Bradburn et al v. North Central Regional Library District

Filing 29

STATEMENT OF FACTS re 28 MOTION for Summary Judgment filed by North Central Regional Library District. (Adams, Thomas)

Bradburn et al v. North Central Regional Library District

Doc. 29

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The Honorable Edward F. Shea
Thomas D. Adams

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3 Celeste Mountain Monroe

4 KARR TUTTLE CAMPBELL
5 1201 Third Avenue, Suite 2900

Seattle, Washington 98101-3028

6 [phone]

7 Attorneys for North Central Regional Library District
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UNITED STATES DISTRICT COURT EASTERN DISTRICT OF WASHINGTON AT SPOKANE

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13 SARAH BRADBURN, PEARL
14 CHERRINGTON, CHARLES
15 HEINLEN, and THE SECOND
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)
)

AMENDMENT FOUNATION,
Plaintiffs,
v.

) NO. CV-06-327-EFS )

) DEFENDANT NORTH CENTRAL
) REGIONAL LIBRARY DISTRICT'S ) STATEMENT OF FACTS IN ) SUPPORT OF MOTION FOR

19

) SUMMARY JUDGMENT
NORTH CENTRAL REGIONAL LIBRARY DISTRICT,
) ) ) )
)

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Defendant.

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26 DEFENDANT NORTH CENTRAL
27 REGIONAL LIBRARY DISTRICT'S STATEMENT OF FACTS IN SUPPORT

28 OF MOTION FOR SUMMARY
JUDGMENT - 1
CV-06-327-EFS
#657989 vI /42703-001
Law Offces

KARR TUTTLE CAMPBELL
A Professional Service Corporation
1201 Third A\'enue, Sui Ie 2900, Scal1lc, Washington 9SIOI-J028 Telephone [phone], Facsimile (2116) 682-7100

Dockets.Justia.com

1

A.
1.

The North Central Regional Library
North Central Regional Library ("NCRL" or "District") is an inter-county
library district and municipal corporation established in 1 960. Declaration
Dean Marney ("Marney Decl.") at iT 3.

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rural

of

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NCRL is organized and operated pursuant to RCW 27.12 et. seq. Id at iT4.

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3. NCRL provides public library services to over 220,000 people in the areas
of

Chelan, Douglas, Ferr, Grant and Okanogan counties. Id at iT5., Ex. A.

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4. The District is funded by local property taxes, federal money, private
grants and endowments. Id. at iT6.

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5, Management and control of NCRL is vested in a board of trustees ("the

Board") composed of two trustees from each of Chelan and Grant counties and
one trustee each from Douglas, Ferr, and Okanogan counties. Id. at iT7.

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6. The Board is responsible for issuing all policies for the District. Id. iT8.

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7. The Board appoints a Director, who manages the library and directs the

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employees. The Director serves as the liaison between the Board and library
DEFENDANT NORTH CENTRAL REGIONAL LIBRARY DISTRICT'S STATEMENT OF FACTS IN SUPPORT OF MOTION FOR SUMMARY JUDGMENT - 2
CY-06-327-EFS
#657989 v i /42703-00 i

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27 28

Lall Offices

KARR TUTTLE CAMPBELL
A Profe.';sional Service Corporation
1201 Third A"cnuc. Suile 2900, Seattle. Washin~ton 98 HIIw31128 Tcleiiliiinc (2116) 22JwlJIJ, Fllcsimilc (2116) 682.71011