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1 No. 3:09-cv-02292-VRW Objector Doug Swardstrom's Administrative Motion To Permit Out-of-State Counsel To Appear by Telephone
1 No. 3:09-cv-02292-VRW Objector Doug Swardstrom's Administrative Motion To Permit Out-of-State Counsel To Appear by Telephone
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Telephone: (916) 388-0833
HICKS THOMAS LLP
1 Pursuant to Civil L.R. 7-11 (Motion for Administrative Relief), Objector Doug Sward-
2 strom respectfully requests permission for his out-of-state counsel James Bopp, Jr. to appear by
4 with a deposition subpoena. In support of his request, Mr. Swardstrom would show the following:
7 2. Although the undersigned local counsel intends to appear at the hearing on such
8 motion, Mr. Bopp is Mr. Swardstrom’s principal counsel, and he desires to present argument on
9 Mr. Swardstrom’s behalf at such hearing. See Declaration of James Bopp, Jr. (“Bopp Decl.”) ¶ 2
11 3. Also on Monday, January 4, 2010, the Court set relevant hearing for Wednesday,
8001 Folsom Boulevard, Suite 100
Sacramento, California 95826
12 January 6, 2010, at 10:00 a.m. See Doc. # 333 at 2. Mr. Bopp learned of the newly set hearing
Telephone: (916) 388-0833
HICKS THOMAS LLP
13 date at approximately 7:00 p.m. Eastern time on Monday the 4th. See Bopp Decl. ¶ 3.
14 4. Given such short notice, neither Mr. Bopp nor any of his law firm colleagues was
15 able to make arrangements to travel to San Francisco from their offices in Terre Haute, Indiana
17 5. Mr. Bopp’s direct telephone number for the time of the hearing is (812) 243-0825.
18 For these reasons, Objector Doug Swardstrom respectfully requests permission for his out-
19 of-state counsel James Bopp, Jr. to appear by telephone at tomorrow’s hearing on Plaintiffs’ mo-
22 Respectfully submitted,
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Telephone: (916) 388-0833
HICKS THOMAS LLP
4 to Compel, filed concurrently herewith. I make the statements of fact in this declaration of my
5 own personal knowledge. If called as a witness in this proceeding, I could and would competently
7 2. Having been retained to represent Mr. Swardstrom only today, and having spent
8 the afternoon preparing Mr. Swardstrom’s opposition to Plaintiffs’ motion to compel, I was unable
9 to turn to the instant administrative motion until after 5:00 p.m. today. Given that such motion
10 involves a hearing set for tomorrow morning at 10:00 a.m., I did not think it possible to obtain,
11 nor reasonable to attempt to obtain, the stipulation referred to in Civil L.R. 7-11(a) prior to filing
8001 Folsom Boulevard, Suite 100
Sacramento, California 95826
13 I declare under penalty of perjury under the laws of the United States of America that the
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{00134111.DOC} 2 No. 3:09-cv-02292-VRW
Declaration of Eric Grant in Support of Objector Doug Swardstrom’s Administrative Motion
Case3:09-cv-02292-VRW Document352-2 Filed01/05/10 Page1 of 2
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Telephone: (916) 388-0833
HICKS THOMAS LLP
4 to Compel, filed concurrently herewith. I make the statements of fact in this declaration of my
5 own personal knowledge. If called as a witness in this proceeding, I could and would competently
8 behalf at the hearing on Plaintiffs’ motion to compel Mr. Swardstrom’s compliance with a depo-
9 sition subpoena.
10 3. On Monday, January 4, 2010, the Court set that hearing for Wednesday, January 6,
11 2010, at 10:00 a.m. I learned of the newly set hearing date at approximately 7:00 p.m. Eastern
8001 Folsom Boulevard, Suite 100
Sacramento, California 95826
13 4. Given such short notice, neither I nor any of my law firm colleagues was able to
14 make arrangements to travel to San Francisco from our offices in Terre Haute, Indiana to appear
16 I declare under penalty of perjury under the laws of the United States of America that the
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{00134111.DOC} 2 No. 3:09-cv-02292-VRW
Declaration of James Bopp, Jr. in Support of Objector Doug Swardstrom’s Administrative Motion
Case3:09-cv-02292-VRW Document352-3 Filed01/05/10 Page1 of 2
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Telephone: (916) 388-0833
HICKS THOMAS LLP
3 WHEREAS, Mr. Swardstrom has established good cause for granting such motion;
5 Jr. shall be permitted to appear by telephone at the hearing on Plaintiffs’ motion to compel set for
8 Date:
10 VAUGHN R. WALKER
United States District Chief Judge
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8001 Folsom Boulevard, Suite 100
Sacramento, California 95826
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Telephone: (916) 388-0833
HICKS THOMAS LLP
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{00134111.DOC} 2 No. 3:09-cv-02292-VRW
Order Granting Objector Doug Swardstrom’s Administrative Motion to Permit Counsel to Appear by Telephone