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63 Mx Protective Order - ThorntonJ Declaration

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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.

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

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: 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,

COUNTY OF KERN, et aI.,
Defendants.

) 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

Document 63

Filed 10/12/2007

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2.

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

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. 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 address to be contacted in connection with this case and there is no reason to contact me at my home. Further, having observed Dr. Jadwin's behavior at Kern Medical Center, I know he is a person who can become emotional and confrontational and I would be uncomfortable ifhe had my home address. I do not want my home address disclosed to him. 4. to them. I certify under penalty of perjury that the foregoing is true and correct. Executed this _ _day of October, 2007, in Bakersfield, California. These facts are within my own personal knowledge and I can testify competently

Jane Thornton

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DECLARATION OF JANE THORNTON SUPPORT OF MOTION FOR PROTECTIVE ORDE


								
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