IN THE CIRCUIT COURT OF THE STATE OF OREGON FOR THE COUNTY OF MARION JANE DOES 1, 2, 3 and 4, | | No. Plaintiffs, | | AFFIDAVIT OF I. FRANKLIN v. | HUNSAKER | | THE STATE OF OREGON; JOHN A. | KITZHABER, Governor of Oregon; | and EDWARD JOHNSON, State | Registrar of the Center for Health | Statistics in Oregon, | | Defendants. | ___________________________________| STATE OF OREGON ) ) ss. County of Multnomah )
I FRANKLIN HUNSAKER, being first duly sworn. hereby depose and say:
1. I am making this Affidavit in this matter as the attorney primarily responsible for representing Plaintiffs.
2. 1 have met with each and every one of the four Plaintiffs in this lawsuit and can verify that the facts set forth in their respective Affidavits were stated to me by each of the Plaintiffs, and I hereby attest to their accuracy.
3. Heretofore, the Plaintiffs' privacy interests have been protected under Oregon law. I believe that the anonymity of each of the Plaintiffs is necessary, important and fair because of promises of confidentiality and privacy that previously were made to each of the Plaintiffs about their identity not being disclosed to either the child that each of them placed for adoption or to the adoptive parents. If Plaintiffs were required to use their real names in pursuing this litigation, they would suffer immediate, irreparable harm or injury and some or all of them might not be willing to pursue this lawsuit because of the harm that they would suffer having their anonymity and promised confidentialities breached.
4. An Affidavit signed by each and every one of the Plaintiffs using their real names is in my possession and will be disclosed to the Court in camera if that becomes necessary.
(SIGNED) FRANKLIN UNSAKER I. Franklin Hunsaker Subscribed and sworn to before me this 30th day of November, 1998. |S| Sandra J, Gotthardt Notary Public for Oregon My commission expires: 5-6-2000
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