Bradburn et al v. North Central Regional Library District - 65

Bradburn et al v. North Central Regional Library District Doc. 65 1 The Honorable Edward F. Shea Thomas D. Adams 2 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 Defendant North Central Regional Library District 8 9 10 11 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF WASHINGTON AT SPOKANE 12 13 14 15 SARAH BRABURN, PEAR CHERRGTON, CHARLES HEINLEN, and THE SECOND AMENDMENT FOUNATION, Plaintiffs, v. 16 17 18 19 ) ) ) NO. CV-06-327-EFS ) ) DECLARATION OF BARAR 20 21 NORTH CENTRAL REGIONAL LIBRARY DISTRICT, ) ) ) ) ) ) ) ) ) WALTERS IN SUPPORT OF DEFENDANT NORTH CENTRAL LIBRARY DISTRICT'S REPLY TO ITS MOTION FOR SUMARY JUDGMENT 22 23 Defendant. 24 25 DECLARATION OF BARBARA W ALTERS IN SUPPORT OF 26 27 28 DEFENDANT NORTH CENTRAL LIBRARY DISTRICT'S REPLY TO ITS MOTION FOR SUMMARY JUDGMENT - 1 CV-06-327-EFS #66 i 598 vi /42703-001 Law Offces KARR TUTTLE CAMPBELL A Professional Service Corpora/ion 1201 Third Avenue, Suite 2900. Seattle, Washington 98101-3028 Telephone (206) 223~13iJI Facsimile (206) 682-7100 Dockets.Justia.com 1 I, Barbara Walters, declare as follows: 1. I am over the age of 18 and competent to testify to the matters set 2 3 4 5 forth herein. 2. I am the Information Technology Manager for NCRL. 6 7 8 3. Internet access was gradually made available at NCRL branch locations. Plaintiffs' correctly note that the first branch with Internet access was NCRL's Omak branch, which went online in November 1999. 4. The second branch was NCRL's Wenatchee branch, which went 9 10 11 12 13 online in January 2000. 14 15 5. NCRL used a Surfwatch brand filter at both the Wenatchee and Omak locations, however, the filtering software consistently froze the public use computers that they were installed on. 16 17 18 6. NCRL implemented its first system-wide Internet filter II December 2000 and that filter was referred to as "BESS." 7. In December 2000, most of NCRL's branches did not have public 19 20 21 22 23 internet computers. In fact, Internet access was not available at all 28 branches 24 25 DECLARATION OF BARBAR WALTERS IN SUPPORT OF DEFENDANT NORTH CENTRAL LIBRARY DISTRICT'S REPLY TO ITS MOTION FOR SUMMARY JUDGMENT - 2 CV-06-327-EFS #661598 vi /42703-001 26 27 28 Law Offces KARR TUTTLE CAMPBELL A Professional Serv;ce Corporation 1201 Third Avenue, Suite 2900, Seattle, Waiihington 98101-3028 Telephone (206) 223-1313, Facsimile (206) 682.7100