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Case 1:07-cv-00026-OWW-TAG Document 75 Filed 11/02/2007 Page 1 of 3
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Plaintiff, STll'ULATION HE: CONTACT
25 INFORMATION FOR WITNE.,S:ES
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vs. DICLOSED IN THE INITIAL
26 DISCLOSURES; OR-PE. R m/~REON
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COUNTY OF KERN, et aI.,
27 Complaint J'iled: January 5, 2001
Defendants. ) Trial Date: August 26, 2008
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I It is hereby stipulated by and between the parties hereto through their respective
2 counsel as follows:
3 1. Defendants disclosed certain potential witnesses in their initial dilclosures.
4 Some of the disclosed individuals are employees and some are independent
5 contractors, This stipulation is to confinn the parties' agreement regarding the
6 disclosure of contact infonnation for witnesses and independent (ontmctOrS
7 who leave County employment or service during pendency ofthil case.
8 2. Defendants shall disclose to Plaintiff, David F. Jadwin, D,O. the last known
9 address and phone munber of any employee who leaves COlmty employment
10 Or service during pendency ofthis case within 5 court days of the date of their
11 last service to the County. In some cases, the last Imown address may be a
12 residence address. In some cases it may be a business address. Tile COWlty'S
13 obligation is to provide Plaintiff with the last known address mosl.likc1y to
14 result in communication with the individual.
15 3. Plaintiff's cOlmsel and Defendants' counsel shall each accept sen ice by
16 facsimile of all process and notices hereafter served in this mattel: including,
17 with respect to Defendants, on behalf of all employees of Defendl mt County
18 of Kern, prOVided that all process and notices shall also be served by first-
19 class wail.
20 4. Defendant County ofKem shall make cunent employees availabl,~ to Plaintiff
21 for deposition or infonnal interview on reasonable notice by requ'lst to
22 Defendants' counsel.
23 5. Unless previously disclosed, Defendants shall disclose the currenl address of
24 any individual identified in Defendants' initial disclosures who is not an
25 employee of the County of Kern within 20 days of the date of thh Stipulation.
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III
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STlPULAnON RE: CONTACT INFORMAnON FOR WITNESSES
DISCLOSED TN THE TNITIAL DISCLOSURES
NOV-02-2007 FRI 08:25 AM USDC CAED BAKERSFIELD FAX NO, 6613274921 p, 04
Case 1:07-cv-00026-OWW-TAG Document 75 Filed 11/02/2007 Page 3 of 3
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3 By: lsi Eugene D. Lee (as authorized on 1L #1/-"-07L.L-_---I
Eugene D. Lee
4 Attorney for Plaintiff, David F. Jadwin D.O.
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6 Dated: November 1, 2007 LAW OFHCES OF MARK A. WASSER
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8 By: lsi Mark A. Wasser
Mark A. Wasser
9 Attorney for Defendants, COI.)l1!y ofKem, et al.
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12 ORDER
13 The parties having stipulated as hereinabove set forth and good CaUse appearing
therefore;
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15 IT IS SO ORDERED.
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Dated: November 1:.-, 2007
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18 T e Honorable TI e a A. Goldner
United States Mist ate Judge
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