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

Filing 9

SUGGESTIONS in support re 6 MOTION for preliminary injunction filed by Ann Elizabeth Blackwell on behalf of Plaintiffs Campus Pride, Inc., Dignity, Inc., Matthew Shepard Foundation, Parents, Families, and Friends of Lesbians and Gays, Inc.. (Attachments: # 1 Exhibit A, # 2 Exhibit A-1, # 3 Exhibit A-2, # 4 Exhibit A-3, # 5 Exhibit A-4, # 6 Exhibit A-5, # 7 Exhibit B, # 8 Exhibit C, # 9 Exhibit D, # 10 Exhibit E, # 11 Exhibit F)(Related document(s) 6 ) (Blackwell, Ann)

UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF MISSOURI
CENTRAL DIVISION
Parents, Families and Friends of Lesbians and Gays, Inc.,
et al.
Plaintiffs
Case No. 2:11-cv-04212
V.

Camdenton R-III School District, et al.
Defendants

DECLARATION OF MARIANNE DUDDY-BURKE
IN SUPPORT OF PLAINTIFFS' MOTION
FOR PRELIMINARY INJUNCTION
Pursuant to 28 U.S.C.

§

1746, Marianne Duddy-Burke hereby declares as follows:

I am the Executive Director

of Plaintiff Dignity, Inc., dlb/a DignityUSA

("DignityUSA"), am competent to testify and have personal knowledge of the matters in this
Declaration.
I

make this Declaration in support of Plaintiffs' Motion for Preliminary

Injunction.
DignityUSA is a non-profit organization incorporated in the District of Columbia.
Its business address is P.O. Box 376, Medford, Massachusetts, 02155.

DignityUSA is the oldest arid largest national lay movement of lesbian, gay,

bisexual and transgender Catholics. DignityUSA envisions and works for a time when Gay,
Lesbian, Bisexual and Transgender Catholics are affirmed and experience dignity through the

integration of their spirituality with their sexuality, and, as beloved persons of God, participate
fully in all aspects of life within the Church and society.

1

DignityUSA has approximately 6,000 members nationwide and 155 members in
Missouri. It has chapters located throughout the United States.

On a national level, DignityUSA advocates for change in the Catholic Church's

teachings on homosexuality; provides educational materials, speakers, and other resources to
Catholic parishes, gay ministries, and other interested groups; and maintains an ongoing dialogue
with Catholic bishops and other Church leaders. In local chapters, members worship openly with

other LGBT and supportive Catholics, socialize, share personal and spiritual concerns, and work
together on educational and social justice issues.
DignityUSA seeks to communicate with students because young people are often
discovering their sexual orientation and/or gender identity and need resources that address

questions they may have. Many feel shame and isolation due to messages they have received
from religious authorities or their religious traditions.

The ability to present gay-positive

religious messages is important in helping create space and freedom for students and other young
people to begin to accept affirming messages.
Dignity USA maintains an internet website located at http://www.dignityusa.org.
The website provides information regarding the organization and its ministries, answers

frequently asked questions regarding Catholicism and homosexuality, and provides resources for
those visiting the site, including a Young Adult Caucus for gay and lesbian youth on its blog.
Several of DignityUSA' s local chapters and affiliates maintain websites,

including dignityboston.org, dignityhouston.freeyellow.com, dignitypacific.org, and
dignitysd.org.

None of DignityUSA's websites contains pornography or sexually explicit
content.

2

DignityUSA's websites are important tools in its communication efforts. Many
students and young people, particularly in rural areas, do not have the ability to join groups for

LGBT and allied individuals. They may not feel comfortable checking materials out of libraries
where they are known to staff. They may not feel safe speaking about issues of sexuality and

gender identity by telephone. Being able to access websites where they can read information,
send messages privately, and post questions or comments on blogs is particularly important to

this group.

DignityUSA's website includes a Young Adult Caucus on its blog that students
may particularly wish to access.
I

declare under penalty of perjury that the foregoing is true and correct.

Executed on August 11, 2011

Marianne Duddy-Burke