Bradburn et al v. North Central Regional Library District

Filing 81

AMENDED OBJECTIONS to 70 Witness and Exhibit Lists by North Central Regional Library District. (Monroe, Celeste) Modified on 4/8/2008 to link to document (CV, Case Administrator).

Bradburn et al v. North Central Regional Library District

Doc. 81

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The Honorable Edward F. Shea
Thomas D. Adams

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3 Celeste Mountain Monroe

4 KA TUTTLE CAMPBELL
5 1201 Third Avenue, Suite 2900

Seattle, Washington 98101-3028

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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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SAR BRABUR, PEARL
CHERRNGTON, CHAES
HEINEN, ~d THE SECOND

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AMENDMENT FOUNATION,
Plaintiffs,
v.

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) ) ) NO. CV-06-327-EFS ) ) DEFENDANT NORTH CENTRAL
) REGIONAL LIBRARY'S AMNDED ) OBJECTIONS TO PLAINTIFFS' ) WITNSS AND EXHIBIT LIST ) WITH ATTACHED EXHIBITS ) ) ) ) )

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NORTH CENTRAL REGIONAL LIBRARY DISTRICT,

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Defendant.

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DEFENDANT NORTH CENTRAL REGIONAL LIBRARY'S AMENDED OBJECTIONS TO PLAINTIFFS'

WITNSS AND EXHIBIT LIST WITH ATTACHED EXHIBITS - 1
CV-06-327-EFS
#665611 vi /42703-001

Law Offces

KARR TUTTLE CAMPBELL
A Professional Service Corporation
1201 Third Al'cnuc, Suite 2900, Seatte, WasbiDglon 98t01~3028 Telephone [phone], Facsimile [phone]

Dockets.Justia.com

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Defendant North Central Regional Library ("NCRL") resubmits its
objections to the following witnesses and exhibits, attaching referenced exhibits

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hereto. NCRL also amends its objection to Exhibit 73 as set forth on page 10
herein.

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I. Objections to Plaintiffs' Witness List

NCRL has moved to strike Kenton Oliver, Sally Beesley and June
Pinnell-Stevens from Plaintiffs' Witness List in its Motions in Limine for the
reasons that follow:
1. Sally Beesley and Kenton Oliver should be excluded from trial as

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their testimony is irrelevant.
Plaintiffs have identified Sally Beesley as a fact witness. Ms. Beesely is

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the Director of the Jefferson County Library District ("JCLD") in Madras,
Oregon. Plaintiffs propose to call Ms. Beesley to testify "about her library's

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policies, procedures and experiences with regard to Internet filters." In addition,
Plaintiffs propose to have Ms. Beesley testify regarding "alternatives to refusing
to disable Internet filters at the request of adult library patrons; the JCLD's

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Internet policies and procedures; how the JCLD's Internet policies and
procedures have been implemented; her experience working with Internet
DEFENDANT NORTH CENTRAL REGIONAL LIBRARY'S AMENDED OBJECTIONS TO PLAINTIFFS'

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WITNSS AND EXHIBIT LIST WITH ATTACHED EXHIBITS - 2
CV -06-327-EFS
#665611 vi /42703-001

Law Offces

KARR TUTTLE CAMPBELL
A Professional Service Corporation
1201 Tbird Avenue, Sui Ie 2900, Sciillle, Wasbin~toD 98101-3028 Telephone [phone], Facsimile [phone]

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policies, procedures and filters; and the consequences of providing unfiltered
access at JCLD's computers."

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Plaintiffs have also identified Kenton Oliver as a fact witness. Mr. Oliver

is the Executive Director of the Stark County District Library ("SCDL") in

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Canton, Ohio. Plaintiffs intend to call Mr. Oliver to testify "about his library
system's policies, procedures and experiences with regard to Internet filters." In

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addition, Mr. Oliver is expected to testify regarding "alternatives to refusing to
disable Internet filters at the request of adult library patrons; the SCDL' s

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Internet policies and procedures; how the SCDL's Internet policies and
procedures have been implemented; his experience working with Internet

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policies, procedures and filters; and the consequences of allowing patrons of the
SCDL to bypass the library's Internet filter."

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Plaintiffs offer Ms. Beesley's and Mr. Oliver's testimony to show
(1) some libraries do not use filters or wil remove the filter at the request of an
adult patron and (2) some of the same libraries do not report any problems with
their Internet policies. With respect to the first point, the fact that some libraries

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do not use filters, or will remove the filter on the request of an adult patron, is

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DEFENDANT NORTH CENTRAL REGIONAL LIBRARY'S AMENDED OBJECTIONS TO PLAINTIFFS' WITNESS AND EXHIBIT LIST WITH ATTACHED EXHIBITS - 3
CV-06-327-EFS
#665611 vI /42703-001

Law Offces

KARR TUTTLE CAMPBELL
A Professional Service Corporation
1201 Third A"CDUC, Suite 2900, Scallle. WllshiDgloD 98101-3028 Telephone [phone], Facgmilc [phone]