Plaintiffs,

V.

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

Defendants.

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BARB REHNER, pursuant to 28 USC § 1746, declare 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 have read the Affidavit of Monica Zegunis, Teacher at Vanguard, regarding the incident where a student handed out “I Love Jesus” pillows in class at Vanguard. (In my prior affidavit, ¶4 I mistakenly stated it read “Jesus loves me.” I have since found the pillow and submit this correction after reviewing the original.) In a discussion with Ms. Zegunis of this incident, she advised Barb Rehner, that she, Ms. Zegunis, had no idea how to handle the request because there was no policy in place at Vanguard to give her guidance on how to handle a request by a student to hand out material of a religious nature.

2. Defendants claim the pillow was distributed during non-instructional time. According to what my child told me, the pillow was distributed in the classroom (where the students remain to eat lunch) to students who were a captive audience in that they were not told they could leave. During lunch, in the classroom, the students are at all times under the supervision and control of their teacher or a parent lunch aide, they are not free to come and go as they please.

3. I, Barb Rehner, talked to Al Couch, Vanguard Principal after the pillow was distributed in my child’s class. At that time Mr. couch admitted there was no policy in place to offer guidance on what is or is not allowed at vanguard regarding distribution of religious materials by students, or others, on school property during school hours. Mr. Couch stated that in lieu of having a policy he would have to handle future events on a case by case basis. I, Barb Rehner, gave Mr. Couch a copy of the Wyoming public School’s policy for such matters as a reference.

4. A picture with word stating “Jesus loves the little children of the world” is displayed in the Kindergarten classroom at Vanguard

Further Affiant sayeth not.

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:

Barb Rehner