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 Att. 1

Exhibit A
Deel of Adams
Page 5

Dockets.Justia.com

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF WASHINGTON AT SPOKANE
SARAH BRADBURN, PEARL CHERRINGTON, CHARLES HEINLEN, and THE SECOND
AMENDMENT FOUNDATION,
pl ai nti ffs,

) No. cv-06-327-EFS

)
) )

vs.
NORTH CENTRAL REGIONAL

LIBRARY DISTRICT,

) ) ) ) ) )

Defendant.

~ CCölli

DEPOSITION UPON ORAL EXAMINATION OF ALAN MERRIL GOTTLIEB
September 12, 2007
Seattl e, washi ngton

Taken Befo re :
cheryl L Hendricks, CCR #2274 Certified Court Reporter

CAPITOL PACIFIC REPORTING, INC.
2401 Bristol Court SW, olympia, WA 98502 Tel [phone] Fax [phone]

of

Tacoma Seattl e Aberdeen
[phone] [phone] [phone]
[phone] [phone]

Chehal i s Bremerton

schedul i ngØcapi to 1 paci fi creporti ng. com
Decl of Adams
Page 6
1

www.capitolpacificreporter.com

CAPITOL PACIFIC REPORTING, INC. [phone]

A 1 an Gottl i eb - by Mr. Adams

1
2
3

Q

okay. Di d you use a compute r te rmi nal 1 n any of those

libraries?
A Q

I can't say with certainty if I did or did not.

4
5

Are you aware of any other SAF representatives usl ng a
computer at an NCRL 1 i brary branch?

6
7

A
Q

NO, I am not.
okay. In the fi fth parag raph on the fi rst page of
Exhi bi t 18 there 1 s a quote that is attri buted to you.

8 9

Do you see that?
A
Q

10

Yes.
And it says that, "we," meani ng the SAF I presume,
"ente red thi s 1 awsui t because ci ti zens are bei ng deni ed

11
12 13

access to our website and information about our

14
15

organization and publication. That clearly violates
both the Fi rst Amendment of the U. S. Consti tuti on and

16 17 18 19 20
A
Q

the washi ngton State Consti tuti on. "

Do you see whe re i'm readi ng?
Yes.

okay. How di d you determi ne that ci ti zens were bei ng
deni ed access to the SAF websi te and i nformati on
available through it and its sister publications?

21
22
A

peop 1 e who call ed ou r offi ce and i also bel i eve may have

23

called our New York office as well because one of our
publications is actually published out of there.
Q

24
25

So SAF has a New York offi ce?
Decl of Adams
Page 7

40

CAPITOL PACIFIC REPORTING, INC. [phone]