62 mx protective order - longd declaration

Upload: eugene-d-lee

Post on 30-May-2018

219 views

Category:

Documents


0 download

TRANSCRIPT

  • 8/14/2019 62 Mx Protective Order - LongD Declaration

    1/2

    Case 1:07-cv-00026-OWW-TAG Document 62 Filed 10/12/2007 Page 1 of 2

    1 Mark A. Wasser CA SB #060160LA W OFFICES OF MARK A. WASSER

    2 400 Capitol Mall, Suite 1100Sacramento, CA 95814

    3 Phone: (916) 444-6400Fax: (916) 444-6405

    4 E-mail: [email protected] Bernard C. Barmann, Sr.

    KERN COUNTY COUNSEL6 Mark Nations, ChiefDeputy

    1115 Truxton Avenue, Fourth Floor7 Bakersfield, CA 93301

    Phone: (661) 868-38008 Fax: (661) 868-3805

    E-mail: [email protected]

    10 Attorneys 'for Defendants County of Kern,Peter Bryan, Irwin Harris, Eugene Kercher,

    11 Jennifer Abraham, Scott Ragland, Toni Smithand William Roy .

    19 COUNTY OF KERN, et al.,

    ) Case No.: 1:07-cv-00026-0WW-TAG)) DECLARATION OF DENISE LONG 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 Cour troom 8)) Date Action Filed: January 6, 2007) Trial Date: August 26, 2008

    UNITED STATES DISTRICT COURT

    EASTERN DISTRICT OF CALIFORNIA

    21

    22

    23

    18 vs.

    20 Defendants.

    12

    13

    14

    15

    16 DAVID F. JADWIN, D.O.

    17 Plaintiff,

    2425

    26

    27

    28

    I, Denise Long, declare as follows:

    1. I am employed by the County of Kern and work in the County Administrative

    Office as a budget analyst. I used to work at Kern Medical Center and I know Dr. David Jadwin

    and worked with him when he was a pathologist at Kern Medical Center.

    1 DECLARATION OF DENISE LONG ISUPPORT OF MOTION FOR PROTECTIVE ORDE

  • 8/14/2019 62 Mx Protective Order - LongD Declaration

    2/2

    Case 1:07-cv-00026-OWW-TAG Document 62 Filed 10/12/2007 Page 2 of 2

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

    2 understand that I may be a witness in the case. To my knowledge, the lawsuit involves work-

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

    4 3. I object to disclosure of my home address. My personal life is separate and5 private from my professional life as a County employee. I am available at my work address to

    6 be contacted in connection with this case and there is no reason to contact me at my home. I

    7 val';le my privacy when I am away from work and I do not want my home address disclosed to

    8 Dr. Jadwin.

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

    10 to them.

    11 I certify under penalty of perjury that the foregoing is true and correct.

    12

    13

    14

    15

    16

    17

    18

    19

    20

    21

    22

    23

    2425

    26

    27

    28

    Executed this ~ day of October, 2007, in Bakersfield, California.

    By: A 1 u : u ~ r n : J- _D e n i s e ~

    2 DECLARATION OF DENISE LONGSUPPORT OF MOTION FOR PROTECTIVE ORDE