Free Declaration in Support - District Court of California - California

Case 3:07-cv-04893-JSW Research - Education

Document 11 VACCHCS

Filed 12/17/2007

Page 1 of 2

SCOTT N. SCHOOLS (SCSBN 9990) United States Attorney JOANN M. SWANSON (SBN 88143) Chiei: Civil Division ABR4HAM SIMMONS (SBN 146400) Assistant United States Attorney 450 Golden Gate Avenue, 9th Floor San Francisco, California 94 102-3495 Telephone: (4 15) 436-7264 Facsimile: (4 15) 436-6748 E-mail: ab~-ahani.sirn~~io~~~~dusdoi.go~

Of Counsel DONALD C. PHILIPS (SBN 129726) United States Department of Veterans Affairs
.4ttorneys for Defendant R. James Nicholson, Secretary of the United Statcs Department of Veterans Affairs

UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION

Arrolene Burrell, Plaintiff,
VS.

) Case No.: C-07-4893-JSW

) DECLARATION OF CAROLYN HUGHES

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R. James Nicholson, Secretary of the United States Department o f Veterans Affairs,
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Defendant.

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Pursuant to 28 U.S.C.

1746, I, Carolyn Hughes, declare as follows:

1. I am the Chief of the Social Work Service at the United States Department of Veterans

Affairs Central California Healthcare System. I have personal knowledge of the fbllowing facts and coiild testify regarding these facts if called to do so. I submit this declaration in support o f defendant's venue motion.
2. My permanent duty station is in Fresno, California and I reside in Clovis. I have been

info~med among the allegations in plaintiffs complaint in this action she claims to be the that
victim of illegal discrimination while she was under my supervision. I deny all allegations of
DECLARATION OF CAROLYN HUGHES - 1

559 228 6943

Case 3:07-cv-04893-JSW Research - Education

Document 11
VACCHCS

Filed 12/17/2007

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Page 2 of 2
12-17-2007
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discrimination by me against plaintiff, .4rrolene B u ~ ~ e l Nonetheless, during the entire time that l.
I was Ms. Runell's supervisor. all activity related to nly supervision of Ms. Burrcll took place in

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Fresno, California.
3. During the entire time that I was her supervisor, Ms. Burrell's duty station was
ill

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Fresno,

' 1 I Fresno, California.
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California.
4. The supervisory records 1 am aware of that are relevant to this lawsuir are ~~iaintained ill

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5. I f Ms. BurreIl was ever in San Francisco County during any ofthc alleged discriminatory
acts. I was not aware of her offtlie VA campus location.

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6. Had Ms. Burrell chosen not to retire u~hen did and if she continued to work for the she

Department of V e t e m s Affairs, her duty station would have been in Fresno, California, unless

she sought to transfer her duty station to another VA instalIation.

7. 1 am informed that plaintiff alleges in her Complaint that. "Many of the u~ilawful

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I practices alleged in this complaint occumd in the County of San Francisco, which is situated in
the Northern District of California." I can recall no interaction that [ had with Ms. Burrcll that

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occ~vred the County of San Francisco. Instead, and as stated herein, all supervisory activity I in /(conductedrelated to Ms. Burrell that is at issue in this action occurred at the VA Medical Ccnter

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I declare under penalty of perjuly that the foregoing is true and correct and that this
declaration was execured under the laws of the Unired State; on this -day of Decembsr.

DECLAR.4TION OF CAROLYN HUGHES - 2