Bradburn et al v. North Central Regional Library District

Filing 65

DECLARATION by Barbara Walters 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. 65

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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

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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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SARAH BRABURN, PEAR CHERRGTON, CHARLES
HEINLEN, and THE SECOND

AMENDMENT FOUNATION,
Plaintiffs,
v.

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

BARAR

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NORTH CENTRAL REGIONAL LIBRARY DISTRICT,

) ) ) ) )
) ) ) )

WALTERS IN SUPPORT OF DEFENDANT NORTH CENTRAL LIBRARY DISTRICT'S REPLY TO

ITS MOTION FOR SUMARY
JUDGMENT

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Defendant.

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DECLARATION OF BARBARA
W ALTERS IN SUPPORT OF

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DEFENDANT NORTH CENTRAL LIBRARY DISTRICT'S REPLY TO ITS MOTION FOR SUMMARY JUDGMENT - 1
CV-06-327-EFS
#66 i 598 vi /42703-001

Law Offces

KARR TUTTLE CAMPBELL
A Professional Service Corpora/ion
1201 Third Avenue, Suite 2900. Seattle, Washington 98101-3028 Telephone (206) 223~13iJI Facsimile [phone]

Dockets.Justia.com

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

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forth herein.
2. I am the Information Technology Manager for NCRL.

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3. Internet access was gradually made available at NCRL branch

locations. Plaintiffs' correctly note that the first branch with Internet access was
NCRL's Omak branch, which went online in November 1999.
4. The second branch was NCRL's Wenatchee branch, which went

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online in January 2000.

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5. NCRL used a Surfwatch brand filter at both the Wenatchee and
Omak locations, however, the filtering software consistently froze the public use
computers that they were installed on.

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6. NCRL implemented its first system-wide Internet filter II
December 2000 and that filter was referred to as "BESS."
7. In December 2000, most of NCRL's branches did not have public

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internet computers. In fact, Internet access was not available at all 28 branches

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DECLARATION OF BARBAR
WALTERS 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

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Law Offces

KARR TUTTLE CAMPBELL
A Professional Serv;ce Corporation
1201 Third Avenue, Suite 2900, Seattle, Waiihington 98101-3028 Telephone [phone], Facsimile [phone]