Professional Documents
Culture Documents
1 availability for deposition by Defendants. Defendants nevertheless chose to set the depositions of
2 Plaintiff’s experts on dates on which they had indicated they were unavailable. Only one expert has so
3 far indicated to Plaintiff that she may be able to adjust her schedule to be deposed on the date which
4 Defendants unilaterally set. Plaintiff’s other experts have said they will not be available and will
5 therefore be unable to attend their depositions. Pursuant to Local Rule 6-144, Plaintiff apprised
6 Defendants of the situation on July 30, 2008 and asked to meet and confer by the next day on shortening
7 time to hear Plaintiff’s motion for protective order. Receiving no response, Plaintiff had no choice but to
8 file this ex parte application to shorten time.
9 Plaintiff served this Ex Parte Application and associated declaration and exhibits on Defendants
10 by facsimile before 5 p.m. on Thursday, July 31, 2008.
11 This Application is based on these moving papers, the declaration of Eugene D. Lee, counsel of
12 record for Plaintiff, the exhibits attached thereto, and the pleadings and papers on file in this action.
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14 RESPECTFULLY SUBMITTED on July 31, 2008.
15 /s/ Eugene D. Lee
LAW OFFICE OF EUGENE LEE
16 555 West Fifth Street, Suite 3100
Los Angeles, CA 90013
17 Phone: (213) 992-3299
Fax: (213) 596-0487
18 email: elee@LOEL.com
Attorney for Plaintiff DAVID F. JADWIN, D.O.
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1 I declare under penalty of perjury under the laws of the State of California and of the United States that
2 the foregoing is true and correct.
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4 Dated: July 31, 2008
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6 ____________________________________
Eugene D. Lee
7 Attorney for Defendant
DAVID F. JADWIN, D.O.
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