Re: Timothy Cox v. R.J. Reynolds Tobacco Company, Inc., et al. (KC068943)

MOTION TO COMPEL PRODUCTION OF DOCUMENTS AND RESPONSES TO PLAINTIFF’S REQUEST FOR PRODUCTION OF DOCUMENTS, SET ONE

Moving Party: Plaintiff Timothy Cox

Respondents: Defendants R.J. Reynolds Tobacco Company, Inc., et al.

POS: Moving OK; Opposing served by regular mail contrary to CCP § 1005(c); Reply timely only for the 11/28/17 continued hearing date

Plaintiff alleges that, following his complaints to management relating to various Labor Code and FEHA violations, he was reprimanded, demoted and ultimately terminated. The complaint was filed 12/22/16. The First Amended Complaint, filed 12/27/16, asserts causes of action against Defendants R.J. Reynolds Tobacco Company, Inc., Reynolds American, Inc., Tasha Kolbe, Staci Meyer and Does 1-50 for:

On 2/15/17, the case was removed to federal court. On 6/8/17, an “Order re Plaintiff’s Ex Parte Application for an Order to Dismiss Federal Claims and Remand State Claim