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
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10 Attorneys for Defendants County of Kern,
Peter Bryan, Irwin Harris, Eugene Kercher,
11 Jennifer Abraham, Scott Ragland, Toni Smith
and William Roy
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13 UNITED STATES DISTRICT COURT

14 EASTERN DISTRICT OF CALIFORNIA
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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
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I, Toni Smith, declare as follows:
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1. I am a registered nurse and am employed by the County of Kern and work at Kern
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Medical Center. I am one of the defendants in this action and I understand that I may be a
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witness. I know Dr. David Jadwin and worked with him when he was in the pathology lab at
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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.
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11 By: _
Toni Smith
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2 DECLARATION OF TONI SMITH I

SUPPORT OF MOTION FOR PROTECTIVE ORDE