60 Mx Protective Order - Smitht Declaration
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Case 1:07-cv-00026-OWW-TAG
1 2 3 4 5 6 7 8
Document 60
Filed 10/12/2007
Page 1 of 2
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: ~~~aill1~~~t:&Q'ill Bernard C. Barmann, Sr. KERN COUNTY COUNSEL Mark Nations, ChiefDeputy 1115 Truxton Avenue, Fourth Floor Bakersfield, CA 93301 Phone: (661) 868-3800 Fax: (661) 868-3805 E-mail: [email protected]
9 10 11
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.
) Case No.: 1:07-cv-00026-0WW-TAG )
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Plaintiff, vs. COUNTY OF KERN, et aI.,
20
Defendants.
21
) ) ) )
DECLARATION OF TONI SMITH IN SUPPORT OF MOTION FOR PROTECTIVE ORDER RE: EMPLOYEES' HOME ADDRESSES
)
) ) ) )
Date: November 5, 2007 Time: 9:30 a.m. Place: U.S. Bankruptcy Courthouse, Bakersfield Courtroom 8
)
22
) Date Action Filed: January 6, 2007 ) Trial Date: August 26, 2008
23 24 I, Toni Smith, declare as follows: 25 1.
I am a registered nurse and am employed by the County of Kern and work at Kern
26 Medical Center. I am one of the defendants in this action and I understand that I may be a 27 witness. I know Dr. David Jadwin and worked with him when he was in the pathology lab at 28
Kern Medical Center. 1
DECLARATION OF TONI SMITH I SUPPORT OF MOTION FOR PROTECTIVE ORDE
Case 1:07-cv-00026-OWW-TAG
1
2.
Document 60
Filed 10/12/2007
Page 2 of 2
I object to disclosure of my home address to Dr. Jadwin. All of the issues in this
2
lawsuit arose in the workplace and are work-related. None of them involve my personal life.
3
My personal privacy and safety are important to me. I am available at my work address to be
4
contacted in connection with this case and there is no reason to contact me at my home. I do not
5
want my home address disclosed to Dr. Jadwin.
6 7
4.
These facts are within my own personal knowledge and I can testify competently
to them.
8
I certify under penalty of perjury that the foregoing is true and correct.
9
Executed this
day of October, 2007, in Bakersfield, California.
10
11 12
By:
_ Toni Smith
13 14
15 16 17 18 19 20 21 22 23 24
25
26 27 28
2
DECLARATION OF TONI SMITH I SUPPORT OF MOTION FOR PROTECTIVE ORDE
1 2 3 4 5 6 7 8
Document 60
Filed 10/12/2007
Page 1 of 2
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: ~~~aill1~~~t:&Q'ill Bernard C. Barmann, Sr. KERN COUNTY COUNSEL Mark Nations, ChiefDeputy 1115 Truxton Avenue, Fourth Floor Bakersfield, CA 93301 Phone: (661) 868-3800 Fax: (661) 868-3805 E-mail: [email protected]
9 10 11
Attorneys for Defendants County of Kern, Peter Bryan, Irwin Harris, Eugene Kercher, Jennifer Abraham, Scott Ragland, Toni Smith and William Roy
12 13
UNITED STATES DISTRICT COURT
14
EASTERN DISTRICT OF CALIFORNIA
15 16
DAVID F. JADWIN, D.O.
) Case No.: 1:07-cv-00026-0WW-TAG )
17 18 19
Plaintiff, vs. COUNTY OF KERN, et aI.,
20
Defendants.
21
) ) ) )
DECLARATION OF TONI SMITH IN SUPPORT OF MOTION FOR PROTECTIVE ORDER RE: EMPLOYEES' HOME ADDRESSES
)
) ) ) )
Date: November 5, 2007 Time: 9:30 a.m. Place: U.S. Bankruptcy Courthouse, Bakersfield Courtroom 8
)
22
) Date Action Filed: January 6, 2007 ) Trial Date: August 26, 2008
23 24 I, Toni Smith, declare as follows: 25 1.
I am a registered nurse and am employed by the County of Kern and work at Kern
26 Medical Center. I am one of the defendants in this action and I understand that I may be a 27 witness. I know Dr. David Jadwin and worked with him when he was in the pathology lab at 28
Kern Medical Center. 1
DECLARATION OF TONI SMITH I SUPPORT OF MOTION FOR PROTECTIVE ORDE
Case 1:07-cv-00026-OWW-TAG
1
2.
Document 60
Filed 10/12/2007
Page 2 of 2
I object to disclosure of my home address to Dr. Jadwin. All of the issues in this
2
lawsuit arose in the workplace and are work-related. None of them involve my personal life.
3
My personal privacy and safety are important to me. I am available at my work address to be
4
contacted in connection with this case and there is no reason to contact me at my home. I do not
5
want my home address disclosed to Dr. Jadwin.
6 7
4.
These facts are within my own personal knowledge and I can testify competently
to them.
8
I certify under penalty of perjury that the foregoing is true and correct.
9
Executed this
day of October, 2007, in Bakersfield, California.
10
11 12
By:
_ Toni Smith
13 14
15 16 17 18 19 20 21 22 23 24
25
26 27 28
2
DECLARATION OF TONI SMITH I SUPPORT OF MOTION FOR PROTECTIVE ORDE
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