63 Mx Protective Order - Thorntonj Declaration

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

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Document 63

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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) Case No.: 1:07-cv-00026-0WW-TAG ) ) DECLARATION OF JANE THORNTON ) 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 ) ) Date Action Filed: January 6, 2007 ) Trial Date: August 26, 2008

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--------------_.)

I, Jane Thornton, declare as follows: 1.

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

supervisor of hematology, coagulation and urinalysis in the pathology laboratory. I know Dr. David Jadwin and worked with him when he was a pathologist at Kern Medical Center.

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DECLARATION OF JANE THORNTON SUPPORT OF MOTION FOR PROTECTIVE ORDE

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

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2.

Document 63

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. Further, having observed Dr. Jadwin's behavior at Kern Medical Center, I know he is a

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person who can become emotional and confrontational and I would be uncomfortable ifhe had

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my home address. I do not want my home address disclosed to him.

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4.

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 _ _day of October, 2007, in Bakersfield, California.

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Jane Thornton

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DECLARATION OF JANE THORNTON SUPPORT OF MOTION FOR PROTECTIVE ORDE