Free Motion to Compel - District Court of California - California

Case 3:07-cv-05756-SI

Document 98

Filed 08/04/2008

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SAMUEL BERNARD JOHNSON III 4420 Abruzzi Circle Stockton, California 95206 (209) 982-5904 ­ Telephone [email protected] ­ Email Plaintiff - In Pro Se

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION

SAMUEL BERNARD JOHNSON III, Plaintiff, vs. CHEVRON CORPORATION, a Delaware corporation, CHEVRON ENVIRONMENTAL MANAGEMENT COMPANY, a California corporation, and DOES 1-10, inclusive Defendants

Case No.: C 07-05756 SI (JSC) PLAINTIFF'S MOTION TO COMPEL DISCOVERY FROM DEFENDANTS CHEVRON CORPORATION, CHEVRON ENVIRONMENTAL MANAGEMENT COMPANY, THEIR ATTORNEY OF RECORD AND REQUEST FOR SANCTIONS DATE: Friday, September 12, 2008 TIME: 9:30 a.m. COURTROOM: A, 15th Floor JUDGE: Hon. Magistrate Joseph C. Spero

PLAINTIFF'S MOTION TO COMPEL DISCOVERY FROM DEFENDANTS, CASE NO. C 07-05756 SI (JCS)

Case 3:07-cv-05756-SI

Document 98

Filed 08/04/2008

Page 2 of 2

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Samuel Bernard Johnson III, (hereinafter referred to as "Plaintiff Johnson") hereby moves the Court for an order to to compel discovery from Defendants Chevron Corporation, Chevron Environmental Management Company, Their Attorney of Record and Request for Sanctions. The Order is needed in order for Defendants Chevron Corporation, Chevron Environmental Management Company and their attorney of record to produce discovery that will lead to admissible evidence in this action as well as will assist the parties in calculating damages. Pursuant to the Honorable Magistrate Judge Joseph C. Spero's July 29, 2008, Order Plaintiff Johnson is providing an explanation as to why the withheld discovery as referenced in his July 10, July 15 and July 16, 2008, letter briefs to the Court should be compelled to be produced from the Defendants Chevron Corporation, Chevron Environmental Management Company and their attorney of record in this action. Given the breadth of withheld discovery, nearly twenty-five discovery requests, responses and supplemental and amended responses this motion is the best vehicle to address this discovery dispute to the Court. /s/ Dated this 4th day of August 2008 SAMUEL BERNARD JOHNSON III

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PLAINTIFF'S MOTION TO COMPEL DISCOVERY FROM DEFENDANTS, CASE NO. C 07-05756 SI (JCS)