Bradburn et al v. North Central Regional Library District - 74

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 10 11 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF WASHINGTON AT SPOKANE 12 13 SARAH BRADBURN, PEARL ) ) ) NO. CV-06-327-EFS ) ) SUPPLEMENTAL DECLARTION ) OF DAN HOWAR IN SUPPORT OF ) NCRL'S MOTION FOR SUMARY ) JUDGMENT ) ) ) 14 15 CHERRNGTON, CHARLES HEINEN, and THE SECOND AMENDMENT FOUNATION, Plaintiffs, v. 16 17 18 19 20 21 NORTH CENTRAL REGIONAL LIBRARY DISTRICT, 22 23 Defendant. ) ) ) 24 25 26 27 28 SUPPLEMENTAL DECLARATION OF DAN HOWARD IN SUPPORT OF NCRL'S MOTION FOR SUMMARY JUDGMENT - i CV-06-327-EFS #657033 v I /42703-001 Law Offces KARR TUTTLE CAMPBELL 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: 1. I am over the age of 18 and competent to testify to the matters set 2 3 4 5 forth herein. 2. Currently, I am the Director of Public Services for North Central 6 7 8 Regional Library. 3. I evaluate patron requests to have Internet content unblocked. 9 10 11 4. In support of their Opposition to NCRL's Motion for Summary Judgment, Plaintiffs offered Ex. FFF, attached hereto. This exhibit purports to 12 13 summarize unblocking requests received by NCRL between 10/1/07 and 2/20/08, and includes NCRL's alleged response. I have carefully reviewed 14 15 Plaintiffs Ex. FFF and believe that clarifications are necessary. 5. Plaintiff s maintain that it is unclear if, or how, NCRL responded to 16 17 18 1 1 of the 92 unblocking requests detailed in Exhibit FFF. With respect to each, the following actions were taken: 19 20 21 22 23 24 25 26 27 28 SUPPLEMENTAL DECLARTION OF DAN HOWARD IN SUPPORT OF NCRL'S MOTION FOR SUMRY JUDGMENT - 2 CV-06-327-EFS #657033 vI /42703-00 I Law Offces KARR TUTTLE CAMPBELL 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 Requested Site 2 3 from Ex. Patron No contact made Patron did not FFF #7 4 5 NCRL was not able to leave contact confirm if "pitbul" was information. a site that was actually blocked, or that this was even the site the 6 7 8 9 10 11 patron was requesting given the lack of information in the request. (Ex. A) #10 No contact made Patron did not Y ahoo.com was leave contact available at this time. information (Ex. B) Patron did not 12 13 #65 No contact made Newgrounds.com was leave contact available at this time. information (Ex. C) #69 14 15 No contact made Patron did not runescape.com is 16 17 18 leave contact blocked at 5 banches information (Wenatchee, Leavenworth, Quincy, 19 20 21 Ephrata, and Soap Lake) due to technical problems with the older computer systems. Use of the website runescape.com at these 5 locations freezes up the Internet terminals 22 23 24 25 making all the public computers unusable. These systems are being replaced this year. (Ex. D). 26 27 28 SUPPLEMENTAL DECLARATION OF DAN HOWARD IN SUPPORT OF NCRL'S MOTION FOR SUMMARY JUDGMENT - 3 CV-06-327-EFS #657033 v I /42703-00 i Law Offces KARR TUTTLE CAMPBELL A Professional Service Corporation 1201 Tbird Avenue, Suite 2900, Seattle; Washington 98101-3028 Telepbone (206) 223-1313, Facsimile (206) 682-7100