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

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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

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9 UNITED STATES DISTRICT COURT

EASTERN DISTRICT OF WASHINGTON
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AT SPOKANE
1 1

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13 SARAH BRADBURN, PEARL )

14 CHERRINGTON, CHARLES )
) NO. CV-06-327-EFS
15 HEINLEN, and THE SECOND
AMENDMENT FOUNATION, )
16 ) DEFENDANT NORTH CENTRAL
17
Plaintiffs, ) REGIONAL LIBRARY DISTRICT'S
) STATEMENT OF FACTS IN
18 v. ) SUPPORT OF MOTION FOR
19 ) SUMMARY JUDGMENT
NORTH CENTRAL REGIONAL )
20 LIBRARY DISTRICT, )
21 )
22
Defendant. )
)
23
24
25
26 DEFENDANT NORTH CENTRAL
27 REGIONAL LIBRARY DISTRICT'S
STATEMENT OF FACTS IN SUPPORT
28 OF MOTION FOR SUMMARY
JUDGMENT - 1 Law Offces

CV-06-327-EFS KARR TUTTLE CAMPBELL

#657989 vI /42703-001 A Professional Service Corporation
1201 Third A\'enue, Sui Ie 2900, Scal1lc, Washington 9SIOI-J028
Telephone (206) 223-1313, Facsimile (2116) 682-7100

Dockets.Justia.com
 1 A. The North Central Regional Library
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1. North Central Regional Library ("NCRL" or "District") is an inter-county
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4 rural library district and municipal corporation established in 1 960. Declaration

5 of Dean Marney ("Marney Decl.") at iT 3.
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7 2. NCRL is organized and operated pursuant to RCW 27.12 et. seq. Id at iT4.
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9 3. NCRL provides public library services to over 220,000 people in the areas
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of Chelan, Douglas, Ferr, Grant and Okanogan counties. Id at iT5., Ex. A.
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4. The District is funded by local property taxes, federal money, private
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14 grants and endowments. Id. at iT6.

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16 5, Management and control of NCRL is vested in a board of trustees ("the

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Board") composed of two trustees from each of Chelan and Grant counties and
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one trustee each from Douglas, Ferr, and Okanogan counties. Id. at iT7.
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6. The Board is responsible for issuing all policies for the District. Id. iT8.
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7. The Board appoints a Director, who manages the library and directs the
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24 employees. The Director serves as the liaison between the Board and library
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26 DEFENDANT NORTH CENTRAL
27 REGIONAL LIBRARY DISTRICT'S
STATEMENT OF FACTS IN SUPPORT
28 OF MOTION FOR SUMMARY
JUDGMENT - 2 Lall Offices

CY-06-327-EFS KARR TUTTLE CAMPBELL

#657989 v i /42703-00 i A Profe.';sional Service Corporation
1201 Third A"cnuc. Suile 2900, Seattle. Washin~ton 98 HIIw31128
Tcleiiliiinc (2116) 22JwlJIJ, Fllcsimilc (2116) 682.71011