8/14/2019 59 Mx Protective Order - AbrahamJ Declaration

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8/14/2019 59 Mx Protective Order - AbrahamJ Declaration

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Case 1:07-cv-00026-OWW-TAG Document 59 Filed 10/12/2007 Page 2 of 2

1 unpleasant interactions between him and other hospital staff. I understand that I may be a

2 witness and that Dr. Jadwin has requested my home address.

3 2. In my experience, Dr. Jadwin is emotional, confrontational and arrogant. He has

4 assaulted me verbally on several occasions and he physically assaulted at least one other

5 physician at Kern Medical Center. He tries to intimidate people he thinks are weaker than he is.

6 I do not trust him.

7 3. I do not want Dr. Jadwin to know where I live. All the claims in this lawsuit

8 arose in the workplace and are work-related. They have nothing to do with my personal life or

9 the lives of my children and family members. Personal privacy and safety are of paramount

10 concern to me. I am available at my work address and can be contacted through the County 's

11 legal counsel for any purpose related to this lawsuit. There is no reason to contact me at my

12 home and I object to disclosing my home address to Dr. Jadwin.

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

14 to them i f called as a witness.

15 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

2 DECLARATION OF JENNIFER ABRAHAMSUPPORT OF MOTION FOR PROTECTIVE ORDE