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Eugene D. Lee, No. 236812LAW OFFICE OF EUGENE LEE

555 West Fifth Street, Suite 3100Los Angeles, CA 90013Phone: (213) 992-3299Fax: (213) 596-0487Email: [email protected]

Attorney for Plaintiff DAVID F. JADWIN, D.O.

UNITED STATES DISTRICT COURT

EASTERN DISTRICT OF CALIFORNIA

FRESNO DIVISION

DAVID F. JADWIN, D.O.,

Plaintiff,

v.

COUNTY OF KERN, and PETER BRYANand IRWIN HARRIS in their individual andofficial capacities,

Defendants.

Case No. 1:07-cv-00026 OWW TAG

PLAINTIFFS REPLY TO OPPOSITION TOMOTION FOR PARTIAL OR FULLSUMMARY JUDGMENT

DATE: January 12, 2008TIME: 10:00 a.m.CTRM: U.S. District Court, Ctrm. 3

2500 Tulare St., Fresno, CA

TRIAL: March 24, 2008Complaint filed: January 6, 2007

Case 1:07-cv-00026-OWW-TAG Document 288 Filed 12/08/2008 Page 1 of 23

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I. ADVERSE EMPLOYMENT ACTIONS

A.

Totality of the CircumstancesContrary to what Defendants contend, Plaintiffs Complaint asserts the totality of the

circumstances approach under Yanowitz v. LOreal 36 Cal.4 th 1028, 1055. Plaintiffs complaint several

times alleges Defendants creation of a hostile work environment. (e.g., Second Amended Complaint,

Doc. 241 19, 44, 110, 136, etc.). And the record establishes that, over a number of years, Defendants

targeted Plaintiff with a smear campaign of disparate treatment, heightened scrutiny, retaliatory peer

review and baseless accusations. [DMF 69-190].

Defendants decisions to 1) place letters of reprimand into Plaintiffs credentials file in October

2005 for a minor time overrun at a monthly Cancer Conference (Credential Threat), 2) force Plaintiff

from part-time onto full-time medical leave in April 2006 (Forced FT Leave), 3) remove Plaintiff

from Pathology department chair (Demotion) in July 2006 and reduce his base pay by over $100,000

in October 2006 (Paycut), 4) place Plaintiff on administrative leave in December 2006 for almost a

year, denying him professional fee income and restricting him to his home during work hours (Admin

Leave

), and 5) not renew his contract which expired in October 2007 (Nonrenewal), must all be

considered collectively under Yanowitz as part of a series of subtle and not-so-subtle damaginginjuries to Plaintiff motivated by illegal retaliation and discrimination.

B. Discrete Adverse Employment Actions

However, caselaw also establishes that each of the foregoing stands on its own as a discrete

adverse employment action. The California Supreme Court has held that an adverse employment action

must materially affect the terms, conditions or privileges of employment. Yanowitz v. LOreal 36 Cal.4 th

1028, 1036. In so doing, the court rejected the arguably broader federal deterrence standard. Ibid .

However, the court further emphasized that the phrase terms, conditions, or privileges of employment

must be interpreted liberally and with a reasonable appreciation of the realities of the workplace in order


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conduct that is merely offensive and requiring the conduct to cause a tangible psychological injury . Id .

at 1053 (emphasis added).1. Credential Threat . Here, the evidence incontrovertibly establishes that the Credential Threat

did cause Plaintiff a tangible psychological injury, and that it impaired his job performance so greatly

that he had to request reduced work schedule medical leave in January 2006. [PMF 75]. 1 When Former

Medical Staff President Scott Ragland (Ragland) was asked Is that a serious thing, for a physician at

Kern Medical Center, to have a letter of reprimand or dissatisfaction entered into their medical staff

file? he responded Of course. (Ragland Depo., 8/22/08, 264:25-265:4). Plaintiffs expert, Lawrence

Weiss, Chair of Pathology at City of Hope National Medical Center, observed of the Credential Threat:

I have never seen a physicians privileges threatened for such an insignificant and patently unwarranted

reason. [DMF 106].

Worse yet, Defendants have admitted they were on notice since 2003 that Plaintiff suffered from

depression. 2 [DMF 62, 63, 64, 65]. Former Medical Staff President and psychiatrist Eugene Kercher

(Kercher) testified as PMK representative on behalf of Defendant County that he was familiar with the

symptoms of depression and had formed the opinion that Dr. Jadwin was depressed over the course of

years of observing and working with him. [PMF 136]. Yet, Defendants engaged in a course of conductthat was calculated to wreak maximum havoc on Plaintiffs disability.

First, on October 17, 2005, days after the monthly 1-hour cancer conference held on October 12,

2005 (October Conference) at which Plaintiff had reported his patient care concerns to medical staff

officers, doctors and residents regarding a radical hysterectomy that had been conducted based on

deficient outside pathology reports, as well as the need for systematic, confirmatory review of outside

pathology reports prior to undertaking surgery [PMF 89] the medical staff officers retaliated by calling

Plaintiff into a meeting where they humiliated him for making his political statements [DMF 114],


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then told him of their decision to place three letters of reprimand solicited from conference attendees

into Plaintiffs credentials file.3

A formal joint letter of reprimand they delivered to Plaintiff at themeeting memorialized this decision and further threatened to subject [Plaintiff] to disciplinary action

by the medical staff 4 if he were to again 1) run over time despite the fact that Plaintiff had spoken at

most for only 15 minutes of the allotted 1 hour, that conferences at KMC run over all the time [PMF

106], that the first presentation of that morning had run over by 5 minutes without incident [DMF 106],

and that the subsequent November cancer conference ran over by 8 minutes [DMF 115] without

incident, 2) ignore the requests of the leader of the conference, Albert McBride, to be brief despite the

fact that McBride later testified that No, I was not upset with Dr. Jadwin. I have always had a lot of

professional respect for Dr. Jadwin. Frankly, I think he is a very good pathologist (McBride Depo.,

8/15/08, 34:1-3), I was not unhappy with [Plaintiffs] presentation. He had a lot of good material to

present [DMF 106], and that I did not want to write this letter [of reprimand] but did so at the

direction really of former Chief Medical Officer Irwin Harris (Harris) (McBride Depo., 8/26/08,

30:6-7), or 3) use a public forum for making political statements direct evidence of retaliatory

motive with respect to the content of Plaintiffs October Conference presentation, i.e., a complaint about

patient care. Defendants further contend Plaintiff ruined the educational mission of the OctoberConference, 5 but the majority of attendee feedback forms collected at the end of the conference gave

3 There is no question that this was a complaint relating to the care, services, or conditions of [a healthfacility] within the meaning of Health & Safety C. 1278.5(b)(1). Defendants own Opposition admitsthat Plaintiffs presentation criticized outside pathology reports of both the University of SouthernCalifornia and Stanford University. (Opposition, Doc. 276, 4:12-13) and took issue with the clinicians,William Roys, handling over a specific case. (Id., at 4:13-14). When McBride was asked indeposition, Would you say it would almost be medically irresponsible to conduct a hysterectomy on apatient based upon poor histology?, he responded Its a tough question, but the answer is, obviously,yes. I mean, you want to do the right operation for the right pathologyon anything. (McBride Depo.,8/15/08, 52:3-12).4 Defendants argue the Credential Threat does not fall within the scope of Health & Safety C. 1278.5(d), but that section expressly prohibits discriminatory treatment of an employee . . . whichincludes discharge demotion suspension or the threat of any of these actions (emphasis added)


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Plaintiff high marks for his presentation and included such praise as V. good speaker and Great.

[DMF 109].To make matters worse, when Plaintiff then requested to see the letters of reprimand, Defendants

refused. It was only when Plaintiffs attorney sent a letter to Defendant County that, on January 6, 2006,

Defendants finally provided Plaintiff with copies of the letters in redacted form. (Second Amended

Complaint, 69 (Doc. 241)) [DMF 32 (Tort Claims Act Complaint at Section 3.C, second paragraph)].

Defendants resort to arguing no harm, no foul based on the fact that they ultimately decided

not to put the letters into Plaintiffs credentials file. Yet, Harris testified they also chose not to tell this

fact to Plaintiff, intentionally keeping him in the dark despite his many anxious inquiries about the

letters being entered into his credentials file. (Harris Depo., 8/13/08, 167:3-8). Harris testified: Dr.

Jadwin was repeatedly obsessed with whether or not the letter was in his fileBut I think he continued

to believe that [the letters of reprimand] was. (Harris Depo., 8/13/08, 168:14-27).

There is no question that, not only was the Credential Threat a serious threat to Plaintiffs

credentials, but that Defendants were acting maliciously in retaliation for his whistleblowing and that

they succeeded in willfully causing Plaintiff tangible psychological injury by re-igniting his major

depressive disorder, of which they had been on notice.6

2. Forced FT Leave . Defendants rely heavily on Swonke v. Sprint, Inc. (N.D. Cal. 2004) 327

F.Supp.2d 1128 in support of the notion that an employer is permitted to place an employee on a leave

the employee did not request. (Opposition, Doc. 276, 5:23-24). However, Swonke is distinguishable.

There, plaintiffs medical providers had told the employer that plaintiff was unable to work at all, even

with modifications. Swonke v Sprint, Inc. , 327 F.Supp.2d 1128, 1133. The court thus found nothing

wrong with the fact that Plaintiffs managers told him to stay home and recuperate. Swonke v Sprint,

Inc. , 327 F.Supp.2d 1128, 1138. Here, Plaintiffs medical leave certification made it abundantly clear

that Plaintiff could work on a reduced work schedule [DMF 14] Moreover Defendant Bryan did not


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medical leave entitlement. [DMF 21]. Bryan also suggested it was because Plaintiffs part-time leave

was creating issues within the Pathology department. [DMF 21, Lee Opp. Decl., Exh. 2 (Bryan Depoat 249:24-250:19)]. The Forced FT Leave denied Plaintiff any opportunity to earn professional fees,

which ranged between $6,000 to $8,000 per month in the 7 months leading up to April 28, 2006. [PMF

25, Rizzardi Decl., Exh. 1, Table 7; Jadwin Decl. para 14].

Defendants allege Plaintiff violated numerous medical leave protocols when he began his

reduced work schedule medical leave on December 16, 2005 and that he unilaterally placed himself on

leave. Those allegations are baseless. 7 Plaintiff was legally required only to give reasonable notice to

his employer of his need for medical leave. 8 It is undisputed that Plaintiff gave such verbal and written

notice to Defendant Bryan in early January 2006, and again in March 2006. [PMF 153; DMF 10, 11, 19,

67]. Although Defendants designated December 16, 2005 as the beginning date of his leave, HR

personnel testified that they had simply taken the date when Plaintiffs condition began as stated on the

medical certification of Plaintiffs therapist, and deemed that Plaintiffs medical leave had begun on that

date. (Nunn Depo., 2/27/08, 84:24-85:25). In fact, a review of Plaintiffs timesheets proves Plaintiff was

working full-time from December 16, 2005 to January 9, 2006, taking 4 sick days off during the

Christmas and New Year holidays [DMF 33, Bryan Memo to JCC of 7/10/06 at Bates 1532-1533)],

upon conclusion of which Plaintiff timely gave Bryan reasonable notice of his need for medical leave.

3. Demotion . Defendants digress into an analysis of the term demotion as it is technically

defined by KMCs bylaws. However, the Yanowitz materiality framework, not KMCs bylaws, is

controlling for purposes of adverse employment action analysis. Defendants attempt to superimpose

their interpretations of KMC Bylaws onto adverse employment action analysis has no support in

caselaw. As Defendants well know, Plaintiff use Demotion as shorthand for Plaintiffs removal

7 Defendants rely heavily on former HR Director Sandra Chesters testimony to establish Plaintiffs


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establishes his state of mind toward Plaintiffs oppositional activity: So why would you want to

establish a contractual relationship with somebody whos suing you. [DMF 34-36, Watson Depo,

8/25/08, 110:17-19].

Defendants attempt to controvert Watsons testimony with obfuscation and a sham declaration.

First they contend Watson only remembered a discussion about [Demotion] (Opposition, Doc. 276,

10:19-20), but that is belied by the foregoing testimony. Watson confirmed the foregoing recollection

not once, but three times (the third time volunteering it on his own initiative). [DMF 34-36]. Plaintiff

even asked Watson if he was speculating or guessing as to whether retaliation for Plaintiffs lawsuit was

a reason for the Nonrenewal decision: [A]re you just speculating now, just guessing, or was that a

consideration for his nonrenewal? Watson responded, Well, I remember it being discussed. [DMF

34-36, Watson Depo.,8/25/08, 110:23-111:5).

Defendants cite to deposition testimony that appears over 200 pages and 2 hours earlier in the

deposition transcript regarding a separate line of questioning to point out that Watson couldnt recall any

discussions about termination, resignation or denial of Plaintiffs privileges. But that proves nothing

about whether discussions about Nonrenewal had occurred. [DMF 34-36].

Defendants argue that Watson couldnt clearly recall whether the JCC or the Board of

Supervisors had voted not to renew Plaintiffs contract, and assert: In fact, neither the JCC nor the

Board of Supervisors decided to let Plaintiffs contract expire. (Opposition, Doc. 276, 25:2-4). 13

Similarly, Watson submitted a lawyer-drafted declaration stating: As a county supervisor, I am

accustomed to making decisions and I assumed, if Dr. Jadwins contract was not renewed, there had

been a decision to not renew it; however , there was no such decision . (Doc. 255, 2:12-14) (emphasisadded).

These assertions are shams. First, when Watson was asked in deposition, So you dont recall a

specific vote, but there was a decision not to renew [Plaintiffs] contract then?, he unequivocally


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that The county decided not to renew Dr. Jadwins contract, which expired on October 4,

2007Admit. (PMF 29 of Defendants Response to Plaintiffs Statement of Undisputed Facts, Doc.

278, 7:3-4).

Third, a contemporaneous email establishes that Defendant County had decided not to renew

Plaintiffs contract as early as May 1, 2007. In an email to Plaintiffs counsel, carbon copied to Kern

County counsel Mark Nations and Karen Barnes more than 5 months before Plaintiffs contract was due

to expire, defense counsel wrote: If we cannot buyout [Plaintiffs] contract then the best [the County]

can do is lift the [home] restrictions on [Plaintiffs] leave and let the contract run out ; The Countys

initial thought was that it could cash Dr. Jadwin out of his remaining contract in return for a discounted

lump sum payment. This would offer the mutual benefits of freeing him from administrative leave and

getting on with his career and freeing the County from his contract . [PMF 63, Lee Supp. Decl., Exh.

6 (Wasser Email to Lee of 5/1/07 at DFJ01705)]. 15 In response, Plaintiffs counsel sent a fax to defense

counsel protesting KMCs decision not to renew Dr. Jadwins contract. [PMF 63, Lee Supp. Decl.,

Exh. 7 (Lee Fax to Wasser of 5/1/07 at DFJ1702, 1703)]. Defendants never responded to the fax.

Defendant County ended up running Plaintiffs contract out as it had said it would.

It simply flies in the face of logic for Defendant County and Chairman Watson to now posit that

there were no discussions or decisions regarding the expiration and nonrenewal of Plaintiffs contract.

The County was anxious as early as May 1, 2007 to free itself from Plaintiffs contract. Watsons

repeated admissions against interest establish retaliatory motives for the Nonrenewal. Defendants should

not now be permitted to create an issue of fact where there is none through sham declarations and lies.

II. COUNTSRegarding skull flaps, Plaintiffs suspicions of unlicensed tissue storage in violation of Health &

Safety C. 1635.1 was reasonable. Plaintiffs successor, Philip Dutt testified that he later disposed of

the up to 15 to 20 skull flaps being stored in an unlicensed freezer because he didnt want to take the


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chance that some might be reimplanted into a patient and run afoul of regulators precisely his

predecessors concern. (Dutt Depo., 8/20/08, 247:13-249:6). Prior to October 2006, Plaintiff had thought

the skull flap issue resolved. (Martinez Depo., 4/16/08, 19:11-20:8).

Regarding FMLA/CFRA, Defendants state that Neisendorf v. Levi Strauss & Co. stands for the

proposition that Once the 12 weeks of [protected medical] leave have been taken, an employees rights

under FMLA expire. (Opposition, Doc. 276, 17:11-12), 143 Cal.App.4th 509, 518. Defendants then

argue in various places throughout their Opposition that all of Plaintiffs rights under FMLA/CFRA

expired upon the end of his leave. This is wrong. Neisendorf established only that an employees right

to reinstatement expires upon exhaustion of his 12 weeks of medical leave. 143 Cal.App.4th 509, 517-

518. 16 Neisendorf did not establish that an employer could, for instance, retaliate with impunity against

an employee for medical leave once his protected 12 weeks were ended.

Regarding disability discrimination, 17 it is undisputed that Defendants approved Plaintiffs

reduced work schedule medical leave from December 16, 2005 to April 28, 2006 whereby he worked

and was only paid for 1 to 2 workdays per week [PMF 121, 226], yet the Pathology department

continued to function well during that time. [PMF 123, 227; DMF 160]. Thus, there is no question that

Plaintiff was otherwise qualified to perform the essential functions of his job with a reduced work

schedule accommodation and that the accommodation was reasonable. Yet, when Plaintiff timely

requested an extension of his accommodation [PMF 14], Defendant Bryan refused to engage in the

interactive process 18 and instead forced Plaintiff onto Forced FT Leave.

Regarding due process, several KMC doctors testified to their understanding that their positions

at KMC were permanent barring cause. Shertukde Depo, 202:24-206:13; Naderi Depo., 17:10-18:5.

16 Defendants also cite to the wrong jury instruction, CACI 2600 (failure to reinstate). Timeliness of notice is not an element under the correct instruction, CACI 2620. The elements to establish medicalleave retaliation under CFRA and FMLA are essentially the same.17 As was made clear in Plaintiffs Opposition FEHA expressly rejects several of the ADAs stricter


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CAST OF CHARACTERS HIERARCHICAL

NAME DESCRIPTION

Kern County Defendant

Barbara Patrick Chair, Board of Supervisors, 2006

Supervisor, 1994 2007

Ray Watson Chair, Board of Supervisors, 2006

Supervisor, 2002 present

Bernard Barmann County Counsel for Kern County

Mark Nations Chief Deputy County Counsel for Kern County

Karen Barnes Chief Deputy County Counsel for Kern County

Kern Medical Center (KMC) Acute care teaching hospital located in Bakersfield, CA, that

is owned and operated by County of Kern.

Joint Conference Committee (JCC) Highest decision-making body at KMC, comprised of 2

Supervisors, CEO, President, Immediate Past President,

President-elect, CMO, Nurse Executive, etc.

Peter Bryan DefendantChief Executive Officer, 1995 - 9/15/06

David Culberson Interim Chief Executive Officer, 8/25/06 5/15/07

Marvin Kolb, M.D. Chief Medical Officer, 1999 8/3/04

Irwin Harris, M.D. Defendant

Chief Medical Officer, 2005 9/1/07

Jennifer Abraham, M.D. Immediate Past President, 7/1/04-7/1/06

Eugene Kercher, M.D. President-elect, 7/1/02 7/1/04


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NAME DESCRIPTION

Royce Johnson, M.D. Chair, Medicine

Maureen Martin, M.D. Chair, Surgery

Javad Naderi, M.D. Chair, Radiology

Tai Yoo, M.D. Chair, Psychiatry

Philip Dutt, M.D. Pathologist, 6/21/05 7/14/06

Acting Chair, Pathology, 7/14/06 - present

David F. Jadwin, D.O., F.C.A.P. Plaintiff

Chair of Pathology, 10/24/00 7/10/06

Staff Pathologist, 7/10/06 10/4/07

Albert McBride, M.D. Moderator, Cancer Conference

Bill Taylor, M.D. Surgeon

Joseph Mansour, M.D. Gynecologist

Savita Shertukde, M.D. Pathologist, 11/1/05 present

Chester Lau, M.D. Former Radiologist

William Roy, M.D. Former GynecologistGilbert Martinez Former Laboratory Manager

Sandra Chester HR Director, 12/05 8/06

Steven OConnor HR Director, 6/06 - present


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CAST OF CHARACTERS ALPHABETICAL

NAME DESCRIPTION

Jennifer Abraham, M.D. Immediate Past President, 7/1/04-7/1/06

Bernard Barmann County Counsel for Kern County

Karen Barnes Chief Deputy County Counsel for Kern County

Peter Bryan Defendant

Chief Executive Officer, 1995 - 9/15/06

Sandra Chester HR Director, 6/06 - present

David Culberson Interim Chief Executive Officer, 8/25/06 5/15/07

Philip Dutt, M.D. Acting Chair, Pathology, 7/14/06 - presentIrwin Harris, M.D. Defendant

Chief Medical Officer, 2005 9/1/07

David Jadwin, D.O.,

F.C.A.P.

Plaintiff

Chair of Pathology, 10/24/00 7/10/06

Staff Pathologist, 7/10/06 10/4/07

Royce Johnson, M.D. Chair, Medicine

Joint Conference

Committee (JCC)

Highest decision-making body at KMC, comprised of 2

Supervisors, CEO, President, Immediate Past President,

President-elect, CMO, Nurse Executive, etc.

Eugene Kercher, M.D. President-elect, 7/1/02 7/1/04

Medical Staff President, 7/1/04 7/1/06

Immediate Past President, 7/1/06 7/1/08


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NAME DESCRIPTION

Chester Lau, M.D. Former Radiologist

Joseph Mansour, M.D. Gynecologist

Maureen Martin, M.D. Chair, Surgery

Albert McBride, M.D. Moderator, Cancer Conference

Javad Naderi, M.D. Chair, Radiology

Mark NationsChief Deputy County Counsel for Kern County

Steven O'Connor HR Director, 12/05 8/06

Savita Shertukde, M.D. Pathologist, 11/1/05 present

Bill Taylor, M.D. Surgeon


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CHRONOLOGY

DATE EVENT10/24/2000 Start of Plaintiff's employment

?/?/2003 Plaintiff tells Kolb of depression, putting County on notice of his depression disability

12/26/2003 Plaintiff's salary increased

10/12/2005 Whistleblowing (hysterectomy) : At October Cancer Conference, Plaintiff reports

patient care issue re hysterectomy based on poor histology to Harris, Abraham, etc.

10/17/2005 CREDENTIAL THREAT

12/16/2005 Medical leave: HR deemed this to be the date when Plaintiff's reduced work schedule

medical leave began

1/9/2006 Medical leave: Plaintiff puts County on notice of the recurrence of his depression

disability and gives reasonable notice of need for medical leave by notifying Bryan. He

requests reasonable accommodation in form of reduced work schedule medical leave,

which Bryan approves

1/13/2006 Medical leave: Plaintiff submits medical leave certification from his therapist to HR

2/22/2006 Harris and Kercher apologize to Plaintiff

3/15/2006 Medical leave: Plaintiff's initial medical leave expires

3/16/2006 Medical leave: Plaintiff requests further reasonable accommodation when he notifies

Bryan of his need to extend his reduced work schedule medical leave

4/17/2006 Whistleblowing (PCC) : Plaintiff reports PCC regulatory noncompliance to Bryan and

requests meeting with Barmann4/17/2006 Bryan tells Plaintiff that the Pathology department is functioning well, but threatens to

terminate him

4/20/2006 Medical leave: HR sends Plaintiff notice by first class mail that his medical leave has


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DATE EVENT4/28/2006 FORCED FT LEAVE

5/31/2006 Plaintiff asks Bryan if he can get additional time past 6/16/06 deadline to decide whether

to resign from his position at KMC

6/14/2006 Bryan preempts Plaintiff and tells him he is initiating demotion procedures "effective

June 17, 2006"; Bryan also places Plaintiff on 90-day personal leave

6/16/2006 Deadline for Plaintiff's decision to return full-time (preempted by Bryan's 6/14/06 letter)

6/29/2006 Plaintiff's counsel sends letter to Barnes re preservation/no spoliation of evidence

7/10/2006 DEMOTION

10/3/2006 PAYCUT

10/4/2006 Plaintiff returns to work as demoted pathologist

11/23/2006 Whistleblowing: Plaintiff notifies Martinez of intent to blow whistle to outside authorities

11/27/2006 Whistleblowing (tipoff) : Harris and Dutt learn Plaintiff intends to blow whistle to

outside authorities

11/28/2006 Whistleblowing (skull flaps et al.) : Plaintiff blows whistle to DHS, CAP and JCAHO re

skull flap regulatory noncompliance, PCC regulatory noncompliance, prostatectomy

patient care issue, etc.

12/6/2006 Whistleblowing (prostatectomy) : Plaintiff reports patient care issue re radical

prostatectomy based on equivocal pathology to Culberson, Dutt, Harris and Barnes and

requests Board of Supervisors be notified.

12/7/2006 ADMIN LEAVE12/13/2006 Whistleblowing: Plaintiff formally notifies County of his whistleblowing report to DHS,

CAP and JCAHO

1/6/2007 Plaintiff files lawsuit


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DATE EVENT10/4/2007 NONRENEWAL


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10

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12

13

14

15

16

17

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2122

23

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8/14/2019 288 P Reply - P MSJ

23/23

WORK LEAVE CHRONOLOGY

12/15/05

Nonrenewal10/4/07

Demotion7/10/06

4/28/06 6/17/06 10/4/06 12/7/06

Admin Leave

Return to Work

(Demoted)

ForcedPersonal

Leave

Forced FT Leave

Reduced Work Schedule

Medical Leave

Duration 4 mos 2 mos 3.5 mos 2 mos 10 mos

Workdays 2 days 0 days 0 days 5 days 0 daysper week

Voluntary Leave

n/a


288 p reply - p msj

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