Plaintiffs,
V
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 BARBARA REHNER
IN SUPPORT OF INJUNCTIVE RELIEF
Barbara Rehner, being first duly sworn upon her oat, deposes and states as follows:
1. I am a resident of Kent County, State of Michigan and my minor children attend Vanguard Charter School Academy (Vanguard) grades kindergarten, third and sixth. In the capacity as their parent, I have personal knowledge of the facts asserted herein.
2. My family is of the Jewish faith.
3. As their parent, it is my belief that my children are impressionable, look to their school teachers and school administrators as role models, and are susceptible to peer pressure.
4. In the later part of October 1998, one of my third grade child's classmates was granted permission by the third grade teacher, Monica Zegunis, to distribute material with a Christian message--a colored cloth item with the message "Jesus loves me"--in the third grade classroom during classroom hours to other students, including to my child.
5. When I questioned the third grade teacher regarding the distribution of this religious message, the teacher confirmed that the event took place and commented that Vanguard had no policy regarding the distribution of religious material.
6. I am also familiar with the Mom’s Prayer Group which, based on information and belief, Vanguard has permitted to meet on school premises during school hours for the purpose of conducting prayer service, and the Mom’s Prayer Group sponsors a luncheon for school teachers and school administrators at least once per month. On December 14, 1998, I observed a sign in the school which invited the teachers and staff to a Christmas luncheon on December 15, 1998 on school premises, which as stated on the sign was sponsored by the Mom’s prayer group.
7. I have frequently seen religious material such as “focus on the family” brochures, on school property in the parent’s room.
[Item 8 missing in original document.]
9. I observed as recently as Thanksgiving week propped upon a shelf in my child’s kindergarten classroom, a printed drawing of children with the caption of “Jesus loves the little children of the world.”
10.. My sixth grade child is being taught as part of the music curriculum by the Vanguard music teacher, Eunice Kunipers, contemporary Christian music which is not part of any holiday season program.
Further affiant sayeth not.
Dated: December 16, 1998
Barbara Rehner
On this 16th day of Dec., 1998
Veronica J. Tasmich
Notary Public, Kent County
My commission expires: 12/17/00