Вы находитесь на странице: 1из 2

Case 1:07-cv-00026-OWW-TAG Document 60 Filed 10/12/2007 Page 1 of 2

1 Mark A. Wasser CA SB #060160


LAW OFFICES OF MARK A. WASSER
2 400 Capitol Mall, Suite 1100
Sacramento, CA 95814
3 Phone: (916) 444-6400
Fax: (916) 444-6405
4 E-mail: ~~~aill1~~~t:&Q'ill
5 Bernard C. Barmann, Sr.
KERN COUNTY COUNSEL
6 Mark Nations, ChiefDeputy
1115 Truxton Avenue, Fourth Floor
7 Bakersfield, CA 93301
Phone: (661) 868-3800
8 Fax: (661) 868-3805
E-mail: mnations@co.kern.ca.us
9
10 Attorneys for Defendants County of Kern,
Peter Bryan, Irwin Harris, Eugene Kercher,
11 Jennifer Abraham, Scott Ragland, Toni Smith
and William Roy
12

13 UNITED STATES DISTRICT COURT


14 EASTERN DISTRICT OF CALIFORNIA
15
16 DAVID F. JADWIN, D.O. ) Case No.: 1:07-cv-00026-0WW-TAG
)
17 Plaintiff, ) DECLARATION OF TONI SMITH IN
) SUPPORT OF MOTION FOR
18 vs. ) PROTECTIVE ORDER RE:
) EMPLOYEES' HOME ADDRESSES
19 COUNTY OF KERN, et aI., )
) Date: November 5, 2007
20 Defendants. ) Time: 9:30 a.m.
) Place: U.S. Bankruptcy Courthouse,
21 ) Bakersfield Courtroom 8
)
22 ) Date Action Filed: January 6, 2007
) Trial Date: August 26, 2008
23
24
I, Toni Smith, declare as follows:
25
1. I am a registered nurse and am employed by the County of Kern and work at Kern
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.

1 DECLARATION OF TONI SMITH I


SUPPORT OF MOTION FOR PROTECTIVE ORDE
Case 1:07-cv-00026-OWW-TAG Document 60 Filed 10/12/2007 Page 2 of 2

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

2 lawsuit arose in the workplace and are work-related. None of them involve my personal life.

3 My personal privacy and safety are important to me. I am available at my work address to be

4 contacted in connection with this case and there is no reason to contact me at my home. I do not

5 want my home address disclosed to Dr. Jadwin.

6 4. These facts are within my own personal knowledge and I can testify competently
7 to them.

8 I certify under penalty of perjury that the foregoing is true and correct.
9 Executed this day of October, 2007, in Bakersfield, California.
10

11 By: _
Toni Smith
12

13

14

15
16

17

18

19

20

21

22

23

24

25
26
27

28

2 DECLARATION OF TONI SMITH I


SUPPORT OF MOTION FOR PROTECTIVE ORDE