61 Mx Protective Order - Burrism Declaration

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

Document 61

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, vs. COUNTY OF KERN, et aI.,

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Defendants.

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) ) DECLARATION OF MICHELLE BURRI ) IN SUPPORT OF MOTION FOR

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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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) Case No.: 1:07-cv-00026-0WW-TAG

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, Michelle Burris, declare as follows:

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I am employed by the County of Kern and work at Kern Medical Center as a

supervising clinical lab scientist. I know Dr. David Jadwin and worked with him when he was a pathologist at Kern Medical Center.

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DECLARATION OF MICHELLE BURRIS SUPPORT OF MOTION FOR PROTECTIVE ORDE

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

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Document 61

Filed 10/12/2007

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I know about the lawsuit Dr. Jadwin has filed against the County and others and

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understand that I may be a witness in the case. To my knowledge, the lawsuit involves work-

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related claims that arose out of Dr. Jadwin's employment and behavior at Kern Medical Center.

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3.

I object to disclosure of my home address to Dr. Jadwin. My personal life is

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separate and private from my professional life as a County employee. I am available at my work

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address to be contacted in connection with this case and there is no reason to contact me at my

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home. I am a private person and I value my privacy. I do not want my home address disclosed.

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

to them.

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

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Executed this -=...1"-- day of October, 2007, in Bakersfield, California.

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DECLARATION OF MICHELLE BURRIS SUPPORT OF MOTION FOR PROTECTIVE ORDE