60 Mx Protective Order - SmithT Declaration by eugenedlee

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

Document 60

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: ~~~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: mnations@co.kern.ca.us Attorneys for Defendants County of Kern, Peter Bryan, Irwin Harris, Eugene Kercher, Jennifer Abraham, Scott Ragland, Toni Smith and William Roy UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA

DAVID F. JADWIN, D.O. Plaintiff, vs. COUNTY OF KERN, et aI., Defendants.

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

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) Date Action Filed: January 6, 2007 ) Trial Date: August 26, 2008

I, Toni Smith, declare as follows: 25 1. 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.
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DECLARATION OF TONI SMITH I SUPPORT OF MOTION FOR PROTECTIVE ORDE

I am a registered nurse and am employed by the County of Kern and work at Kern

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

Document 60

Filed 10/12/2007

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I object to disclosure of my home address to Dr. Jadwin. All of the issues in this

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lawsuit arose in the workplace and are work-related. None of them involve my personal life. My personal privacy and safety are important to me. I am available at my work address to be contacted in connection with this case and there is no reason to contact me at my home. I do not want my home address disclosed to Dr. Jadwin. 4. to them. These facts are within my own personal knowledge and I can testify competently

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I certify under penalty of perjury that the foregoing is true and correct.
Executed this day of October, 2007, in Bakersfield, California.

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By: Toni Smith

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DECLARATION OF TONI SMITH I SUPPORT OF MOTION FOR PROTECTIVE ORDE


								
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