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Case 1:07-cv-00026-OWW-TAG Document 61 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: mwasser@markwasser.com
5 Bernard C. Barmann, Sr.
KERN COUNTY COUNSEL
6 Mark Nations, Chief Deputy
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
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17 Plaintiff, ) DECLARATION OF MICHELLE BURRI
) IN SUPPORT OF MOTION FOR

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18 vs. PROTECTIVE ORDER RE:
EMPLOYEES' HOME ADDRESSES
19 COUNTY OF KERN, et aI., )

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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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u,p..~---------)
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, Michelle Burris, declare as follows:
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1. I am employed by the County of Kern and work at Kern Medical Center as a
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supervising clinical lab scientist. I know Dr. David Jadwin and worked with him when he was a
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pathologist at Kern Medical Center.
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1 DECLARATION OF MICHELLE BURRIS

SUPPORT OF MOTION FOR PROTECTIVE ORDE
' •. Case 1:07-cv-00026-OWW-TAG Document 61 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 to Dr. Jadwin. My personal life is
5 separate and private from my professional life as a County employee. I am available at my work
6 address to be contacted in connection with this case and there is no reason to contact me at my
7 home. I am a private person and I value my privacy. I do not want my home address disclosed.
8 4. These facts are within my own personal knowledge and I can testify competently
9 to them.
10 I certify under penalty of perjury that the foregoing is true and correct.
11 Executed this -=...1"-- day of October, 2007, in Bakersfield, California.
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2 DECLARATION OF MICHELLE BURRIS

SUPPORT OF MOTION FOR PROTECTIVE ORDE