Free Declaration - District Court of Delaware - Delaware

Case 1:08-cv-00352-SLR

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE GLORIA M. HARRISON, Plaintiff, v. RENATA J. HENRY, individually and in her official capacity as Director of the Division of Alcoholism, Drug Abuse and Mental Health of the Delaware Department Health and Social Services, SUSAN WATSON ROBINSON, individually and in her official capacity as Hospital Director of the Delaware Department of Health and Social Services, PHILIP THOMPSON, individually and in his capacity as Unit Director of the Delaware Department of Health and Social Services, DELAWARE DEPARTMENT OF HEALTH AND SOCIAL SERVICES, THE DELAWARE PSYCHIATRIC CENTER, and JOHN DOES 1-20, Defendants. : : : : : : : : : : : : : : : : : : : : :

Civil Action No. 08-352 (SLR)

DECLARATION OF KATHLEEN M. JENNINGS, ESQ., IN SUPPORT OF DEFENDANTS' MOTION TO DISMISS PURSUANT TO FED. R. CIV. P. 12(b)(1) and 12(b)(6) I, Kathleen M. Jennings, Esq., declare as follows: 1. I am a partner with the law firm WolfBlock LLP, attorneys for defendants

Delaware Department of Social Services, Delaware Psychiatric Center, Renata Henry, Susan Watson Robinson, and Philip Thompson (collectively, the "defendants") in the above-captioned matter. 2. I make this declaration in support of Defendant's Motion to Dismiss Pursuant to

Fed. R. Civ. P. 12(b)(1) and 12(b)(6). I am competent to testify to the matters stated in this

CHL:413135.1/DEL227-253522

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declaration, have personal knowledge of the facts and statements herein, and each of the facts and statements is true and correct. 3. Attached hereto as Exhibit "A" is a true and correct copy of a State of Delaware

FMLA Medical Certification dated Jan. 22, 2007. 4. Attached hereto as Exhibit "B" is a true and correct copy of an undated State of

Delaware FMLA Medical Certification. 5. Attached hereto as Exhibit "C" is a true and correct copy of a Fax Cover Sheet

from Delaware Foot and Ankle Group. 6. Attached hereto as Exhibit "D" is a true and correct copy of the Division of

Substance Abuse and Mental Health's Web Page. I declare under penalty of perjury that the foregoing is true and correct. Executed this 8th day of August, 2008. /s/ Kathleen M. Jennings Kathleen M. Jennings, Esq. (No. 913)

CHL:413135.1/DEL227-253522

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