345 P Prop Joint Stmt Of Case Corrected
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Case 1:07-cv-00026-OWW-DLB
1 2 3 4 5 6 7 8 9 10
Document 345
Filed 05/11/2009
Page 1 of 3
LAW OFFICE OF EUGENE LEE Eugene D. Lee (SB#: 236812) 555 West Fifth Street, Suite 3100 Los Angeles, CA 90013 Phone: (213) 992-3299 Fax: (213) 596-0487 email: [email protected] Joan Herrington, SB# 178988 BAY AREA EMPLOYMENT LAW OFFICE 5032 Woodminster Lane Oakland, CA 94602-2614 Telephone: (510) 530-4078 Facsimile: (510) 530-4725 Email: [email protected] Of Counsel to LAW OFFICE OF EUGENE LEE Attorneys for Plaintiff DAVID F. JADWIN, D.O.
11
UNITED STATES DISTRICT COURT
12
EASTERN DISTRICT OF CALIFORNIA
13 14
DAVID F. JADWIN, D.O.
15 16 17 18 19 20
Plaintiff, vs. COUNTY OF KERN, Defendant.
Case No.: 1:07-cv-00026-OWW-DLB PLAINTIFF’S CORRECTED PROPOSED NEUTRAL JOINT STATEMENT OF CASE DATE: May 8, 2009 TIME: 12:00 p.m. CRTM: U.S. District Court, Courtroom 3 2500 Tulare Street, Fresno, CA Date Action Filed: January 6, 2007
21 22 23 24 25 26 27 28
PLAINTIFF’S CORRECTED PROPOSED NEUTRAL JOINT STATEMENT OF CASE
1
Case 1:07-cv-00026-OWW-DLB
1 2 3
Document 345
Filed 05/11/2009
Page 2 of 3
Plaintiff submits the following *corrected* proposed joint statement of the case for use in jury selection. PLAINTIFF’S PROPOSED NEUTRAL JOINT STATEMENT OF CASE
4
In October 2000, Defendant County of Kern hired Plaintiff Dr. David Jadwin, a
5
pathologist, to be the Chairman of the Department of Pathology at Kern Medical Center. The
6
County employed him for seven years until October 2007.
7
Dr. Jadwin claims he suffered from severe depression for nine months from December
8
2005 to September 2006. Beginning December 2005, Dr. Jadwin went on a part-time medical
9
leave of absence for his claimed severe depression, working part-time at the hospital and doing
10
some work from home. Dr. Jadwin claims the County interfered with his medical leave by
11
ordering him onto full-time leave in April 2006. He claims he would have been able to continue
12
doing his job while recovering from his claimed depression if the County had allowed him to
13
continue the part-time work schedule and work-from-home arrangement. The County claims it
14
properly accommodated Dr. Jadwin by approving a modified work schedule. The County also
15
denies any interference and claims it approved every leave request Dr. Jadwin made.
16
The County demoted Dr. Jadwin from chair of the Department of Pathology in July 2006,
17
placed him on paid administrative leave in December 2006, and did not renew his employment
18
agreement which expired in October 2007. Dr. Jadwin claims the County did these things, as
19
well as forcing him onto full-time leave in April 2006, in discrimination against his mental
20
disability and in retaliation for his medical leaves. The County claims it did these things because
21
Dr. Jadwin was not present at the hospital and refused to return to work full-time.
22
Dr. Jadwin claims that he had a right to active duty, but that the County violated his
23
Constitutional due process rights by placing him on administrative leave for 10 months from
24
December 6, 2006 to October 4, 2007, without telling him what the charges were against him or
25
letting him respond. The County believes all of its actions toward Dr. Jadwin were legal and
26
authorized by the County’s personnel rules.
27 28
During Dr. Jadwin’s employment, disputes arose between him and members of the medical staff at Kern Medical Center. Dr. Jadwin claims those disputes arose in response to the
PLAINTIFF’S CORRECTED PROPOSED NEUTRAL JOINT STATEMENT OF CASE
2
Case 1:07-cv-00026-OWW-DLB
Document 345
Filed 05/11/2009
Page 3 of 3
1
patient care problems at the hospital that he was complaining of. The County claims Dr. Jadwin
2
caused the disputes himself by his conduct towards other members of the hospital staff.
3 4
Plaintiff is requesting monetary compensation for his lost wages and benefits, emotional distress, expenses, and other relief.
5 6 7
Dated: May 11, 2009.
10
/s/ Eugene D. Lee SB# 236812 LAW OFFICE OF EUGENE LEE 555 West Fifth Street, Suite 3100 Los Angeles, California 90013 Telephone: (213) 992-3299 Facsimile: (213) 569-0487 Email: [email protected]
11
Attorney for Plaintiff DAVID F. JADWIN, D.O.
8 9
12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
PLAINTIFF’S CORRECTED PROPOSED NEUTRAL JOINT STATEMENT OF CASE
3
1 2 3 4 5 6 7 8 9 10
Document 345
Filed 05/11/2009
Page 1 of 3
LAW OFFICE OF EUGENE LEE Eugene D. Lee (SB#: 236812) 555 West Fifth Street, Suite 3100 Los Angeles, CA 90013 Phone: (213) 992-3299 Fax: (213) 596-0487 email: [email protected] Joan Herrington, SB# 178988 BAY AREA EMPLOYMENT LAW OFFICE 5032 Woodminster Lane Oakland, CA 94602-2614 Telephone: (510) 530-4078 Facsimile: (510) 530-4725 Email: [email protected] Of Counsel to LAW OFFICE OF EUGENE LEE Attorneys for Plaintiff DAVID F. JADWIN, D.O.
11
UNITED STATES DISTRICT COURT
12
EASTERN DISTRICT OF CALIFORNIA
13 14
DAVID F. JADWIN, D.O.
15 16 17 18 19 20
Plaintiff, vs. COUNTY OF KERN, Defendant.
Case No.: 1:07-cv-00026-OWW-DLB PLAINTIFF’S CORRECTED PROPOSED NEUTRAL JOINT STATEMENT OF CASE DATE: May 8, 2009 TIME: 12:00 p.m. CRTM: U.S. District Court, Courtroom 3 2500 Tulare Street, Fresno, CA Date Action Filed: January 6, 2007
21 22 23 24 25 26 27 28
PLAINTIFF’S CORRECTED PROPOSED NEUTRAL JOINT STATEMENT OF CASE
1
Case 1:07-cv-00026-OWW-DLB
1 2 3
Document 345
Filed 05/11/2009
Page 2 of 3
Plaintiff submits the following *corrected* proposed joint statement of the case for use in jury selection. PLAINTIFF’S PROPOSED NEUTRAL JOINT STATEMENT OF CASE
4
In October 2000, Defendant County of Kern hired Plaintiff Dr. David Jadwin, a
5
pathologist, to be the Chairman of the Department of Pathology at Kern Medical Center. The
6
County employed him for seven years until October 2007.
7
Dr. Jadwin claims he suffered from severe depression for nine months from December
8
2005 to September 2006. Beginning December 2005, Dr. Jadwin went on a part-time medical
9
leave of absence for his claimed severe depression, working part-time at the hospital and doing
10
some work from home. Dr. Jadwin claims the County interfered with his medical leave by
11
ordering him onto full-time leave in April 2006. He claims he would have been able to continue
12
doing his job while recovering from his claimed depression if the County had allowed him to
13
continue the part-time work schedule and work-from-home arrangement. The County claims it
14
properly accommodated Dr. Jadwin by approving a modified work schedule. The County also
15
denies any interference and claims it approved every leave request Dr. Jadwin made.
16
The County demoted Dr. Jadwin from chair of the Department of Pathology in July 2006,
17
placed him on paid administrative leave in December 2006, and did not renew his employment
18
agreement which expired in October 2007. Dr. Jadwin claims the County did these things, as
19
well as forcing him onto full-time leave in April 2006, in discrimination against his mental
20
disability and in retaliation for his medical leaves. The County claims it did these things because
21
Dr. Jadwin was not present at the hospital and refused to return to work full-time.
22
Dr. Jadwin claims that he had a right to active duty, but that the County violated his
23
Constitutional due process rights by placing him on administrative leave for 10 months from
24
December 6, 2006 to October 4, 2007, without telling him what the charges were against him or
25
letting him respond. The County believes all of its actions toward Dr. Jadwin were legal and
26
authorized by the County’s personnel rules.
27 28
During Dr. Jadwin’s employment, disputes arose between him and members of the medical staff at Kern Medical Center. Dr. Jadwin claims those disputes arose in response to the
PLAINTIFF’S CORRECTED PROPOSED NEUTRAL JOINT STATEMENT OF CASE
2
Case 1:07-cv-00026-OWW-DLB
Document 345
Filed 05/11/2009
Page 3 of 3
1
patient care problems at the hospital that he was complaining of. The County claims Dr. Jadwin
2
caused the disputes himself by his conduct towards other members of the hospital staff.
3 4
Plaintiff is requesting monetary compensation for his lost wages and benefits, emotional distress, expenses, and other relief.
5 6 7
Dated: May 11, 2009.
10
/s/ Eugene D. Lee SB# 236812 LAW OFFICE OF EUGENE LEE 555 West Fifth Street, Suite 3100 Los Angeles, California 90013 Telephone: (213) 992-3299 Facsimile: (213) 569-0487 Email: [email protected]
11
Attorney for Plaintiff DAVID F. JADWIN, D.O.
8 9
12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
PLAINTIFF’S CORRECTED PROPOSED NEUTRAL JOINT STATEMENT OF CASE
3
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