Professional Documents
Culture Documents
84
9
UNITED STATES DISTRICT COURT
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EASTERN DISTRICT OF WASHINGTON
11 AT SPOKANE
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Dockets.Justia.com
1 I. WITNESSES
2
Plaintiffs' arguments in support of its objections to the introduction of
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14
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
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26
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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
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.
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Accordingly, Plaintiffs' hearsay objection lacks merit.
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11 Second, the documents are relevant. When asked why NCRL has elected
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to employ the filter at all times, Executive Director Dean Marney testified that,
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14 among other things, "Libraries have a peculiar problem that we attract a certain
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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
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18 operating a public library, which NCRL administrators believe offers further
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support for their decision to filter content such as adult materials and
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21 pornography.
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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.
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(Ct. Rec. 80, p. 4). Plaintiffs ask the Court to consider NCRL's Internet Usage
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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
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reports are relevant and admissible.
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7 B. NCRL Exhibits 542-645
8 NCRL seeks to introduce all patron unblocking requests and related
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correspondence. In its original disclosure, NCRL envisioned identifying each
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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
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14
copy of these exhibits (specifically labeled Exs. 542-645) for purposes of
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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25
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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
14
letter to show that the ACLU actively solicited litigants to advance its view of
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'
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
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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27
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
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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
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NCRL'S RESPONSE TO PLAINTIFFS'
28 OBJECTIONS TO DEFENDANT'S
WITNESSES AND EXHIBIT LIST - 8 Law Offces
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
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'
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
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.\.
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
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Lake.
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24
25
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DEFENDANT NORTH CENTRAL
28 REGIONAL LIBRARY'S WITNSS
AND EXHIBIT LIST - 4 Law Offces
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
4 1. Paul Resnick
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
)
27
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 )
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 //
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//
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//
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24 //
25
//
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DEFENDANT NORTH CENTRAL
28 REGIONAL LIBRARY'S WITNESS
AND EXHIBIT LIST - 9 Law Offices
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
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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:
9
KARR TUTTLE CAMPBELL
10
11
12
13
By~LG Heather L. White
hwhite~arrttle.com
14
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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
Duncan
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,
NCRL's Response
417/200& Page 23
Page 2 of2
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N CRL' s Response
4/7 /2008 Page 24
EXHIBIT C
N CRL' s Response
Page 25
/\ /
t ) L
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
2
i. FACT WITNSSES
3
4 1. Dean Marney
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...
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
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
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
4 1. Paul Resnick
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
NCRL's Response
Page 31
\
') )
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"
NCRL's Response
Page 34
) !, -,,
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
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
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DEFENDANT NORTH CENTRAL
28 REGIONAL LIBRAY'S AlNDED
WITNSS AND EXHIBIT LIST - 11 Law Offces
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:
9
KARR TUTILE CAMPBELL
BY~
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Heather L. White
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DEFENDANT NORTH CENTRAL
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WITNSS AND EXHIBIT LIST - 12 Law Offces
NCRL's Response
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