The following excerpt is from Ramone v. U.S. Postal Serv., Case No.: 1:17-cv-0825 - JLT (E.D. Cal. 2019):
1. Plaintiffs' counsel repeatedly referenced the fact that there was delay in obtaining the medical records. However, he offered no explanation why the plaintiffs were unable to obtain a copy of the notes by simply asking for them at the time of the medical contact or soon after or why a statement of the Ramones explaining what occurred at the medical visit could not have been submitted. See, e.g., Blair v. I.R.S., 304 F.3d 861, 866 (9th Cir. 2002).
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