Case No.: 1:98 CV 897
HON. David W. McKeague
U.S. District Judge
MEGAN DAUGHERTY AND DONALD SWEENY,
JEFFREY AND CATHY SEAVER,
individually and as next friends
of their minor children,
Plaintiffs ,
v.
VANGUARD CHARTER SCHOOL ACADEMY,
GRAND VALLEY STATE UNIVERSITY, and
NATIONAL HERITAGE ACADEMIES, a
Michigan Corporation,
Defendants.
DECLARATION OF H. COLEMAN McGEHEE JR.
H. COLEMAN McGEHEE, Jr., pursuant to 28 USC § 1746, declares under penalty of perjury that the following is true and correct, excepting those matters stated to be on information or belief, and as to those matters I declare that same are true and correct to the best of my knowledge, information and belief:
1. I am now retired but was the VIII Bishop of Michigan, from 1973 to 1990. I have attached a copy of my “Biographical Sketch” (see: Exhibit A) which is a true and accurate statement of my educational and experiential background demonstrating my expertise in the areas concerning which I offer the opinions stated below. My education includes receipt of degrees from the Virginia Theological Seminary, M. Div. Degree 1957 and D.D. Degree 1973. I have held positions as Vicar, St. John’s Episcopal Church, Arlington VA, 1957-60; Rector, Immanuel Church on the Hill, Alexandria, VA, 1960-71 and Bishop CoAdjutor, Diocese of Michigan, 1971—73
2. I have reviewed the portions of Plaintiff’s Brief, pages 12 and 13 regarding the Moral Focus Curriculum at Vanguard Charter School. I understand the Defendants in this case contend that the
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Moral Focus Curriculum (“MFC” below) is based on. and consistent with, four cardinal greek virtues: prudence; temperance; fortitude: justice.” Based on the materials reviewed, I have the following theological opinion of the Moral Focus Curriculum. I have not been paid or promised anything of value in consideration of this Affidavit, but make this Affidavit solely as a theologian.
3. In my review of the Plaintiffs’ brief, I note the MFC includes use of the concepts of “faith, grace, righteousness, mercy compassion, conscience, self-sacrifice and forgiveness.” Based on my educational and experiential background as a theologian, it in my opinion that these concepts are important Christian teachings.
Further Affiant sayeth not.
VERIFICATION
I, the undersigned, pursuant to 28 USC § 1746. declare under penalty of perjury that the foregoing is true and correct, excepting those matters stated to be on information or belief, and as to those matters I declare that same are true and correct to the best of my knowledge. information and belief.
Date: March 16, 2000
H. COLEMAN McGEHEE, Jr.
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