Bradburn et al v. North Central Regional Library District Doc.

74

1 The Honorable Edward F. Shea

2
Thomas D. Adams
3 Celeste Mountain Monroe
4 KARR TUTTLE CAMPBELL
5 1201 Third Avenue, Suite 2900
Seattle, Washington 98101-3028
6 (206)223-1313
7 Attorneys for North Central Regional Library District
8

9 UNITED STATES DISTRICT COURT

EASTERN DISTRICT OF WASHINGTON
10
AT SPOKANE
11

12
13 SARAH BRADBURN, PEARL )
14 CHERRNGTON, CHARLES )
HEINEN, and THE SECOND ) NO. CV-06-327-EFS
15
AMENDMENT FOUNATION, )
16 ) SUPPLEMENTAL DECLARTION
17
Plaintiffs, ) OF DAN HOWAR IN SUPPORT OF
) NCRL'S MOTION FOR SUMARY
18 v. ) JUDGMENT
19 )
NORTH CENTRAL REGIONAL )
20 LIBRARY DISTRICT, )
21 )
22
Defendant. )
)
23
24
25
26
27 SUPPLEMENTAL DECLARATION OF
DAN HOWARD IN SUPPORT OF
28 NCRL'S MOTION FOR SUMMARY
JUDGMENT - i Law Offces

CV-06-327-EFS KARR TUTTLE CAMPBELL

#657033 v I /42703-001 A Professional Service Corporation
1201 Tbird A\"cnue, Suite 2900, Seattle, Washington 98101-3028
Telephone (206) 223-1313, Facsimile (206) 682-7100

Dockets.Justia.com
 1 I, Dan Howard, declare as follows:
2
1. I am over the age of 18 and competent to testify to the matters set
3

4 forth herein.
5
2. Currently, I am the Director of Public Services for North Central
6
7 Regional Library.

8 3. I evaluate patron requests to have Internet content unblocked.

9
4. In support of their Opposition to NCRL's Motion for Summary
10
11 Judgment, Plaintiffs offered Ex. FFF, attached hereto. This exhibit purports to
12
summarize unblocking requests received by NCRL between 10/1/07 and
13

14 2/20/08, and includes NCRL's alleged response. I have carefully reviewed

15
Plaintiffs Ex. FFF and believe that clarifications are necessary.
16
5. Plaintiff s maintain that it is unclear if, or how, NCRL responded to
17
18 1 1 of the 92 unblocking requests detailed in Exhibit FFF. With respect to each,
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the following actions were taken:
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21
22
23
24
25
26
27 SUPPLEMENTAL DECLARTION OF
DAN HOWARD IN SUPPORT OF
28 NCRL'S MOTION FOR SUMRY
JUDGMENT - 2 Law Offces

CV-06-327-EFS KARR TUTTLE CAMPBELL

#657033 vI /42703-00 I A Professional Service Corporation
1201 Third A,'cnuc. Suite 2900, Seattle, Washington 98iol~30i8
Telepbone (206) 223-1313, Facsimile (206) 682-7100
 1 Item # Response to Reason Action Taken with
2 from Ex. Patron Requested Site
FFF
3
#7 No contact made Patron did notNCRL was not able to
4 leave contact confirm if "pitbul" was
information. a site that was actually
5
blocked, or that this
6 was even the site the
7 patron was requesting
given the lack of
8
information in the
9 request. (Ex. A)
#10 No contact made Patron did not Y ahoo.com was
10
leave contact available at this time.
11 information (Ex. B)
12 #65 No contact made Patron did not Newgrounds.com was
leave contact available at this time.
13
information (Ex. C)
14 #69 No contact made Patron did not runescape.com is
leave contact blocked at 5 banches
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information (Wenatchee,
16 Leavenworth, Quincy,
17 Ephrata, and Soap
Lake) due to technical
18
problems with the older
19 computer systems. Use
of the website
20
runescape.com at these
21 5 locations freezes up
22 the Internet terminals
making all the public
23 computers unusable.
24 These systems are
being replaced this
25
year. (Ex. D).
26
27 SUPPLEMENTAL DECLARATION OF
DAN HOWARD IN SUPPORT OF
28 NCRL'S MOTION FOR SUMMARY
JUDGMENT - 3 Law Offces

CV-06-327-EFS KARR TUTTLE CAMPBELL

#657033 v I /42703-00 i A Professional Service Corporation
1201 Tbird Avenue, Suite 2900, Seattle; Washington 98101-3028
Telepbone (206) 223-1313, Facsimile (206) 682-7100