Free Memorandum in Opposition - District Court of California - California

Case 3:07-cv-03165-CRB

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Filed 08/12/2008

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1 EDMUND G. BROWN JR. Attorney General of the State of California 2 PAUL T. HAMMERNESS Supervising Deputy Attorney General 3 JENNIFER C. ADDAMS, State Bar No. 209355 Deputy Attorney General 455 Golden Gate Avenue, Suite 11000 4 San Francisco, CA 94102-7004 Telephone: (415) 703-5382 5 Facsimile: (415) 703-5480 Email: [email protected] 6 7 Attorneys for Defendants J. Chudy, M.D.; D. Pompan, M.D.; and I. Grewal, M.D. 8 9 10 11 12 13 14 15 16 17 18 19 20 I, Jennifer C. Addams, declare: 1. I am a Deputy Attorney General for the State of California and attorney of record for v. JOSEPH CHUDY, et al., Defendants. RAYNARD B. HILL, JR., Plaintiff, Case No. C 07-3165-CRB (PR) DECLARATION OF JENNIFER C. ADDAMS IN SUPPORT OF OPPOSITION TO PLAINTIFF'S MOTION TO COMPEL RESPONSES TO REQUEST FOR ADMISSIONS Hearing: None The Honorable Charles R. Breyer IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF CALIFORNIA

21 defendants J. Chudy, M.D., D. Pompan, M.D., and I. Grewal, M.D. If called upon to testify, I 22 could and would competently testify as to the facts within this declaration, based on my personal 23 knowledge. 24 2. On June 10, 2008, I received plaintiff Raynard B. Hill's Request for Admissions

25 Propounded Upon the Defendants. These requests were not specifically directed toward any one 26 individual. 27 /// 28 ///
Dec of Jennifer Addams in Support of Opposition to Motion to Compel HILL, Raynard B. v. Joseph Chudy, et al. C 07-3165-CRB (PR)

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Case 3:07-cv-03165-CRB

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3.

On June 16, 2008, I filed a motion for a protective order requesting that the court order

2 stay discovery until after the motion for summary judgment was ruled upon. On July 7, 2008, 3 the court denied this motion. 4 4. I immediately prepared responses to plaintiff's discovery. Because the discovery was

5 not specifically directed to one defendant, I contacted Defendant J. Chudy, M.D., to respond 6 because, as the Medical Director, I believed him to have information that would be the most 7 relevant to the plaintiff. 8 5. Although the requests were compound and not directed to any one individual, instead

9 of objecting to the entire set as a whole, I worked with Dr. Chudy to respond completely to the 10 intelligible requests. I did this because I did not want to hinder the briefing schedule for the 11 motion for summary judgment. 12 6. A true and correct copy of Defendant Dr. Chudy's Responses to Plaintiff's Request for

13 Admissions is attached hereto and incorporated herein as Exhibit A. 14 7. I never received any attempt by plaintiff to meet and confer regarding any alleged

15 inadequacies in Dr. Chudy's responses to his request for admissions. 16 I declare under penalty of perjury under the laws of the State of California that the

17 foregoing is true and accurate. 18 19 20 21 22 23 24 25 26 27 28
Dec of Jennifer Addams in Support of Opposition to Motion to Compel HILL, Raynard B. v. Joseph Chudy, et al. C 07-3165-CRB (PR)
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Executed this 12th day of August, 2008, at San Francisco, California.

/s/ Jennifer C. Addams

_________________________________ Jennifer C. Addams

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DECLARATION OF SERVICE BY U.S. MAIL

Case Name: No.

HILL, Raynard B. v. Joseph Chudy, et al.

C 07-3165-CRB (PR)

I declare: I am employed in the Office of the Attorney General, which is the office of a member of the California State Bar, at which member's direction this service is made. I am 18 years of age or older and not a party to this matter. I am familiar with the business practice at the Office of the Attorney General for collection and processing of correspondence for mailing with the United States Postal Service. In accordance with that practice, correspondence placed in the internal mail collection system at the Office of the Attorney General is deposited with the United States Postal Service that same day in the ordinary course of business. On August 12, 2008, I served the attached DECLARATION OF JENNIFER C. ADDAMS IN SUPPORT OF OPPOSITION TO PLAINTIFF'S MOTION TO COMPEL RESPONSES TO REQUEST FOR ADMISSIONS, Exhibit A, by placing a true copy thereof enclosed in a sealed envelope with postage thereon fully prepaid, in the internal mail collection system at the Office of the Attorney General at 455 Golden Gate Avenue, Suite 11000, San Francisco, CA 94102-7004, addressed as follows:

Raynard B. Hill, Jr. H-43428 California Substance Abuse Treatment Facility F3-B-126 Low P.O. Box 7100 Corcoran, CA 93212-7100

I declare under penalty of perjury under the laws of the State of California the foregoing is true and correct and that this declaration was executed on August 12, 2008, at San Francisco, California.

C. Deuel Declarant

/s/ C. Deuel Signature

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