IN THE
UNITED STATED DISTRICT COURT FOR THE
EASTERN DISTRICT OF VIRGINIA
Alexandria Division

______________________________________________________	
                                                      )
MAINSTREAM LOUDOUN, INC., et al.                      )
                                                      )
                                                      )
                      Plaintiffs,                     )
                                                      )
               v.                                     )        Civ. Action No. 97-2049-A
                                                      )
                                                      )
BOARD OF TRUSTEES OF THE LOUDOUN                      )
COUNTY PUBLIC LIBRARY                                 )
                                                      )
                      Defendant.                      )
                                                      )
______________________________________________________)
                                                      )
THE SAFER SEX PAGE, et. al.,                          )
                                                      )
                     Plaintiff-Intervenors,           )
                                                      )
            v.                                        )
                                                      )
BOARD OF TRUSTEES OF THE LOUDOUN                      )
COUNTY PUBLIC LIBRARY                                 )
                                                      )
                     Defendant.                       )
                                                      )
______________________________________________________)

I, Loren Kropat, declare as follows:

1. I am a plaintiff in the above-referenced case.

2. I have resided in Loudoun County for 18 years and am a member of the Purcellville Town Council. I am a regular and frequent user of the Purcellville Library, visiting over 50 times a year, and I use the Internet for research and educational purposes.

3. Since access was provided in November, 1997, I have used the Internet at Loudoun County public libraries on a number of occasions in November and December, 1997, and in January 1998.

4. Contrary to the public position being taken by certain members of the Library Board of Trustees, I have found that the filtering software installed on the Loudoun County library Internet terminals has blocked access to numerous Web sites that contain constitutionally-protected information and have no conceivable connection to pornography. In my experiences in the public library, I have had access blocked to well over 100 Web sites that I believe fall into this category.

5. Examples of some of the Web sites that I have found to be blocked in Loudoun County libraries include the following: The American Association of University Women (www.aauw.org); Information on HIV and AIDS (www.aidsquilt.org/aidsinfo); Criticism of America On Line guidelines on vulgarity (www.aolsucks.org/censor/tos/secret_tos.html); the Atomic Books Web site (www.atomicbooks.com); DNAI, an internet service provider ((www.dnai.com); San Francisco Aids Foundation web page (www.dnai.com/~sfaf); University of Chicago Censorship Fileroom (fileroom.aaup.uic.edu/FileRoom/documents); Gay/Lesbian International News Network (www.glinn.com/); The Heritage Foundation, a conservative think tank (www.heritage.org); Fairness and Accuracy in Reporting. (www.igc.apc.org/fair); CCG Research Protocols (www.nccf.org/nccf/protocol.htm); The Religious Society of Friends (www.quaker.org); Quality Resources Online Books (www.quality.org); Ask Kim Martyn, advice on human sexuality (www.regsex.com/askkim/index.html); Jacksonville Florida, Republican Party site (www.republican-jax-fl.org); the Safe Sex Web site, (www.safesex.org); Ethical Spectacle (www.spectacle.org/freespch); National Journal of Sexual Orientation Law at the University of North Carolina (sunsite.unc.edu/gaylaw/); Yale University Graduate Biology Program (www.biology.yale.edu/graduateprogram.html); Zero Population Growth (www.zpg.org/zpg); Institute for Global Communications Web site (http://www.igc.apc.org/fair); Cybernothing, a site that collects media articles on censorship issues and on the debate over the Communications Decency Act (http://www.cybernothing.org/cno/reports/cyberporn.html); South Carolina Life (http://www.epi.scarolina.edu/general/life.html); Roe v. Wade (http://www.law.cornell.edu/supct/classics/410us113); Touro College (http://law.touro.edu/abouttlc/journals/internation); Canadian National Institute for the Blind (http://www.nation.org/~david/cnib/index.htm); University of Minnesota (http://www.soils.umn.edu/brochures). This is only a partial list of sites that I found were blocked.

6. I have also found that searches are blocked by a "foul word filter" on Internet terminals in the Loudoun County libraries. Contrary to the claims made in the Declaration of Cindy Timmerman filed in support of Defendants' Motion to Dismiss, the foul word blocking feature has been installed on Internet terminals in the libraries, and has been activated at times other than just "a brief period in December," as asserted.

7. Although I found many legitimate Web sites that were blocked in the library, I have not filled out a request form to unblock a site because I would feel intimidated to have to go through that procedure. The Internet Policy that I was required to sign states that the blocked sites contain "pornography" and materials that would constitute "sexual harassment." To request that a site be unblocked, the library user is required to submit a form that contains the patron=s name, library barcode number, telephone number, and a "specific" reason for objection to the blocked site.

I declare, under penalty of perjury, that the foregoing is true and correct. Executed on February __, 1998.