Measure 58 Lawsuit

Affidavit of Jane Doe 3



             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 JANE DOE 3
      v.                           |    
                                   |
                                   |    
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, JANE DOE 3, being first duly sworn, hereby depose and say:

1. I am an adult citizen and resident of Oregon. I am 23 years of age. I make this Affidavit based on my own personal knowledge.

2. In February 1993, when 1 was 17 years of age, in high school and living at home with my parents in Oregon, I gave birth out ot wedlock to an infant girl ("the child") in a hospital in Salem, Oregon. I immediately placed the child for adoption through LDS Social Services, a licensed adoption agency in Oregon.

3. My decision to place the child for adoption was based on promises of confldentiality and privacy that were made to me by LDS Social Services. I was assured that, under Oregon law, my name and identity would not be disclosed to the child or to the adoptive parents without the mutual consent of all concerned parties.

4. I have no desire to make contact with or to be contacted by the child or the adoptive parents. It is my sincere desire that the original birth certificate containing my name and address at the time of the birth and adoption of the child remain sealed, as I was promised it would be. I believe that if the child or the adoptive parents or anyone else were to obtain confidential information about me under Measure 58, if it becomes law, that there is absolutely nothing that I could do to prevent that information from being disclosed. That would breach promises of confidentiality and privacy that were made to me when I decided to place the child for adoption, and it would be a significant invasion of my privacy.

                                |S| Jane Doe 3
                                Jane Doe 3


        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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