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Bradburn et al v. North Central Regional Library District - 73

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Bradburn et al v. North Central Regional Library District Doc. 73 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 WASHIGTON AT SPOKANE 12 13 SARA BRABUR, PEAR CHERRNGTON, CHAES HEINEN, md THE SECOND 14 15 ) ) ) NO. CV-06-327-EFS AMNDMENT FOUNATION, Plaintiffs, v. ) ) DEFENDANT NORTH CENTRAL 16 17 18 ) ) ) ) ) ) ) ) REGIONAL LIBRAY'S AMNDED WITNSS AND EXHIBIT LIST 19 20 21 NORTH CENTRAL REGIONAL LIBRARY DISTRICT, 22 23 Defendant. 24 25 Defendant North Central Regional Library identifies the following witnesses and exhibits: DEFENDANT NORTH CENTRAL 26 27 28 REGIONAL LIBRAY'S AMNDED WITNSS AND EXHIBIT LIST - 1 CV-06-327-EFS #664851 vI /42703-001 Law Offces KARR TUTTLE CAMPBELL A Professional Service Corporation 1201 Third Avenue, Suile 2900, SealIle. WasbiDg10n 98101-3028 Telephone (206) 223-1313, Facsimile (206) 682-7100 Dockets.Justia.com 1 2 3 i. FACT WITNESSES 1. Dean Marney 4 5 Dean Marney is the Director of the North Central Regional Library 6 7 8 ("NCRL") District. Mr. Marney was appointed to his position by the NCRL Board of Trustees in 1990. As Director, Mr. Marney serves as the liaison between the Board and library staff. 9 10 11 Mr. Marney wil testify regarding NCRL and its policies, including: its 12 13 mission, collection development policy and internet usage policy. He wil testify regarding NCRL's need to comply with the Children's Internet Protection 14 15 Act ("CIP A") and the Board's decision to implement an Internet filter to 16 17 18 facilitate compliance with CIPA. Mr. Marney wil discuss NCRL's current internet filtering profile, as well as the procedure for requesting that certain 19 internet content be unblocked by the filter. Mr. Marney will discuss the unblocking requests NCRL has received from patrons and the process that he and Mr. Howard follow in evaluating the requests. Mr. Marney wil also discuss the other purposes the Internet filters serve, beyond compliance with CIP A, to 20 21 22 23 24 25 include: (1) fulfillment of traditional collection decisions; (2) protection of staff 26 27 28 DEFENDANT NORTH CENTRAL REGIONAL LIBRARY'S AMNDED WITNSS AND EXHIBIT LIST - 2 CV -06-327-EFS Lmi' Offces KARR TUTTLE CAMPBELL A Professional Service Corporation 1201 Third Avenue, Suite 2900, Seattle. Washington 98101-3028 Telephone (206) 223-1313, Facsimile (206) 682-7100 #664851 vI /42703-001 1 and patrons from inadvertent exposure to ilegal, pornographic, or other 2 3 disruptive and inappropriate material; and (3) compliance with other state and federal laws. 4 5 2. Dan Howard 6 7 8 Dan Howard is the Public Services Director for NCRL. Mr. Howard administers NCRL's 28 branch libraries and its mail order library. He also 9 10 11 coordinates collection development activities and administer grants. With respect to the individual branches, Mr. Howard's responsibilities include, among 12 13 other things, management of personneL. This includes supervision of all NCRL branch librarians. 14 15 Mr. Howard wil testify regarding NCRL's policies, to include: its mission statement, collection development policy and internet usage policy. He 16 17 18 wil discuss the relationship between the filter and collection development. He 19 20 21 wil testify regarding his district's need to comply with the Children's Internet Protection Act ("CIPA"). Mr. Howard wil also discuss NCRL's current 22 23 internet filtering profile and the procedure for requesting that certain internet 24 25 content be unblocked. Mr. Howard wil discuss the unblocking requests that 26 27 28 DEFENDANT NORTH CENTRAL REGIONAL LIBRAY'S AMENDED WITNSS AND EXHIBIT LIST - 3 CV -06-327-EFS #664851 v I /42703-00 I Lmy Offces KARR TUTTLE CAMPBELL A Professional Service Corporation 1201 Third A\'cnuc, Suite 2900. Seattle. WasbiDglon 98iol~3028 Telephone (206) 223-1313, Facsimile (206) 682-7100

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