsel
26 and sought agreement on both the motion for protective order and shortening time on the hearing
27 on the motion and no agreement was reached.
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DEFENDANTS' EX PARTE APPLICATION FOR ORDER SHORTENING TIME FOR MOTION
FOR PROTECTIVE ORDER RE: FURTHER DEPOSITIONS AND INTERROGATORIES BY PLAINTIFF
 Case 1:07-cv-00026-OWW-TAG Document 164 Filed 07/14/2008 Page 3 of 3

I This ex-parte application is supported by the Declaration of Mark A. Wasser, the exhibits

2 thereto, and any papers and argument hereafter submitted.

3 Respectfully submitted,

4 Dated: July 14, 2008 LAW OFFICES OF MARK A. WASSER

5 By :_-,I-"s/,-"M~a",-!rk"-..£:A,,-.-'-W-'-'a"'s"'s"'er'-- _
Mark A. Wasser
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Attorney for Defendants, County of Kern, et al.
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DEFENDANTS' EX PARTE APPLICATION FOR ORDER SHORTENING TIME FOR MOTION
FOR PROTECTIVE ORDER RE: FURTHER DEPOSlTIONS AND INTERROGATORIES BY PLAINTIFF