Case 1:07-cv-00026-OWW-DLB Document 342 Filed 05/10/2009 Page 1 of 1

PLAINTIFF’S PROPOSED NEUTRAL JOINT STATEMENT OF CASE

In October 2000, Defendant County of Kern hired Plaintiff Dr. David Jadwin, a
pathologist, to be the Chairman of the Department of Pathology at Kern Medical Center.
The County employed him for seven years until October 2007.
Dr. Jadwin claims he suffered from severe depression for nine months from
December 2005 to September 2006. Beginning December 2005, Dr. Jadwin went on a
part-time medical leave of absence for his claimed severe depression, working part-time
at the hospital and doing some work from home. Dr. Jadwin claims the County interfered
with his medical leave by ordering him onto full-time leave in April 2006. He claims he
would have been able continue doing his job while recovering from his claimed
depression if the County had allowed him to continue the part-time work schedule and
work-from-home arrangement. The County denies that it failed to accommodate Dr.
Jadwin and believes it did everything it should have done. The County also denies it
interfered with Dr. Jadwin’s medical leave and claims it approved every leave request Dr.
Jadwin made.
The County demoted Dr. Jadwin from chair of the Department of Pathology in
July 2006, placed him on paid administrative leave in December 2006, and did not renew
his employment agreement which expired in October 2007. Dr. Jadwin claims the
County did these things, as well as forcing him onto full-time leave in April 2006, in
discrimination against his mental disability and in retaliation for his medical leaves. The
County claims it did these things because Dr. Jadwin was not present at the hospital and
refused to return to work full-time.
During Dr. Jadwin’s employment, disputes arose between him and members of
the medical staff at Kern Medical Center. Dr. Jadwin claims those disputes arose because
of the patient care problems at the hospital that he was complaining of. The County
claims Dr. Jadwin caused them himself by his behavior towards other members of the
hospital staff.