Bradburn et al v. North Central Regional Library District

Filing 30

DECLARATION by Thomas D. Adams in Support re 28 MOTION for Summary Judgment filed by North Central Regional Library District. (Attachments: # 1 Exhibit Exhibit A, Pages 5-14, # 2 Exhibit Exhibit B, Pages 15-24, # 3 Exhibit Exhibits C & D, Pages 25-34, # 4 Exhibit Exhibits E-G, Pages 35-57)(Adams, Thomas)

Bradburn et al v. North Central Regional Library District

Doc. 30

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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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SARAH BRADBURN, PEARL

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CHERRNGTON, CHARLES
HEINLEN, and THE SECOND

) )

AMENDMENT FOUNATION,
Plaintiffs,
v.

) NO. CV-06-327-EFS )

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DECLARATION OF THOMAS D. ADAMS IN SUPPORT OF ) DEFENDANT'S MOTION FOR
) )

)
) ) ) ) ) )

SUMARY JUDGMENT

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NORTH CENTRAL REGIONAL 20 LIBRARY DISTRICT,
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Defendant.

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I, Thomas D. Adams, declare as follows:
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I am over the age of 18 and competent to testify to the matters set

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forth herein.
DECLARA TION OF THOMAS D. ADAMS - 1
CV-06-327-EFS
#656588 v i /42703-00 i

Law Offces

KARR TUTTLE CAMPBELL
A Professional Service Corpora/ion
1201 Third A\'cnuc, Suile 2911~ Seatte. Wllshin~lUn 9811)1-31128 Tclciihonc (lOG) 223-13 13, Fac...iinilc (206) 6S2~71H1I

Dockets.Justia.com

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2. Attached as Ex. A are relevant portions of the transcript from

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Mr. Alan Gottlieb's deposition (Second Amendment Foundation 30(b)(6)
deposition) taken September 12,2007.

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3. Attached as Ex. B are relevant portions of the transcript from
Ms. Sarah Bradburn's deposition taken August 13, 2007.

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4. Attached as Ex. C are relevant portions of the transcript from
Ms. Pearl Cherrington's deposition taken August 13,2007.

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5. Attached as Ex. D are relevant portions of Ms. Cherrington's
responses to Defendant's First Interrogatories and Requests for Production.

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6. Attached as Ex. E are relevant portions of the transcript from
Mr. Heinlen's deposition taken on August 13, 2007.

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7. Attached as Ex. F is a January 15, 2008 article from The Dallas

Morning News, "On Dallas Library Computers, Porn is a Regular Sight,"
obtained on-line January 22, 2008.
8. Attached as Ex. G is a August 16, 2003 article from

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Brainerddispatch.com, "Librarians Settle Internet Porn Case," obtained on-line
January 30, 2008.
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DECLARATION OF THOMAS D. ADAMS - 2
CY-06-327-EFS
#656588 v i /42703-00 i

Lmi' Offlces

KARR TUTTLE CAMPBELL
A Professional Service Corporation
12111 Third Ai'cnuc, Suile 2900, SCiitllC, Wushingion 98101-31128 Telephone [phone], Fac...imilc (206) 6S2~ 7100