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Bradburn et al v. North Central Regional Library District Doc.

84

1 The Honorable Edward F. Shea


2
Thomas D. Adams
3 Celeste Mountain Monroe
4 KARR TUTTLE CAMPBELL
5 1201 Third Avenue, Suite 2900
Seattle, Washington 98101-3028
6 (206) 223-1313

7 Attorneys for North Central Regional Library District


8

9
UNITED STATES DISTRICT COURT
10
EASTERN DISTRICT OF WASHINGTON
11 AT SPOKANE
12
13

14 SARAH BRADBURN, PEARL )


CHERRNGTON, CHARLES )
15
HEINLEN, and THE SECOND ) NO. CY-06-327-EFS
16 AMENDMENT FOUNATION, )
17 ) NCRL'S RESPONSE TO
Plaintiffs, ) PLAINTIFFS' OBJECTIONS TO
18 ) DEFENDANT'S WITNESSES AND
19 v. ) EXHIBIT LIST
)
20 NORTH CENTRAL REGIONAL )
21 LIBRARY DISTRICT, )
22 )
Defendant. )
23 )
24
Defendant NCRL hereby responds to Plaintiffs Objections to Defendants'
25
26 Wi tness and Exhibit List.
27
NCRL'S RESPONSE TO PLAINTIFFS'
28 OBJECTIONS TO DEFENDANT'S
WITNESSES AND EXHIBIT LIST - 1 l.alO 0llices

CV-06-327-EFS KARR TUTTLE CAMPBELL


DOCS.66SS371 - A I'r(~fe.\sional .)'erv/ce Corpora/ion
12111 Third An:nuc, Suite 291~i, Seallie. Washin~ll1n IJHIUI-J02H
lclcl'liunc (2'1l'í) 223-13 13, Fiicsiinilc (2116) 6H2-7 1011

Dockets.Justia.com
1 I. WITNESSES
2
Plaintiffs' arguments in support of its objections to the introduction of
3

4 NCRL witnesses Connie Kuhlman, Sharon Reddick, Katy Sessions, and


5 Deborah Moore are set forth in Plaintiff s Motions in Limine. This pleading
6
was filed separately from Plaintiffs' Objections to NCRL's Witness and Exhibit
7
8 List. Accordingly, NCRL reserves its response to Plaintiffs' arguments
9
regarding the introduction of Kuhlman, Reddick, Sessions and Moore for its
10
11 opposition to Plaintiffs' Motion in Limine, which is scheduled to be filed on or
12
before April 11, 2008.
13

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II. EXHIBITS
15 A. NCRL's Exs. 533-536
16 NCRL seeks to introduce four incident reports prepared by NCRL branch
17
librarians between 2005 and 2008 detailing instances where sex offenders have
18

19 patronized NCRL branch libraries and created disruptions or posed a threat to


20
children, as well as one situation where an individual was asked to leave the
21
22 library for inappropriate sexual conduct in a library setting. Plaintiffs object to
23
the incident reports, arguing that the documents are hearsay and that they are
24
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irrelevant.

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NCRL'S RESPONSE TO PLAINTIFFS'
28 OBJECTIONS TO DEFENDANT'S
WITNSSES AND EXHIBIT LIST - 2 Law Offces

CV -06-327-EFS
KARR TUTTLE CAMPBELL
DOCS.66SS371 - A Professional Sen!ice Corpora/ion
I2U1 Third A,'cnuc, Suile 2!JULI, SCiiiilc, W;ishin~lnn 98101-31128
Telephone (2U6) 223.13 13, Facsimile (206) 6S2-7WiI
1 Plaintiffs hearsay objection is easily overcome by the business records
2
exception. The reports are writings or records of act/events, made at or near the
3

4 time of the incidents, or from information transmitted by a person with

5
knowledge of the incident. The reports were kept and turned over to NCRL
6
7 administrators Dan Howard and Dean Marney in the normal course of business.
8 The incident reports were not prepared in anticipation of litigation.
9
Accordingly, Plaintiffs' hearsay objection lacks merit.
10
11 Second, the documents are relevant. When asked why NCRL has elected
12
to employ the filter at all times, Executive Director Dean Marney testified that,
13

14 among other things, "Libraries have a peculiar problem that we attract a certain
15
element in our communities that isn't always family friendly." (Marney Dep. at
16
p. 55). These incident reports are evidence of unique risks associated with
17
18 operating a public library, which NCRL administrators believe offers further
19
support for their decision to filter content such as adult materials and
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21 pornography.
22
Plaintiffs suggestion that the incidents detailed in the proffered reports
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24 "have nothing to do with any of the issues before the Court" is disingenuous.
25
(Ct. Rec. 80, p. 4). Plaintiffs ask the Court to consider NCRL's Internet Usage
26
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NCRL'S RESPONSE TO PLAINTIFFS'
28 OBJECTIONS TO DEFENDANT'S
WITNSSES AND EXHIBIT LIST - 3 KARR TUTTLE CAMPBELL
I.aw Offces

CV-06-327-EFS
DOCS.66SS371 - A Professional Service Corpora/ion
1201 Third r\\cnUl~1 Suile 29110, ScatHe, Washin~liin 98101-3028
Telephone (206) 223-13 13, Facsimile (206) 682.7HlO
1 Policy in a vacuum, without reference to the types of conduct and issues that
2
inform, and continue to justify, the Policy. Plaintiffs can argue as to the weight
3

4 the reports should be given at trial, but they cannot passively contend that the
5
reports are relevant and admissible.
6
7 B. NCRL Exhibits 542-645
8 NCRL seeks to introduce all patron unblocking requests and related
9
correspondence. In its original disclosure, NCRL envisioned identifying each
10
11 request and response as a separate exhibit - which would be numbered
12
approximately Exs. 542-645. Although NCRL did not provide Plaintiffs with a
13

14
copy of these exhibits (specifically labeled Exs. 542-645) for purposes of

15 exchanging exhibit lists, Plaintiffs were certainly in possession of all of the


16
documents NCRL intends to include as they are all, for the most part, contained
17
18 in Plaintiffs' Ex. 66.
19
At this time, NCRL and Plaintiffs counsel have conferred and believe that
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21 both parties wil be able to use Plaintiffs' Ex. 66, which was reserved as

22 NCRL's Ex. 702, at triaL. The parties intend to work together to refine and
23
update the exhibit in the coming weeks. In the event that there is any dispute
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NCRL'S RESPONSE TO PLAINTIFFS'
28 OBJECTIONS TO DEFENDANT'S
Lall Offces
WITNESSES AND EXHIBIT LIST - 4
CY-06-327-EFS
KARR TUTTLE CAMPBELL
A IJrafè.\.,\'onal Sei,ijc:e CorporaflOn
DOCS-66SS371 -
12111 Third A\'cnLlc, Suiic Z'JUU, ScalUc. Waiihinginn 9HIlJl-J1I2H
Tclqihunc (211(,) 223-13 i 3, Facsimile (2U6) 6HZ.711111
1 between what should and should not be included, NCRL wil fill its document
2
separately under NCRL Ex. 702.
3

4 C. NCRL's Ex. 699


5 NCRL seeks to introduce a letter from the ACL U of Washington to
6
NCRL library patrons as Ex. 699. NCRL's Executive Director Dean Marney
7
8 obtained this letter from a library staff member. NCRL does not intend to
9
introduce the letter for the truth of the mater asserted therein, i.e. that NCRL was
10
11 allegedly "depriving patrons of making choices" or depriving "parents of the
12
ability to make the choice for their children." Rather, NCRL introduces the
13

14
letter to show that the ACLU actively solicited litigants to advance its view of

15 internet filtering in public libraries. Accordingly, Plaintiffs' hearsay objection


16
lacks merit.
17
18 D. NCRL's Exs. 706-720
19 On March 24, 2008, NCRL filed its Original Witness and Exhibit List.
20
21 (See Ex. A attached hereto.) The following day, NCRL e-mailed Plaintiffs'

22 counsel a list of all of its exhibits with references to bates numbers and court
23
record cites for each document. On March 28, 2008, Plaintiffs' counsel
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25 contacted NCRL' s counsel, Celeste Monroe, to inform Ms. Monroe that the two
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NCRL'S RESPONSE TO PLAINTIFFS'
28 OBJECTIONS TO DEFENDANT'S
WITNESSES AND EXHIBIT LIST - 5 I.aii' OJ/ìce.i'

CV-06-327-EFS KARR TUTTLE CAMPBELL


DOCS.66SS371 - A Profe.\'sional Service Corporafion
12Ul Third A,'cnuc, Suiic 2lJIlII, Seatte, Wilshin~l()n 98~i1-3028
Telephone (206) 22J-IJ 13, Facsimile (2116) 682-71011
1 documents were inconsistent. Specifically, there were more documents on the
2
e-mailed version ofNCRL's exhibit list than on the one that was filed.
3

4 After some investigation, it was revealed that NCRL accidentally filed a


5
draft version of the witness and exhibit list, as opposed to the final version. (See
6
7 Ex. B attached hereto.) NCRL thanked Plaintiffs for bringing the matter to their

8 attention and immediately filed an Amended Witness and Exhibit List. (See Ex.
9
C attached hereto). Plaintiffs' counsel thanked NCRL for the clarification. (See
10
11 Ex. B).
12
In light of the parties' exchange and NCRL' s prompt correction of its
13

14 error, NCRL was surprised to receive Plaintiffs' objections to the Amended


15
Witness and Exhibit List. This was particularly true given that Plaintiffs had
16
17 received a complete list of the items contained in the Amended Witnesses List,

18 via e-mail, less than 24 hours after the original (albeit draft) version was filed.
19
In any event, Plaintiffs' objections to the introduction of these exhibits as
20
21 untimely, should be overruled.
22
As an initial matter, NCRL explicitly reserved its rights to amend its
23
24 witness and exhibit list. Furthermore, Plaintiffs' cannot demonstrate prejudice.

25 The documents that were accidentally omitted from the original filing include a
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NCRL'S RESPONSE TO PLAINTIFFS'
28 OBJECTIONS TO DEFENDANT'S
WITNESSES AND EXHIBIT LIST - 6 I.all Offices

CV -06-327-EFS
KARR TUTTLE CAMPBELL
DOCS.66SS371 - A Professional Service Corporarion
liOt Third Aveiiiie. Suite 291IU, Scaiiic. Washin¡:IO" 9HIIII-J02H
Tclciihoiic (206) 223.1313, facsimile (2U6) 682-7)111
1 number of newspapers articles collected by Mr. Marney discussing widespread
2
problems with unfiltered Internet access at public libraries throughout the
3

4 county, as well as written discovery of the parties. None of these documents


5
were new to Plaintiffs. The newspapers articles were submitted by NCRL in
6
7 support of its motion for summary judgment and counsel has already engaged in
8 considerable debate regarding their admissibility. The written discovery was
9
exchanged over a year ago. In the absence of any prejudice to Plaintiffs, NCRL
10
11 should be permitted to introduce Exs. 706-720 at triaL.
12
Beyond the timeliness of their disclosure, Plaintiffs' have raised several
13

14 other challenges to the admissibility of the newspaper articles, including a


15
hearsay challenge. Plaintiffs arguments on these points are contained in their
16
17
Motions in Limine. Accordingly, NCRL reserves its response to Plaintiffs'
18 arguments regarding the admissibility of the newspaper articles for its
19
opposition to Plaintiffs' Motion in Limine, which is scheduled to be filed on or
20
21 before April 11, 2008.

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NCRL'S RESPONSE TO PLAINTIFFS'
28 OBJECTIONS TO DEFENDANT'S
WITNESSES AND EXHIBIT LIST - 7 I.all ()ßh'es

CY -06-327-EFS
KARR TUTTLE CAMPBELL
DOCS.66SS371 - A Projè.\'.\ional Service Corporation
1211 Third A"cnuc, Suiic 2911l. ScilUlc. Wiishin~lnn 9H1UI-3UZH
Telephone (2U6) 223-1313, Facsimile (2U6) 68Z-71un
1

2 DATED this ih day of April, 2008


3
KARR TUTTLE CAMPBELL
4
By:ls/ Celeste Mountain Monroe
5
Celeste Mountain Monroe, WSBA #35843
6 E-mail -cmonroe(fkarruttle.com
7 Thomas D. Adams, WSBA #18470
E-mail-tadams(fkarruttle.com
8 Attorneys for Defendant North Central
9 Regional Library District
KARR TUTTLE CAMPBELL
10
1201 Third Ave., Ste. 2900
11 Seattle, WA 98101
Telephone: 206.233.1313
12
Facsimile: 206.682.7100
13

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NCRL'S RESPONSE TO PLAINTIFFS'
28 OBJECTIONS TO DEFENDANT'S
WITNESSES AND EXHIBIT LIST - 8 Law Offces

CV -06-327-EFS KARR TUTTLE CAMPBELL


DOCS-66SS371 - A Professional Service Corporation
12111 Third A\'cnuc, Suiic 21J1l. Sciittlc. Washinj!iun 9HIlI-JU2H
Tclciihoni: (2116) 223-1313, Facsimile (2Ihí) (¡H2-71UU
1 CERTIFICATE OF SERVICE
2
I hereby certify that on April 7, 2008, I electronically filed the foregoing
3

4 with the Clerk of the Court using the CM/ECF system which wil send
5
notification of such filing to the persons listed below:
6
7 Duncan Manvile Aaron Caplan
1629 2nd Ave. W ACLU of Washington
8 Seattle, W A 98119 705 Second Ave., Ste. 300
9 Seattle, W A 98103
10
Catherine Crump
11 American Civil Liberties Union
12 Foundation
125 Broad Street, 1 ih Floor
13 New York, NY 10004
14
15 KARR TUTTLE CAMPBELL
16
17
C
By: IYt4tYl-
18 Deborah Messer
19 dmesser(ßkarruttl e. com

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NCRL'S RESPONSE TO PLAINTIFFS'
28 OBJECTIONS TO DEFENDANT'S
WITNSSES AND EXHIBIT LIST - 9 1.0Il' OffceJ

CV-06-327-EFS KARR TUTTLE CAMPBELL


DOCS-66SS371 - A Professional Service Coiporaiion
1201 Third Avenue, Suiic 2900, Sciillc. Wlishin~l()n 98101-3028
Telephone (2116) 223-1313, Fac~miJc (20G) 682-7HIU
EXHIBIT A
NCRL's Response
Page 10
)

1 The Honorable Edward F. Shea


2
Thomas D. Adams
3 Celeste Mountain Monroe

4 KARR TUTTLE CAMPBELL


5 1201 Third Avenue, Suite 2900
Seattle, Washington 98101-3028
6 (206) 223-1313

7 Attorneys for North Central Regional Library District


8

9 UNITED STATES DISTRICT COURT


EASTERN DISTRICT OF WASHINGTON
10
AT SPOKANE
11

12
13 SARAH BRADBURN, PEAR )
14 CHæRRNGTON, CHARLES )
HEINLEN, and THE SECOND ) NO. CY-06-327-EFS
15
AMENDMENT FOUNATION, )
16 ) DEFENDANT NORTH CENTRAL
17
Plaintiffs, ) REGIONAL LIBRARY'S WITNSS
) AND EXHIBIT LIST
18 v. )
19 )
NORTH CENTRAL REGIONAL )
20 LIBRARY DISTRICT, )
21 )
22
Defendant. )

23
24
Defendant North Central Regional Library identifies the following
25
26 witnesses and exhibits:
27
DEFENDANT NORTH CENTRAL
28 REGIONAL LIBRARY'S WITNESS
AND EXHIBIT LIST - 1 I.all O(fh'e.i'

CV -06-327-EFS KARR TUTTLE CAMPBELL


#663448 v I 142703-00 i A Pro/e,'isional Service Corporation
NCRL's Response I2UI Third Avenue, Suite i901~ ScaliIe, WashiD~loD 98101-3028

Pi.\J~ 11 Telephone (206) 223.1313, Facsimile (206) 682-7100


1

2
1. FACT WITNSSES
3

4 1. Dean Marney
5 Dean Marney is the Director of the North Central Regional Library
6
7
("NCRL") District. Mr. Marney was appointed to his position by the NCRL
8 Board of Trustees in 1990. As Director, Mr. Marney serves as the liaison
9
between the Board and library staff.
10
11 Mr. Marney wil testify regarding NCRL and its policies, including: its
12
mission, collection development policy and internet usage policy. He wil
13

14
testify regarding NCRL's need to comply with the Children's Internet Protection

15 Act ("CIP A") and the Board's decision to implement an Internet filter to
16
facilitate compliance with CIPA. Mr. Marney wil discuss NCRL's current
17
18 internet filtering profile, as well as the procedure for requesting that certain
19
internet content be unblocked by the filter. Mr. Marney wil discuss the
20
21 unblocking requests NCRL has received from patrons and the process that he
22 and Mr. Howard follow in evaluating the requests. Mr. Marney wil also discuss
23
the other purposes the Internet filters serve, beyond compliance with CIP A, to
24
25 include: (1) fulfillment of traditional collection decisions; (2) protection of staff
26
27
DEFENDANT NORTH CENTRAL
28 REGIONAL LIBRARY'S WITNESS
AND EXHIBIT LIST - 2 Law Offces

CV -06-327-EFS KARR TUTTLE CAMPBELL


#663448 v i 142703-001 A Professional Service Corporation
N CRL' s Response iiui Third Avenue. Sulle 290'~ Scaiiic, Washingion 9llJ01-3028
Telephone (206) 223-1313, Facsimile (206) 682-7100
Page 12
"
)

1 and patrons from inadvertent exposure to ilegal, pornographic, or other


2
disruptive and inappropriate material; and (3) compliance with other state and
3

4 federal laws.
5
2. Dan Howard
6
7 Dan Howard is the Public Services Director for NCRL. Mr. Howard
8 administers NCRL's 28 branch libraries and its mail order library. He also
9
coordinates collection development activities and administer grants. With
10
11 respect to the individual branches, Mr. Howard's responsibilities include, among
12
other things, management of personneL. This includes supervision of all NCRL
13

14 branch librarians.
15
Mr. Howard wil testify regarding NCRL's policies, to include: its
16
17
mission statement, collection development policy and internet usage policy. He
18 will discuss the relationship between the filter and collection development. He
19
will testify regarding his district's need to comply with the Children's Internet
20
21 Protection Act ("CIP A"). Mr. Howard will also discuss NCRL' s current
22
internet filtering profile and the procedure for requesting that certain internet
23
24 content be unblocked. Mr. Howard will discuss the unblocking requests that
25
26
27
DEFENDANT NORTH CENTRAL
28 REGIONAL LIBRARY'S WITNESS
AND EXHIBIT LIST - 3 Law Offce.\.

CV -06-327-EFS KARR TUTTLE CAMPBELL


#663448 vi 142703-001 A Professional Service Corpora/ion
NCRL's Response 1101 Thiril Avenue, 5pilc 2900, Seatlle, Wa!lhiDglon 981111-3028
Telephone (206) 223-1313, Facsmile (106) 682.1100
Page 13
)

1 NCRL has received from patrons and the process that he and Mr. Marney use in
2
evaluating the requests.
3

4 Mr. Howard wil also discuss his experience with certain privacy
5
measures suggested by Plaintiffs, including: (1) privacy screens; (2) recessed
6
7 desks and (3) a "tap and tell" policy. Mr. Howard discuss his concerns with
8 unfiltered access and the impact on branch staff.
9
3. Barbara Walters
10
11 Barbara Walters is the Information Technology Manager for the North
12
Central Regional Library District. She has served in this role since 2002.
13
14 Ms. Walters wil testify regarding the structure ofNCRL's computer network, to
15
include technical information and details regarding the configuration of the
16
17 Internet filter.

18 4. Connie Kuhlman
19
Connie Kuhlman is the Grant County Regional Manager and head of
20
21 Moses Lake Branch. Ms. Kuhlman ran the Grand Coulee Branch before Moses
22
Lake.
23
24
25
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DEFENDANT NORTH CENTRAL
28 REGIONAL LIBRARY'S WITNSS
AND EXHIBIT LIST - 4 Law Offces

CV-06-327-EFS KARR TUTTLE CAMPBELL


#663448 v I 142703-00 I A Professional Service Corporation
NCRL's Response 120) Tbird Avenue, Suile 2900, Seattle, Washington 98101-3028
Page i 4 Telciihone (206) 223-13)3, Fllc~mile (206) 682-7100
1 Ms. Kuhlman wil discuss her personal experience with the internet filter,
2
including instances where individuals have circumvented the filter to obtain
3

4 ilicit materiaL. She wil also discuss her concerns with unfiltered access.
5
5. Sharon Reddick
6
7 Sharon Reddick is the Okanogan/err County Regional Manager &
8 Head of Omak Branch.
9
Ms. Reddick wil discuss her personal experience with the internet filter,
10
11 including instances where individuals have circumvented the filter to obtain
12
ilicit materiaL. She will also discuss her concerns with unfiltered access.
13

14 6. Katy Sessions

15
Katy Sessions is the Chelan/Douglas County Regional Manager & Head
16
17
of Wenatchee Branch.

18 Ms. Sessions will discuss her personal experience with the internet filter,
19
including instances where individuals have circumvented the filter to obtain
20
21 illicit materiaL.
22
7. Deborah Moore
23
24 Deborah Moore is a NCRL Board Trustee from Grant County. She has
25 served in this capacity since January 2007. Ms. Moore wil testify regarding the
26
27
DEFENDANT NORTH CENTRAL
28 REGIONAL LIBRARY'S WITNESS
AND EXHIBIT LIST - 5 Law Offces

CY -06-327-EFS KARR TUTTLE CAMPBELL


#663448 v I 142703-00 i A Professional Service Corporalion
N CRL' s Response 201 Third Avcnue, Suile 2900, Si:lilfe, Wa,hiD~ton 98HII-3U28
TclelihllDC (2116) 223-1313, Fllc~mih: (206) 682-7100
P~HJf' 1"
,,'" .
i .)
"

1 current Internet Filtering Policy.


2
II. EXPERT WITNSS
3

4 1. Paul Resnick

5 Paul Resnick is a professor at the University of Michigan School of


6
Information. Mr. Resnick was retained by NCRL to serve as an expert in the
7
8 current litigation.
9 Mr. Resnick was asked to explain how the NCRL filtering software
10
11
works. He was also asked to assess the methods used in studying the error rates

12 in the filtering software NCRL uses as reported by Plaintiffs' expert,


13
Mr. Bennett Haselton. Mr. Resnick wil testify regarding all of these topics. In
14
15 addition, Mr. Resnick wil testify regarding his own study ofNCRL's filter.
16
III. EXHIBITS
17
18
500 NCRL Branch Library Map
19 501 - NCRL Branch Photos
20 528
529 NCRL Resolution adopting Internet Usage
21
Policy
22 530 NCRL Board Minutes adopting Internet Usage
23 Policy
531 NCRL Internet Usage Policy
24
532 NCRL Current Fortiguard Filtering Profile
25 533 - NCRL Incident Reports
26 536

27
DEFENDANT NORTH CENTRAL
28 REGIONAL LIBRARY'S WITNSS
AND EXHIBIT LIST - 6 Law Offces

CV -06-327-EFS
KARR TUTTLE CAMPBELL
#663448 v 1 142703-001 A Professional Senlice Corporation
NCRL's Response 201 Third Avenue, Suite 2900, Sealtle, Washinglon 98101-31128
Telephone (206) 223.1313, Facsimile (206) 682-7100
Page 16
)

1 537 NCRL Internal memo discussing decision to


2 unblock "Plagerism"
538 NCRL Internal memo discussing decision to
3
unblock " Personal Relationships"
4 539 NCRL Internal memo discussing decision to
5 unblock Y ouTube, with accompanying
Terms of Use
6
540 NCRL Internal memo discussing decision to
7 unblock Myspace, with accompanying
8
Terms of Use
541 NCRL Internal memo discussing decision to
9 unblock Craigslist, excepting personals
10 542-645 N CRL/Patrons Patron requests to unblock specific
internet content and N CRL response
11
646 NCRL Collection Development Policy
12 647 NCRL Mission Statement
13 648 Paul Resnick Paul Resnick's Expert Report/Data
14 649 FortiGuard Diagrams re: how FortiGuard filter work
(simply demonstrative?)
15 NCRL March 11, 1999 Director's Report
650
16 651 NCRL March 11, 1999 Board Meeting Minutes
17 652 NCRL April 15, 1999 Board Meeting Minutes
653 NCRL June 10, 1999 Board Meeting Minutes
18 July 15, 1999 Board Meeting Minutes
654 NCRL
19 655 NCRL September 16, 1999 Board Meeting
20 Minutes
656 NCRL August 12, 1999 Director's Report
21 October 14, 1999 Director's Report
657 NCRL
22 658 NCRL December 16, 1999 Director's Report
23 659 NCRL February 10, 2000 Director's Report
660 NCRL January 13, 2000 Director's Report
24 November 17, 1999 Director's Report
661 NCRL
25 662 NCRL December 16, 1999 Board Meeting
26 Minutes

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DEFENDANT NORTH CENTRAL
28 REGIONAL LIBRARY'S WITNESS
AND EXHIBIT LIST - 7 I.a'" Offces

CV -06-327-EFS
KARR TUTTLE CAMPBELL
#663448 v I 142703-001 A Profe.\",\"ional Servir:e Corporation

N CRL' s Response no) Thii-iI A,'cnuc, Suilc 291111, Scaillc, Wiiiihington 911WI-JII2H
Tcleiibone (2116) 223-1313. Facsimile (206) 682-7100
p~(JP 17
r )

1 664 NCRL February 10, 2000 Board Meeting


2 Minutes
663 NCRL March 16, 2000 Board Meeting Minutes
3
664 NCRL May 11, 2000 Board Meeting Minutes
4 665 NCRL June 15, 2000 Board Meeting Minutes
5 666 NCRL August 10, 2000 Board Meeting Minutes
667 NCRL September 14, 2000 Board Meeting
6
Minutes
7 668 NCRL August 10, 2000 Director's Report
8 669 NCRL October 12, 2000 Director's Report
670 NCRL October 12, 2000 Board Meeting
9
Minutes
10 671 NCRL December 14, 2000 Board Meeting
11 Minutes
672 NCRL December 14, 2000 Director's Report
12
673 NCRL January 11, 2001 Board Meeting
13 Minutes
14 674 NCRL January 11, 2001 Director's Report
675 NCRL February 15, 2001 Director's Report
15
676 NCRL February 15,2001 Board Meeting
16 Minutes
17 677 NCRL March 15, 2001 Board Meeting Minutes
678 NCRL June 14, 2001 Director's Report
18
679 NCRL October 11, 2001 Board Meeting
19 Minutes
20 680 NCRL October 11, 2001 Director's Report
681 NCRL November 15, 2001 Board Meeting
21
Minutes
22 682 NCRL January 17, 2002 Board Meeting
23 Minutes
683 NCRL February 14,2002 Board Meeting
24 Minutes
25 684 NCRL February 14, 2002 Director's Report
26 685 NCRL May 16, 2002 Director's Report
27
DEFENDANT NORTH CENTRAL
28 REGIONAL LIBRARY'S WITNESS
AND EXHIBIT LIST - 8 Law Offces

CV -06-327-EFS
KARR TUTTLE CAMPBELL
#663448 v I 142703-00 I A Professional Service Corporalion
NCRL's Response 201 ThiriJ A'tcnue, Suite 2900, Seattle, Wii!lhingion 98101-3028
Tclcpbonc (206) 223.1313, Facsimile (206) 682.7100
Paiæ 18
1 686 NCRL May 16,2002 Board Meeting Minutes
2 687 NCRL October 10, 2002 Board Meeting
Minutes
3
688 NCRL December 12,2002 Director's Report
4 689 NCRL January 15,2004 Board Meeting
5 Minutes
690 NCRL Apri115, 2004 Director's Report
6
691 NCRL May 13, 2004 Board Meeting Minutes
7 692 NCRL May 13, 2004 Director's Report
8 693 NCRL April 14, 2005 Board Meeting Minutes
694 NCRL December 15, 2005 Board Meeting
9
Minutes
10 695 NCRL March 16, 2006 Board Meeting Minutes
11 696 NCRL July 20, 2006 Board Meeting Minutes
697 NCRL November 16, 2006 Director's Report
12
698 NCRL January 18, 2007 Director's Report
13 699 ACLU Correspondence from ACLU to NCRL
14 patrons soliciting a lawsuit
700 - NCRL/Heinlen Correspondence between NCRL and
15
703 Charles Heinlen
16 704 NCRL NCRL Bylaws
17
18
//
19
20 //

21
//
22
//
23
24 //
25
//
26
27
DEFENDANT NORTH CENTRAL
28 REGIONAL LIBRARY'S WITNESS
AND EXHIBIT LIST - 9 Law Offices

CV -06-327-EFS KARR TUTTLE CAMPBELL


#663448 v i 142703-001 A Professional Service Corpora/ion
NCRL's Response 1201 Tbiril Avenue. Suite 2900, Scallc, Wa,hington 98101 -3028
TclephoDc (206) 223-13 13, Facijrnilc (206) 682-7100
Page 19
r )

2
NCRL reserves the right to amend its exhibit list, both to withdraw or
3

4 add certain exhibits, based on Plaintiff's disclosure. NCRL reserves the right
5
to use any exhibit proposed by Plaintiffs and admitted into evidence.
6
7 DATED this 24th day of March, 2008.

8
KARR TUTTLE CAMPBELL
9
10
By:/s/ Thomas D. Adams
Thomas D. Adams, WSBA #18470
11 E-mail-tadams(fkarruttle.com
12 Celeste Mountain Monroe, WSBA #35843
E-mail-cmonroe(fkarrttle.com
13
Attorneys for Defendant North Central
14 Regional Library District
KARR TUTTLE CAMPBELL
15
1201 Third Ave., Ste. 2900
16 Seattle, W A 98101
17 Telephone: 206.233.1313
Facsimile: 206.682.7100
18
19
20
21
22
23
24
25
26
27
DEFENDANT NORTH CENTRAL
28 REGIONAL LIBRARY'S WITNESS
AND EXHIBIT LIST - 10 Law Offc:e.\"

CV -06-327-EFS
KARR TUTTLE CAMPBELL
#663448 vI 142703-001 A Professional Service Corporation
N CRL' s Response :01 Third Avenue, SuiIe 2900, SullIe, Washington 98101-3028
Telepbone (206) 22J-IJIJ, Facsimile (206) 682-7100
Paiæ 20
)

1 CERTIFICATE OF SERVICE

2 I hereby certify that on March 24, 2008, I electronically fied the foregoing with the Clerk of the Court

3 using the cM/EcF system which wil send notification of such fiing to the persons listed below:

4 Duncan Manvile Aaron Caplan


1629 2nd Ave. W AcLU of Washington
5 Seattle, W A 981 i 9 705 Second Ave., Ste. 300
Seattle, W A 98 i 03
6 Catherine Crump
American Civil Liberties Union
7 Foundation
i 25 Broad Street, 17th Floor
8 New York, NY 10004

9
KARR TUTTLE CAMPBELL
10
11

12
13
By~LG Heather L. White
hwhite~arrttle.com

14
15

16
17
18
19
20
21
22
23
24
25
26
27
DEFENDANT NORTH CENTRAL
28 REGIONAL LIBRARY'S WITNESS
AND EXHIBIT LIST - 11 Laiv Offce..

CV -06-327-EFS
KARR TUTTLE CAMPBELL
#663448 vi 142703-001 A Professional Se~;ce Corporation
N CRL' s Response 01 Third Avenue, Suile 2900. Seattle, Wa!lhiDglOß 98101-3028
Telephone (206) 223-1313, Facsimile (206) 6H2.7100
Page 21
EXHIBIT B
NCRL's Response
Page 22
Page 1 of2

Celeste M. Monroe

From: Duncan Manville (duncan.manville(§yahoo.comJ


Sent: Friday, March 28,200810:26 AM
To: Celeste M. Monroe
Cc: Aaron Caplan; Catherine Crump
Subject: Re: NCRL Witness/Exhibit List

Thanks for the clarification, Celeste.

Duncan

----- Original Message ----


From: Celeste M. Monroe .(cmonroe(fkarruttle.com?
To: Duncan Manville .(duncan.manvile(fyahoo.com?
Cc: Thomas D. Adams .(tadams(fkarrtuttle.com?; Catherine Crump .(ccrup(faclu.org?; Aaron
Caplan .(caplan(faclu-wa.org?
Sent: Friday, March 28,20089:47:58 AM
Subject: NCRL Witness/Exhibit List

Duncan -

In response to your message this morning, I went and looked at the Witness and Exhibit List that we filed and it
did not match what was on our electronic system. Heather believes that she accidentally filed a draft version of
the pleading that was sitting on her desk - which did not include anything after Ex. 704. I had added 705 (the
Reserved Exhibit to match up with your Ex. 66) as well as all of the newspaper articles, and interrogatories/RFPs
for Plaintiffs and NCRL to the document that should have been filed.

All of the documents that we intend to offer at trial were included in the chart that I sent you on the 25th - except
the rogs/RFPS, which I didn't believe you needed citations for.

We apologize for this confusion and are in the process of filing the amended version of our Witness and Exhibit
List right now.

Thank you,

o Karr Tuttle Campbell

Celeste Mountain Monroe


Attorney
1201 3rd Avenue, Suite 2900
Seatte, Washington 98101
"direct 206-224-8064
e main 206-223-1313
. fax 206-682-7100
Visit our website www.karrtuttle.com

A Law Firm for the Pacific Northwest

NCRL's Response
417/200& Page 23
Page 2 of2

IMPORTANT/CONFIDENTIAL: This e-mail message (and any attachments accompanying it) may
contain confidential information, including information protected by attorney-client privilege. The
information is intended only for the use of the intended recipient(s). Delivery of this message to anyone
other than the intended recipient(s) is not intended to waive any privilege or otherwise detract from the
confidentiality of the message. If you are not the intended recipient, or if this message has been
addressed to you in error, do not read, disclose, reproduce, distribute, disseminate or otherwise use this
transmission, rather, please promptly notify the sender by reply e-mail, and then destroy all copies ofthe
message and its attachments, if any.

IRS Circular 230 Disclaimer: To ensure compliance with requirements imposed by the IRS, we inform
you that to the extent this communication contains advice relating to a Federal tax issue, it is not
intended or written to be used, and it may not be used, for (i) the purpose of avoiding any penalties that
may be imposed on you or any other person or entity under the Internal Revenue Code or (ii) promoting
or marketing to another part any transaction or matter addressed herein.

Looking for last minute shopping deals? Find them fast with Yahoo! Search.

N CRL' s Response
4/7 /2008 Page 24
EXHIBIT C
N CRL' s Response
Page 25
/\ /
t ) L

The Honorable Edward F. Shea

UNTED STATES DISTRICT COURT


EASTERN DISTRICT OF WASHIGTON
AT SPOKANE

SAR BRABUR, PEAR )


CHERRNGTON, CHAES )
HE~EN, md THE SECOND ) NO. CV-06-327-EFS
AMNDMENT FOUNATION, )
) DEFENDANT NORTH CENTRA
Plaintiffs, ) REGIONAL LIBRAY'S AMNDED
) WITNSS AND EXHIBIT LIST
v. )
)
NORTH CENTRA REGIONAL )
LIBRARY DISTRICT, )
)
Defendant. )

24
Defendant North Central Regional Library identifies the following
25
26 witnesses and exhibits:
27
DEFENDANT NORTH CENTRAL
28 REGIONAL LIBRAY'S AMNDED
WITNSS AND EXHIBIT LIST - 1 Law Offces

cV06-327-EFS KARR TUTTLE CAMPBELL


#664851 vi 142703-001 A Professional Service Corporafion
1101 Third AYeDu~. S.¡Ic i900 SIt.llfe, W.,bia~oD 911101-3028
Tekphoiie (i06)i1J~I3IJ. Fiicdmlle (206) 682.7100
NCRL's Response
Page 26
J) )

2
i. FACT WITNSSES
3

4 1. Dean Marney

5 Dean Marney is the Director of the North Central Regional Library


6
7 ("NCRL") District. Mr. Marney was appointed to his position by the NCRL
8 Board of Trustees in 1990. As Director, Mr. Marney serves as the liaison
9
between the Board and librar staff.
10
11 Mr. Marney will testify regarding NCRL and its policies, including: its
12
mission, collection development policy and internet usage policy. He wil
13

14
testify regarding NCRL's need to comply with the Children's Internet Protection

15 Act ("CIP A") and the Board's decision to implement an Internet filter to
16
faciltate compliance with CIPA. Mr. Marney wil discuss NCRL's current
i7
18 internet fitering profile, as well as the procedure for requesting that certain

19
internet content be unblocked by the fiter. Mr. Marney wil discuss the
20
21 unblocking requests NCRL has received from patrons and the process that he
22 and Mr. Howard follow in evaluating the requests. Mr. Marney wil also discuss
23
the other purposes the Internet fiters serve, beyond compliance with CIP A, to
24
25 include: (1) fulfillment of traditional collection decisions; (2) protection of staff
26
27
DEFENDANT NORTH CENTRAL
28 REGIONAL LIBRARY'S AMNDED
WITNSS AND EXHIBIT LIST - 2 Law Offce...

CY06-327-EFS KARR TUTTLE CAMPBELL


#66485 J v i i 42703 -00 i A Professional Service Corporaiion
'lii..d ""caue, Suiic i9tJG. StIlIUe, WI,hiQiloD 98101-3028
'clcpbDDe (206) 123-1313, Facsimile (206 611-710D
NCRL's Response
Page 27
, \
I
, )

1 and patrons from inadvertent exposure to ilegal, pornographic, or other


2
disruptive and inappropriate material; and (3) compliance with other state and
3

4 federal laws.
5
2. Dan Howard
6
7 Dan Howard is the Public Services Director for NCRL. Mr. Howard
8 administers NCRL's 28 branch libraries and its mail order librar. He also
9
coordinates collection development activities and administer grants. With
10
11 respect to the individual branches, Mr. Howard's responsibilities include, among
12
other things, management of personneL. This includes supervision of all NCRL
13

14 branch librarians.
15
Mr. Howard will testify regarding NCRL's policies, to include: its
16
17 mission statement, collection development policy and internet usage policy. He
18 will discuss the relationship between the filter and collection development. He
19
will testify regarding his district's need to comply with the Children's Internet
20
21 Protection Act ("CIPA"). Mr. Howard wil also discuss NCRL's current

22
internet fitering profie and the procedure for requesting that certain internet
23
24 content be unblocked. Mr. Howard wil discuss the unblocking requests that
25
26
27
DEFENDANT NORTH CENTRL
28 REGIONAL LIBRAY'S AMNDED
WITNSS AND EXHIBIT LIST - 3 Law Offces

CV-06-327-EFS KARR TUTTLE CAMPBELL


#56485 i v l 142703-00 i A Professional Service Co'poralion
1101 Tblrd A\'cauc:. Siliie. 1700. SCiI"te, WalblDRIOII 98101-3028

N CRL' s Response TckphoM (106) iiJ-IJIJ, ¥ai:NmiJe (206) 681-7100

Page 28
J)

1 NCRL has received from patrons and the process that he and Mr. Marey use in
2
evaluating the requests.
3

4 Mr. Howard wil also discuss his experience with certain privacy
5
measures suggested by Plaintiffs, including: (1) privacy screens; (2) recessed
6
7 desks and (3) a "tap and tell" policy. Mr. Howard discuss his concerns with
8 unfitered access and the impact on branch staff.
9
3. Barbara Walters
10
11 Barbara Walters is the Information Technology Manager for the North
12
Central Regional Library District. She has served in this role since 2002.
13

14 Ms. Walters wil testify regarding the structure ofNCRL's computer network, to
15
include technical information and details regarding the configuration of the
16
17 Internet filter.

18 4. Connie Kuhlman
19
Connie Kuhlman is the Grant County Regional Manager and head of
20
21 Moses Lake Branch. Ms. Kuhlman ran the Grand Coulee Branch before Moses
22
Lake.
23
24
25
26
27
DEFENDANT NORTH CENTRAL
28 REGIONAL LIBRARY'S AMENDED
WITNSS AND EXHIBIT LIST - 4 Law Offces

Cì'-06-327-EFS KARR TUTTLE CAMPBELL


#664851 vI 142703-001 A Professional Service Corporalion
i,ni Tbird AVCIlIJC,Sui Ie 2900. Sciitllc, Wubliigfoii !1IIJOI..01Ø
lclepboae (i~iZJ-IJ1J. FlK3mili: (106) 6U-71DO
NCRL's Response
Page 29
r-
( )
')

1 Ms. Kuhlman wil discuss her personal experience with the internet filter,
2
including instances where individuals have circumvented the fiter to obtain
3

4 ilicit materiaL. She wil also discuss her concerns with unfiltered access.

5
5. Sharon Reddick
6
7 Sharon Reddick is the Okanogan/err County Regional Manager &
8 Head of Omak Branch.
9
Ms. Reddick wil discuss her personal experience with the internet filter,
10
11 including instances where individuals have circumvented the filter to obtain
12
ilicit materiaL. She wil also discuss her concerns with unfiltered access.
13

14 6. Katy Sessions

15
Katy Sessions is the ChelanIouglas County Regional Manager & Head
16
17 o f Wenatchee Branch.

18 Ms. Sessions wil discuss her personal experience with the internet filter,
19
including instances where individuals have circumvented the filter to obtain
20
21 illicit materiaL.
22
7. Deborah Moore
23
24 Deborah Moore is a NCRL Board Trustee from Grant County. She has
25 served in this capacity since January 2007. Ms. Moore will testify regarding the
26
27
DEFENDANT NORTH CENTRAL
28 REGIONAL LilRAY'S AMNDED
WITNSS AND EXHIBIT LIST - 5 Law Offces

C V-06-327-EFS KARR TUTTLE CAMPBELL


#664851 vI 142703-001 A Proftssional Service Corpora/ion
4__, Third Aytiiue, Sulle 25100 Sunle. WUhla&lO. 5l81ØI-J028
TclepboDe (106) 113-1313, F"i'mlle (106) 682.7100
N CRL' s Response
Page 30
r )
\

1 current Internet Filtering Policy.


2
II. EXPERT WITNSS
3

4 1. Paul Resnick

5 Paul Resnick is a professor at the University of Michigan School of


6
Information. Mr. Resnick was retained by NCRL to serve as an expert in the
7
8 current litigation.

9 Mr. Resnick was asked to explain how the NCRL fitering software
10
works. He was also asked to assess the methods used in studying the error rates
11

12 in the fitering software NCRL uses as reported by Plaintiffs' expert,


13
Mr. Bennett Haselton. Mr. Resnick wil testify regarding all of these topics. In
14
15 addition, Mr. Resnick wil testify regarding his own study ofNCRL's filter.
16
Mr. Resnick wil be unavailable after June 6, 2008.
17
18
III. EXfITS
19
20 500 NCRL Branch Library Map
501 - NCRL Branch Photos
21
528
22 529 NCRL Resolution adopting Internet Usage
23 Policy
530 NCRL Board Minutes adopting Internet Usage
24 Policy
25 531 NCRL Internet Usage Policy
26 532 NCRL Current Fortiguard Filtering Profie
27
DEFENDANT NORTH CENTRAL
28 REGIONAL LIBRARY'S AMENDED
WITNSS AND EXHIBIT LIST - 6 LulIOffcC!.'

CY06-327-EFS KARR TUTTLE CAMPBELL


#664851 v i 142703-001 A Professional Service! Corporation
.,ni T1:nlAYCIJlIlC, SlIile. 19UO,Sei11Ie. Wluhi8&IOa 98101-31)28
~pbODC (2Ð6) lZ3.JJIJ, PII.!milc (106) 681-7100

NCRL's Response
Page 31
\
') )

1 533 - NCRL Incident Reports


2 536
537 NCRL Internal memo discussing decision to
3
unblock "Plagerism"
4 538 NCRL Internal memo discussing decision to
5
unblock" Personal Relationships"
539 NCRL Internal memo discussing decision to
6
unblock YouTube, with accompanying
7 Terms of Use
8 540 NCRL Internal memo discussing decision to
unblock Myspace, with accompanying
9 Terms of Use
10 541 NCRL Internal memo discussing decision to
unblock Craigslist, excepting personals
11
542-645 NCRL/Patrons Patron requests to unblock specific
12 internet content and NCRL response
13 *The number of these exhibits may
increase between now and trial as
14
additional requests are received and
15 additional correspondence is generated*
16 646 NCRL Collection Development Policy
647 NCRL Mission Statement
17
648 Paul Resnick Paul Resnick's Expert Report/Data
18 649 Forti Guard Diagrams re: how FortiGuard fiter work
19 (may be simply demonstrative)
650 NCRL March 11, 1999 Director's Report
20
651 NCRL March 11, 1999 Board Meeting Minutes
21 652 NCRL April 15, 1999 Board Meeting Minutes
22 653 NCRL June 10, 1999 Board Meeting Minutes
654 NCRL July 15, 1999 Board Meeting Minutes
23
655 NCRL September 16, 1999 Board Meeting
24 Minutes
25 656 NCRL August 12, 1999 Director's Report
657 NCRL October 14, 1999 Director's Report
26
27
DEFENDANT NORTH CENTRA
28 REGIONAL LIBRAY'S AMNDED
WITNESS AND EXHIBIT LIST - 7 La" OjJces

cV-06-327-EFS KARR TUTTLE CAMPBELL


#664851 y i 142703-001 A Profe.sslonal Senilce Corporation
i 20 i Tbird Avcauc, Su¡lc 2900. Sc.llle. W..billg1Dl 9Ð 101.3028
1bo_c (106) 223.1313, VacÄmlle (:tD6 682-7100
N CRL' s Response
Page 32
,
i, ) ¡)

1
658 NCRL December 16, 1999 Director's Report
2 659 NCRL February 10, 2000 Director's Report
660 NCRL January 13, 2000 Director's Report
3
661 NCRL November 17, 1999 Director's Report
4 662 NCRL December 16, 1999 Board Meeting
5 Minutes
664 NCRL February 10,2000 Board Meeting
6
Minutes
7 663 NCRL March 16, 2000 Board Meeting Minutes
8 664 NCRL May 11, 2000 Board Meeting Minutes
665 NCRL June 15, 2000 Board Meeting Minutes
9
666 NCRL August 10, 2000 Board Meeting Minutes
10 667 NCRL September 14, 2000 Board Meeting
11 Minutes
668 NCRL August 10, 2000 Director's Report
12
669 NCRL October 12, 2000 Director's Report
13 670 NCRL October 12, 2000 Board Meeting
14 Minutes
671 NCRL December 14, 2000 Board Meeting
15
Minutes
16 672 NCRL December 14, 2000 Director's Report
17 673 NCRL January 11, 2001 Board Meeting
Minutes
18
674 NCRL January 11, 2001 Director's Report
19 675 NCRL February 15, 2001 Director's Report
20 676 NCRL February 15, 2001 Board Meeting
Minutes
21
677 NCRL March 15, 2001 Board Meeting Minutes
22 678 NCRL June 14, 2001 Director's Report
23 679 NCRL October 11, 2001 Board Meeting
Minutes
24
680 NCRL October 11, 2001 Director's Report
25 681 NCRL November 15, 2001 Board Meeting
26 Minutes
27
DEFENDANT NORTH CENTRAL
28 REGIONAL LIBRARY'S AMENDED
WITNSS AND EXHIBIT LIST - 8 Law Offce"

CV-06-327-EFS KARR TUTTLE CAMPBELL


#66485 i vi 142703-001 A Professional Service CorporalJon
)201 Third MeaDe, Sulii: 2900 Sciillle, WiiblDi10II 98101-3018
Ti:kphoDe (106) 21J-I313, FKlImilc (206) 61l-7100
N CRL' s Response
Page 33
) )

1 682 NCRL January 17, 2002 Board Meeting


2 Minutes
683 NCRL February 14, 2002 Board Meeting
3
Minutes
4 684 NCRL February 14, 2002 Director's Report
5 685 NCRL May 16, 2002 Director's Report
686 NCRL May 16, 2002 Board Meeting Minutes
6
687 NCRL October 10, 2002 Board Meeting
7 Minutes
8 688 NCRL December 12, 2002 Director's Report
689 NCRL January 15, 2004 Board Meeting
9
Minutes
10 690 NCRL April 15, 2004 Director's Report
1 1
691 NCRL May 13,2004 Board Meeting Minutes
692 NCRL May 13, 2004 Director's Report
12
693 NCRL April 14, 2005 Board Meeting Minutes
13 694 NCRL December 15, 2005 Board Meeting
14 Minutes
695 NCRL March 16, 2006 Board Meeting Minutes
15
696 NCRL July 20, 2006 Board Meeting Minutes
16 697 NCRL November 16, 2006 Director's Report
17 698 NCRL January 18, 2007 Director's Report
699 ACLU Correspondence from ACLU to NCRL
18
patrons soliciting a lawsuit
19 700 - NCRL/Heinlen Correspondence between NCRL and
20 703 Charles Heinlen
704 NCRL NCRL Bylaws
21
705 RESERVED RESERVED
22 706 Dallas Morning News 1/15/2008 Article "On Dallas Library
23 Computers, Porn is a Regular Sight"
707 Brainerd Dispatch 8/16/2003 Article" Librarians Settle
24
Porn Case"
25 708 KTHV Little Rock 10/3/2007 Article "Preventing Internet
26 Predators in Libraries"
27
DEFENDANT NORTH CENTRAL
28 REGIONAL LIBRAY'S AMNDED
WITNSS AND EXHIBIT LIST - 9 Law Offces

cV-06-327-EFS KARR TUTTLE CAMPBELL


#664851 v I 142703-00 I A Professional ServJce Corpora/ion
1201 Third AVCDUl:, Siiiic ZlJl. Seattle, WubhiglO8 ,110)..028
TdcpboDc (206) i1JJ3JJ, F.cimillc(206) 6I1-7JOO

NCRL's Response
Page 34
) !, -,,

1 709 KTHV Little Rock 10/09/2007 Article "Sex Offender


2 Legislation Targets Libraries"
710 Library Journal 2/5/2008 Article" After Attach on Child
3
in Library, Mayor Wants to Bar Sex
4 Offenders"
5 711 Courier -Journal 11/20/2007 Article "Louisvile man
pleaded guilty to Child Pornography
6
Charges - He Got Files Using Library
7 Computers. "
8
712 WSB Atlanta 11/12/2007 Article "Woman Wants
Porn-Watching At Library Stopped"
9 713 Library Journal 6/15/2007 Article "Monroe Cty. Adopts
10 Tough Net Policy"
11
714 Winonan 9/20/2007 Article "Library Reassess
Public Access After Man Looks at Porn"
12 715 Mercury News 10/21/2007 Article "Councilman wants
13 San Jose Libraries to Block Online Porn"
716 Charles Heinlen Interrogatory /RFP Responses from
14
Charles Heinlen
15 717 Sarah Bradburn Interrogatory /RFP Responses from Sarah
16 Bradburn
718 Pearl Cherrington Interrogatory /RFP Responses from Pearl
i7
Cherrington
18 719 Second Amendment Interrogatory /RFP Responses from
i9 Foundation Second Amendment Foundation
720 NCRL Interrogatory /RFP Responses from
20
NCRL
21
22
NCRL reserves the right to amend its exhibit list, both to withdraw or
23
24 add certain exhibits, based on Plaintiff's disclosure or to add exhibits as
25
26
27
DEFENDANT NORTH CENTRAL
28 REGIONAL LIBRARY'S AMENDED
WITNSS AND EXHIBIT LIST - 10 L.aw Offces

cY06-327-EFS KARR TUTTLE CAMPBELL


#664851 vi 142703-001 A Professional Servke Corporalion
1101 Third AveDaft Suiic 1900 Seatte. Wa~biD.ilon 98101-30Z8
Tele(lhone (106) iiJ~IJIJ. PI(:8mllc (106 GØ2-7100

N CRL' s Response
P:io-P. 1'1
T
\. ,ì

1 additional unblocking requests are received. NCRL reserves the right to use
2
any exhibit proposed by Plaintiffs and admitted into evidence.
3

4 DATED this 28th day of March, 2008.

5
KA TUTTLE CAIvBELL
6
7 By:/s/Celeste Mountain Monroe
Celeste Mountain Monroe, WSBA #35843
8
E-mail -cmonroecqkaruttle.com
9 Thomas D. Adams, WSBA #18470
10
E-mail-tadams~karruttle.com
Attorneys for Defendant North Central
11 Regional Library District
12 KARR TUTTLE CAlBELL
1201 Third Ave., Ste. 2900
13 Seattle, W A 98101
14 Telephone: 206.233.1313
Facsimile: 206.682.7100
15

16
17
18
19
20
21
22
23
24
25
26
27
DEFENDANT NORTH CENTRAL
28 REGIONAL LIBRAY'S AlNDED
WITNSS AND EXHIBIT LIST - 11 Law Offces

cY06-327-EFS KARR TUTTLE CAMPBELL


#5(í4851 vI 142703-001 A Professional Service Corpora/ion
1%01 Third ÅYCIlIIC, Slillt 190Sun.c. WublDgtH 98101-30î8
TelepboDC (106li.U13, J'aciimlh: (2D6 68-7100
N CRL' s Response
Page 36
,: ')
:
\.

1 CERTIFICATE OF SERVICE

2 I hereby certify that on March 28, 2008, I electronically fied the foregoing with the Clerk of the Court

3 using the CMlEcF system which will send notification of such fiing to the persons listed below:

4 Duncan Manvile Aaron Caplan


1629 2nd Ave. W ACLU of Washington
5 Seattle, W A 98 i 19 705 Second Ave., Ste. 300
Seattle, W A 98 i 03
6 Catherine Crup
American Civil Liberties Union
7 Foundation
125 Broad Street, 17th Floor
8 New York, NY 10004

9
KARR TUTILE CAMPBELL

BY~
10
11

12
Heather L. White
13 hwhiteCfkartt1e.com

14
15

16
17
18
19
20
21

22
23
24
25
26
27
DEFENDANT NORTH CENTRAL
28 REGIONAL LIBRARY'S A1'NDED
WITNSS AND EXHIBIT LIST - 12 Law Offces

C"V06-327-EFS KARR TUTTLE CAMPBELL


#6ti4851 vI /42703-00 i A Professional Service Corporation
IZO) ThiriJ AnDDc, Suiic 290O,Sclnle. WlublD¡:0d 981UI-JUii
Ti:lcpboDC (106 iZJ-1J 13, Ficlimlle (106) 681-7100

NCRL's Response
Page 37

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