Parents, Families, and Friends of Lesbians and Gays, Inc. et al v. Camdenton R-III School District et al

Filing 28

MOTION for leave to file supplemental suggestions in support of motion for preliminary injunction filed by Anthony E. Rothert on behalf of All Plaintiffs. Suggestions in opposition/response due by 9/16/2011 unless otherwise directed by the court. (Attachments: # 1 Supplement Supplemental Suggestions in Support of Motion for Preliminary Injunction, # 2 Affidavit Declaration of Jane Doe)(Rothert, Anthony)

UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF MISSOURI
CENTRAL DIVISION

Parents, Families, and Friends of Lesbians
and Gays, Inc., et al.,
Plaintiffs,
v.
Camdenton R-III School District; et al.,
Defendants.

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No. 2:11-cv-04212-NKL

DECLARATION OF JANE DOE
1.

I am a Plaintiff in the case No. 2:11-cv-04212-NKL, Parents, Families, and

Friends of Lesbians and Gays, Inc. et al v. Camdenton R-III School District, proceeding with
the use of a pseudonym.
2.

The statements in this declaration are based on my personal knowledge.

3.

I am currently a student at Camdenton High School in the Camdenton R-III

School District. Prior to attending Camdenton High School, I attended Camdenton Middle
School, which is also in Camdenton R-III School District.
4.

I have used, and plan to continue to use, computers in the Camdenton High

School library to access information on the Internet. The library computers allow students to
search for information using search engines; however, some websites are blocked.
5.

I also had the opportunity to use the computers in the library at Camdenton

Middle School to browse the Internet.
6.

I am straight, but I have several friends at school who are gay or bi-sexual.

7.

I have no complaints about the teachers at Camdenton Middle School or

Camdenton High School. In my experience, they do their best to educate all of their students.
8.

Unfortunately, in my experience, the Camdenton Middle School and Camdenton

High School are not friendly places for students who are gay or lesbian, or who people think are
gay or lesbian. I have witnessed my friends being teased, taunted, and called names because
other kids think they might be gay. While the teachers are great, the kids are vicious. I myself
have been taunted just for being supportive of my gay friends.
9.

I tried to be supportive of all of my friends, regardless of their sexual orientation.

10.

I would like to be able to use computers in the library to access information on the

Internet that would help me support my friends, but many websites that are supportive of gay
and lesbian people are blocked at my school.
11.

I want to be able to access information on diverse ideas and issues, including

information about lesbian, gay, bi-sexual, and transgender people, but I am prevented from
doing so by the software blocking sites on the Internet.
12.

I would not feel comfortable asking for a website that is supportive of lesbian,

gay, bi-sexual, and transgender people to be unblocked because I am afraid doing so will draw
attention to me and make me the subject of further taunting.
Pursuant to 28 U.S.C. § 1746, I declare under penalty of perjury that the foregoing is true
and correct.

August 30, 2011

/s/ Jane Doe
Jane Doe