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61 Mx Protective Order - BurrisM Declaration

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

Document 61

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: mwasser@markwasser.com 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: 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

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DAVID F. JADWIN, D.O. Plaintiff,

) Case No.: 1:07-cv-00026-0WW-TAG
) ) DECLARATION OF MICHELLE BURRI ) IN SUPPORT OF MOTION FOR

COUNTY OF KERN, et aI., Defendants.

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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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, Michelle Burris, declare as follows: 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

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

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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 address to be contacted in connection with this case and there is no reason to contact me at my home. I am a private person and I value my privacy. I do not want my home address disclosed.

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

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DECLARATION OF MICHELLE BURRIS SUPPORT OF MOTION FOR PROTECTIVE ORDE


				
DOCUMENT INFO
Description: David F. Jadwin v. Kern County: 1:07-cv-26 in the United Stated District Court for the Eastern District of California, Fresno Division before Judge Oliver W. Wanger. This was a 2009 federal employment lawsuit that went to a bench and jury trial resulting in a unanimous verdict and significant judgment for the plaintiff employee. Issues involved violations of medical leave and disability discrimination laws, as well as 42 U.S.C. 1983 procedural due process violation. Plaintiff was represented by Eugene Lee, a Los Angeles, California employment lawyer.