UNITED STATES FEDERAL DISTRICT COURT

WESTERN DISTRICT OF MICHIGAN



Case No.: 1 :98CV897
HON. David W. McKeague

MEGAN DAUGHERTY AND DONALD SWEENY,
JEFF AND CATHY SEAVER,
individually and as next friends of their minor children,

Plaintiffs,



VANGUARD CHARTER SCHOOL ACADEMY,
GRAND VALLEY STATE UNIVERSITY, and
NATIONAL HERITAGE ACADEMIES,
a Michigan corporation

Defendants.

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Kary Love (P42623)
Attorneys for Plaintiffs
Suite 2
348 Waverly Road
Holland, MI 49423
Phone: (616) 396-6100

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AFFIDAVIT OF MICHELLE NELSON

Michelle Nelson, being first duly sworn upon her oath, deposes and states as follows:

1. My husband, Mark Nelson, and I have a daughter, Chyenne Nelson who attends the second grade class at VanGuard Charter School Academy, Defendant in the above-referenced case. The second grade teacher, Ms. Cindy Rosema, did not assign certain stories in the reading curriculum concerning dinosaurs.

2. At the fall 1998 parent/teacher conference, I questioned Ms. Rosema as to why the stories about dinosaurs were not assigned from the reading curriculum. Ms. Rosema stated that she did not like the stories and some other parents did not like the subject of dinosaurs being taught because it was against their religious belief.

3. In January 1999, My husband and I attended a conference with the Vanguard’s Principal, Al Couch and Ms. Rosema. We brought up the fact that the subject of dinosaurs was not being taught in my daughter’s second grade class. Ms. Rosema again repeated that the dinosaurs were not being taught because some parents object to the subject of dinosaurs being taught because it was against their religious beliefs. The principal, Mr. Couch, confirmed that some parents have objected to the teaching of dinosaurs on the basis of their religious beliefs. He stated that the teaching on the subject of dinosaurs varies from class to class and from year to year.

4. As a parent I have a very great concern over the fact that a subject such as dinosaurs is not being taught in a public school because of a person’s religious beliefs.

Further affiant sayeth not.
Dated: January 26, 1999

Michelle Nelson

On this 26th day of Jan. ,1999

Diane L. Miller
Notary Public, Kent County
My commission expires: 12- 25-99