Bradburn et al v. North Central Regional Library District

Filing 63

DECLARATION by Dan Howard in Support 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. 63

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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 Defendant North Central Regional Library District

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UNITED STATES DISTRICT COURT EASTERN DISTRICT OF WASHINGTON AT SPOKANE

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SAR BRABURN, PEAR
CHERRNGTON, CHAES
HEINEN, and THE SECOND

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AMENDMENT FOUNATION,
Plaintiffs,
v.

) ) ) NO. CV-06-327-EFS )

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DECLARATION OF DAN HOWARD ) IN SUPPORT OF DEFENDANT ) NORTH CENTRAL LIBRARY ) DISTRICT'S REPLY TO ITS
)

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NORTH CENTRAL REGIONAL LIBRARY DISTRICT,

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Defendant.

) ) ) ) ) )

MOTION FOR SUMMAY
JUDGMENT

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DECLARATION OF DAN HOWAR IN SUPPORT OF DEFENDANT NORTH CENTRAL LIBRARY DISTRICT'S REPLY TO ITS MOTION FOR SUMARY JUDGMENT - 1
CV-06-327-EFS
#66 i 598 v i /42703-00 i

I.all Ojjices

KARR TUTTLE CAMPBELL
A Professional Service Corporaf;on
1201 Third A,'cnuc. Suile 29UU, Seattle, Washington 981111-3028 Tclci,honc [phone], Fac~milc (2116) 682-7100

Dockets.Justia.com

i, Dan Howard, declare as follows:
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1. I am over the age of 18 and competent to testify to the matters set

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fort herein.

2. I am the Director of

Public Services for NCRL.

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3.

Of the 81 automated requests NCRL received between October

8 2007 and February 1, 2008, 65 were evaluated within 24 hours. The remaining

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16 requests were typically made over a weekend or holiday. Accordingly,
decisions could not be made on the same day.
4.

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NCRL has responded to all requests for unblocking provided a

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patron provides contact information.
5.

Certn

ci tes

highlighted

by

Plaintiffs,

including:

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17 www.keyartpromotions.com, www.arbyjohndan.com.; www.pethandbook.com;

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www.firstthngslst.com; and www.ourfamily-web.com have all been unblocked.
6.

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NCRL refuses to unblock image search sites on the grounds that it

alows patrons to circumvent the fiter to obtain obscene, ilegal or pornographic

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material. However, NCRL does provide access to other image databanks and

24 other resources for the requested materiaL.
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DECLARA nON OF DAN HOWARD IN SUPPORT OF DEFENDANT NORTH CENTRAL LIBRARY DISTRICT'S REPLY TO ITS MOTION FOR SUMMARY JUDGMENT - 2
CV-06-327-EFS
#661598 vI /42703-001

ÚJW OJJcu

KARR TUTTLE CAMPBELL
A Profusiontl Service CorporøOll

1201 nuA.'Or.5i-I, ag!i w..Ia... 91101.3 T,,__(1 iu.iJIJ, '_li:, (20 "1-100