59 Mx Protective Order - Abrahamj Declaration

Case 1:07-cv-00026-OWW-TAG

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Document 59

Filed 10/12/2007

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Mark A. Wasser CA SB #060160 LAW OFFICES OF MARK A. WASSER 400 Capitol Mall, Suite 1100 Sacramento, CA 95814 Phone: (916) 444-6400 Fax: (916) 444-6405 E-mail: [email protected] Bernard C. Barmann, Sr. KERN COUNTY COUNSEL Mark Nations, Chief Deputy 1115 Truxton Avenue, Fourth Floor Bakersfield, CA 93301 Phone: (661) 868-3800 Fax: (661) 868-3805 E-mail: [email protected]

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Attorneys for Defendants County of Kern, Peter Bryan, Irwin Harris, Eugene Kercher, Jennifer Abraham, Scott Ragland, Toni Smith and William Roy

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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DAVID F. JADWIN, D.O.

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Plaintiff,

) Case No.: 1:07-cv-00026-0WW-TAG ) ) DECLARATION OF JENNIFER ) ABRAHAM IN SUPPORT OF MOTION

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vs.

COUNTY OF KERN, et aL,

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Defendants.

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FOR PROTECTIVE ORDER RE: EMPLOYEES' HOME ADDRESSES

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Date: November 5, 2007 Time: 9:30 a.m. Place: U.S. Bankruptcy Courthouse, ) Bakersfield Courtroom 8 ) ) Date Action Filed: January 6, 2007 ) Trial Date: August 26, 2008

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---------------)

I, Jennifer Abraham, declare as follows: 25 1.

I am a physician and am employed by the County of Kern at Kern Medical

26 Center. I am one of the defendants in this action and I know Dr. David Jadwin. He and I had 27 several unpleasant interactions while he was working at Kern Medical Center and I witnessed 28

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DECLARATION OF JENNIFER ABRAHAM SUPPORT OF MOTION FOR PROTECTIVE ORDE

Case 1:07-cv-00026-OWW-TAG

Document 59

Filed 10/12/2007

Page 2 of 2

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unpleasant interactions between him and other hospital staff. I understand that I may be a

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witness and that Dr. Jadwin has requested my home address.

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2.

In my experience, Dr. Jadwin is emotional, confrontational and arrogant. He has

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assaulted me verbally on several occasions and he physically assaulted at least one other

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physician at Kern Medical Center. He tries to intimidate people he thinks are weaker than he is.

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I do not trust him.

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3.

I do not want Dr. Jadwin to know where I live. All the claims in this lawsuit

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arose in the workplace and are work-related. They have nothing to do with my personal life or

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the lives of my children and family members. Personal privacy and safety are of paramount

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concern to me. I am available at my work address and can be contacted through the County's

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legal counsel for any purpose related to this lawsuit. There is no reason to contact me at my

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home and I object to disclosing my home address to Dr. Jadwin.

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4.

These facts are within my own personal knowledge and I can testify competently

to them if called as a witness.

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I certify under penalty of perjury that the foregoing is true and correct.

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Executed this _-,--_ day of October, 2007 in Bakersfield, California

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DECLARATION OF JENNIFER ABRAHAM SUPPORT OF MOTION FOR PROTECTIVE ORDE