Showing posts with label This Book Is Gay. Show all posts
Showing posts with label This Book Is Gay. Show all posts

Friday, November 8, 2024

Freedom to Read Act: NJ Democrats Protect 'Freedom' to Give Obscene Material to Children, by Alex Newman

NJ Democrats Protect ‘Freedom’ to Give Obscene Material to Children,” by Alex Newman, Liberty Sentinel, October 30, 2024:

Democrat lawmakers in New Jersey just passed a bill granting government employees immunity from civil and criminal liability when giving children access to obscene materials at school or in libraries, sparking outrage among those seeking to protect minors. Predators, groomers, and perverts rejoiced at the news.

The so-called “Freedom to Read Act,” passed by the State Senate on Monday after it was approved in the House earlier this year, is being portrayed by Democrats and their far-left media allies as a measure aimed at limiting “book banning.” The lawmakers behind it also claimed it would protect librarians and teachers from alleged “threats.”  

Under current New Jersey law, giving “obscene material” to a minor is considered a felony of the third degree. Obscenity is described in the statute as any material that includes audio or visual picture or description of s[]xual intercourse, s[]x acts, and more. Numerous books being distributed to children in the state fit that description well.

An example of the books stirring controversy in New Jersey is “This Book is Gay.” It includes, among other outrages, tips on how children can meet up with adults for homos[]xual encounters without letting their parents find out. The book also features detailed and extremely graphic instructions for sodomy and various other s[]x acts.

Because of obscenity laws, which exist nationwide to protect the innocence of children, some librarians and teachers have hesitated before providing such material. Parents and concerned citizens have also warned librarians and “education” officials that they could be running afoul of obscenity laws by giving children access. 

But lawmakers in New Jersey think children need access to such material. “In recent years, public and school libraries have come under attack by a small number of individuals hoping to erase diverse materials from bookshelves, usually targeting works focused on race and LGBTQ+ themes,” argued bill sponsor NJ Senator Andrew Zwicker, a Democrat.

“A library is a place of voluntary inquiry and provides equitable access to learning resources,” continued the far-left senator without acknowledging concerns. “Through the ‘Freedom to Read Act,’ local school boards shall implement policies that ensure our libraries still have an array of content while including the public in that process.”

Ironically, protecting those seeking to corrupt minors with perversion and s[]xual fanaticism was portrayed by Senator Zwicker as a “defense of freedom.” Critics, however, warned that the legislation was an attack on constitutionally protected freedoms including parental rights and the right to petition the government for redress of grievances.

One leading opponent of the bill was Victoria Jakelsky, director and founder of NJ Parental Rights. In her testimony before lawmakers against the legislation, Jakelsky read the legal definition of obscenity and warned that this “freedom” legislation was aimed at stripping parents, taxpayers, and the community of the right (and duty) to protect children.

“This bill is incorrectly named,” she continued. “The legislation is not advocating for any right, except the right of state employees to be exempt from the consequences of committing a crime — a crime that could have lifelong implications upon hundreds if not thousands of innocent children.”

Jakelsky, who has been battling the indoctrination and s[]xualization of New Jersey children in public schools for years, blasted the notion of giving state employees immunity from criminal liability for breaking the law. “Should employees of the NJ Department of Education not be held accountable if they commit this crime?” she asked rhetorically.

GOP lawmakers denounced the bill during debate, too. “How exactly does a person distribute obscene materials to a child in good faith?” asked Senator Michael Testa (Republican) on the floor of the Senate, a reference to protections in the bill for those acting in “good” faith. “I don’t want adults promoting explicit stuff to children.”

“I also think it’s incredibly telling that if some of these very same explicit materials were shown to a child by a neighbor, that individual would be charged with a Megan’s Law offense, and rightfully so,” continued Senator Testa, a reference to a law protecting children named after a 7-year-old girl who was raped and murdered by a predatory neighbor.

Of course, many Democrats claimed there was no obscene material being given to children in schools. Testa was not buying it: “To my colleagues across the aisle that are so adamant that there is no obscene material being pushed in our schools, and that there never will be under this bill, then why do you need an exemption from the obscenity law?”

While bill sponsors and supporters claimed it was the government officials corrupting minors who were being “harassed” and “threatened,” the reality is just the opposite. In fact, as The Newman Report documented last year, parents who advocate for their children have been targeted by law enforcement, lawfare, unions and even the military.

Under current state policy, children in New Jersey are s[]xualized and indoctrinated with LGBT ideology starting as soon as Kindergarten. From being encouraged to experiment with sodomy and other perversions to being taught that they can pick new “genders,” the abuse begins as soon as government gets its hands on the children. 

It appears giving children grotesque and obscene s[]x materials is now a higher priority than teaching basic academics in the Garden State. Just last year, Governor Phil Murphy signed a law eliminating a basic-skills test to ensure government-school teachers know how to read, write, and do basic math. He is expected to sign the new obscenity measure soon.

Civilized societies have always used the law to protect children and punish those who seek to corrupt them with obscene material. Unfortunately, the veneer of civilization is rapidly disappearing, especially in Democrat-controlled states. For the sake of children and society, it is imperative that these horrific trends be reversed — fast.  

For more great content like this, visit FreedomProject Media.


4 thoughts on “NJ Democrats Protect “Freedom” to Give Obscene Material to Children”

LIBERTY

Thank you very much for covering this. It truly is a fight of good against evil here in NJ, but we must not grow weary.
We were thankful for one no vote from one Democrat and that the Democrat from LD-15 Shirley Turner did not vote. The NJ Democrat leadership found a way to block many emails from getting to the legislators. If the democrats had even listened to 20% of those concerned and were willing to look at the facts and the pictures that are in many of the books currently in the school libraries, they would have voted no. The leadership blocked us for being able to tell the the truth.
Thank you for showing this and covering this. God help NJ.


LINDA GOUDSMIT

Always dressed up in positive sounding language, “Freedom to Read” is a license to legally s[]xualize children in schools, libraries, and predictably entertainment, as young as possible. Why? Because a basic tenet of liberal/leftist/Marxism is the deliberate destruction of childhood innocence. The best sentence in the entire article is this: “To my colleagues across the aisle that are so adamant that there is no obscene material being pushed in our schools, and that there never will be under this bill, then why do you need an exemption from the obscenity law?” The essential issue is one of language and definition. The liberal/leftist/Marxist Democrats do not consider any s[]xual act, no matter how perverse or age-inappropriate, to be obscene. Words matter.


TED WEILAND
....


FENICIA REDMAN
Happening next door in PA too. I’m done with legislative hearings. We now have a President who will prosecute these crimes and my Defendants should buckle up!



SOURCE OF ABOVE:


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Monday, March 18, 2024

Moms Countersue School Librarian Roxana Caivano

COYLE & MORRIS LLP
201 Littleton Road, Suite 210
Morris Plains, NJ 07950
(973) 370-0592
jcoyle@coylemorris.com
John D. Coyle 029632001
Attorneys for Defendants
Christina S. Balestriere and Kristen Cobo

__________________________________________
ROXANA M. RUSSO CAIVANO, 
     Plaintiff,

v.

THOMAS SERETIS, CHRISTINA
SCARBROUGH BALESTRIERE, KRISTEN
COBO, AND KATRINA ALBO, and/or 
JOHN DOE 1-5 (fictitious names), JANE DOE 
1-5 (fictitious names),

     Defendants, 

CHRISTINA SCARBROUGH 
BALESTRIERE and KRISTEN COBO,

     Third-Party Plaintiffs,

v.

ANTHONY P. CAIVANO,

     Third-Party Defendant.
__________________________________________


SUPERIOR COURT OF NEW JERSEY LAW DIVISION: MORRIS COUNTY

Docket No.: MRS-L-485-23 
Civil Action

ANSWER, COUNTER-CLAIM, THIRD-PARTY COMPLAINT, DEMAND FOR DISCOVERY, and JURY DEMAND


Christina S. Balestriere (“Christina”) and Kristen Cobo (“Kristen”), by way of Answer to the Complaint of Roxana M. Russo Caivano, say:

FIRST COUNT

1. Christina and Kristen lack knowledge or information sufficient to form a belief as to the truth or falsity of the allegations contained in this paragraph and leave Plaintiff to her proofs.

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2. Christina and Kristen lack knowledge or information sufficient to form a belief as to the truth or falsity of the allegations contained in this paragraph and leave Plaintiff to her proofs. 

3. Christina and Kristen lack knowledge or information sufficient to form a belief as to the truth or falsity of the allegations contained in this paragraph and leave Plaintiff to her proofs. 

4. Christina and Kristen lack knowledge or information sufficient to form a belief as to the truth or falsity of the allegations contained in this paragraph and leave Plaintiff to her proofs. 

5. Christina and Kristen lack knowledge or information sufficient to form a belief as to the truth or falsity of the allegations contained in this paragraph and leave Plaintiff to her proofs. 

6. Christina and Kristen lack knowledge or information sufficient to form a belief as to the truth or falsity of the allegations contained in this paragraph and leave Plaintiff to her proofs.

7. Denied.

8. Christina and Kristen lack knowledge or information sufficient to form a belief as
to the truth or falsity of the allegations contained in this paragraph and leave Plaintiff to her proofs.

9. Denied.

10. Denied.

11. Denied.

12. Christina and Kristen lack knowledge or information sufficient to form a belief as
to the truth or falsity of the allegations contained in this paragraph and leave Plaintiff to her proofs. 

13. Christina and Kristen lack knowledge or information sufficient to form a belief as to the truth or falsity of the allegations contained in this paragraph and leave Plaintiff to her proofs.

SECOND COUNT

1. Christina and Kristen repeat and reallege their responses to the foregoing paragraphs as if fully set forth herein.

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2. Denied.

3. Denied.

4. Denied.

5. Denied.

6. Denied.

7. Denied.

8. Denied.

9. Denied.

THIRD COUNT

1. Christina and Kristen repeat and reallege their responses to the foregoing paragraphs as if fully set forth herein.

2. Denied.

3. Denied.

4. Denied.

5. Denied.

6. Denied.

FOURTH COUNT

1. Christina and Kristen repeat and reallege their responses to the foregoing paragraphs as if fully set forth herein.

2. Christina and Kristen lack knowledge or information sufficient to form a belief as to the truth or falsity of the allegations contained in this paragraph and leave Plaintiff to her proofs.

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3. Christina and Kristen lack knowledge or information sufficient to form a belief as to the truth or falsity of the allegations contained in this paragraph and leave Plaintiff to her proofs.

4. Christina and Kristen lack knowledge or information sufficient to form a belief as to the truth or falsity of the allegations contained in this paragraph and leave Plaintiff to her proofs.

FIFTH COUNT

1. Christina and Kristen repeat and reallege their responses to the foregoing paragraphs as if fully set forth herein.

2. Denied.

3. Denied.

4. Denied.


AFFIRMATIVE DEFENSES

First. Plaintiff’s Complaint fails to state a claim upon which relief can be granted.

Second. Christina and Kristen assert their First Amendment right to freedom of speech regarding their opinions.

Third. Christina and Kristen assert their First Amendment right to petition the government for redress and the legal protections of their statements made pursuant thereto. 

Fourth. Christina and Kristen deny that any statements made were defamatory.

Fifth. Christina and Kristen are protected by the Fair Reporting Privilege.

Sixth. The statements made by Christina and Kristen were true and thus, not defamatory.

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Seventh. The statements made by Christina and Kristen were substantially true, and thus, not defamatory.

Eighth. The statements made by Christina and Kristen were opinion, and thus, not defamatory.

Ninth. The statements made by Christina and Kristen are protected by qualified privileges.

Tenth. The statements made by Christina and Kristen were made in good faith. 

Eleventh. Plaintiff was not damaged by the statements made by Christina and Kristen. 

Twelfth. Plaintiff has received elevated status and not suffered any harm as a result of the statements from Christina and Kristen. https://youtu.be/i4pgUgEn99Y





Thirteenth. Plaintiff is not entitled to punitive damages under the claims asserted here. 

Fourteenth. Plaintiff was a public figure and thus, the statements made by Christina and Kristen are not actionable.

Fifteenth. Plaintiff was a limited purpose public figure, and thus, the statements made by Christina and Kristen are not actionable.

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Sixteenth. The statements made by Christina and Kristen were made regarding a legitimate public concern.

Seventeenth. The statements made by Christina and Kristen were not made with actual malice.

Eighteenth. The statements made by Christina and Kristen were not made with reckless disregard for whether they were true or false.

     WHEREFORE HAVING FULLY ANSWERED, DEFENDANTS CHRISTINA. S. BALESTRIERE AND KRISTEN COBO DEMAND THAT THE COMPLAINT BE DISMISSED AGAINST THEM WITH AN AWARD OF COSTS AND FEES.


JURY DEMAND

Christina and Kristen demand a trial by jury on all issues involved herein.


TRIAL COUNSEL DESIGNATION

Pursuant to Rule 4:25-4, John D. Coyle, Esq. is hereby designated as trial counsel in the within matter on behalf of responding defendants.


RULE 4:5-1 CERTIFICATION

I hereby certify that the matter in controversy is not the subject of any other action pending in any other Court or of a pending arbitration proceeding, nor is it contemplated that the matter in controversy will be the subject of any other action or arbitration proceeding. I further certify that I am not presently aware of the identity of any other party whose joinder is required by law.

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RULE 1:38-7 CERTIFICATION

I hereby certify that all confidential personal identifiers have been redacted and that subsequent papers submitted to the court will not contain confidential personal identifiers in accordance with the provisions of this rule.


COUNTER_CLAIM AND THIRD-PARTY CLAIM

Defendants/Counter-Claimants/Third-Party Plaintiffs Christina S. Balestriere and Kristen Cobo, by way of Counter-Claim against Plaintiff, and Third-Party Complaint against Anthony Caivano, hereby state:

1. Plaintiff Christina S. Balestriere grew up in West Orange, NJ and graduated from Mount Saint Dominic Academy. She went on to receive her Bachelor’s Degree in Psychology from Drew University and eventually her Certificate of Eligibility with Advanced Standing for Teacher of Students with Disabilities from The College of Saint Elizabeth.

2. A former Catholic school Physical Education teacher and most recently a public school Special Education teacher, Christina moved with her family to Roxbury in 2014 and chose to stay home and raise her 3 young children. She is a member of St. Therese Church and an active member of the community with her children involved in multiple sports and activities.

3. Having 3 boys moving up through the public school system and having been an educator herself, Christina understands the importance of being involved in her children's education both present and future.

4. Plaintiff Kristen Cobo moved to Roxbury at age 6 and attended Roxbury schools from 1st grade, ultimately graduating from Roxbury High School in 2003. She went on to receive her Bachelor of Social Work degree at Ramapo College, receiving advanced standing in her major.

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Kristen then attended Fordham University and received her Masters of Social Work degree with a specialization in children and families in just one year.

5. Kristen went on to receive her LCSW(Licensed Clinical Social Worker) and beyond that, a certificate in clinical supervision which enables her to supervise and train new therapists; a requirement prior to becoming licensed. She has worked in the mental health field for 18 years and has seen the detriments of adults who are unable to put the safety and wellbeing of children first. Kristen worked at St. Clare’s Children’s Crisis Unit, High Focus Centers Children’s Psych, and for Effective School solutions for 9 years at which time she was a direct clinician and ultimately a Regional Clinical Director overseeing the intensive clinical mental health services being provided to the most at risk students in school districts all over NJ.

6. She currently has her own private practice which she opened in 2022. In 2022, Kristen was appointed by the Roxbury school principal to her children’s school crisis response team, a volunteer position. She has been an active member at St. Therese RC Church in Succasunna for the last 31 years, attending church every Sunday with her family. Kristen currently resides with her husband of 10 years and two children. Kristen enjoys volunteering in the many activities in which her children participate, including Girls Scouts of America, CCD, coaching little league baseball and many other activities at her children’s school.

7. In or around August of 2022, Christina and Kristen became aware of three books that were in the Roxbury Public School library which is used by students as young as age 13.

8. Subsequently, Christina and Kristen learned that the books, “This Book is Gay,” “Lawn Boy,” “Gender Queer,” “Fun House,” and “All Boys Aren’t Blue” were in the library.

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9. Christina and Kristen contacted Roxbury School Superintendent, Dr. Radulic, to advise her of the presence of these books as well as the explicitly sexually explicit illustrations in said books.

10. Dr. Radulic advised Defendants to contact the school librarian, Plaintiff Roxana Caivano, to raise their concerns.

11. On August 29th 2022, Dr. Loretta Radulic emailed Roxana Caivano explicitly requesting her to remove the books. “......I’m sure Dominick already shared with you that we will temporarily pull the books off the shelf and ask the parent to complete a ‘challenge ’form for review.”

12. On August 29, 2022, Roxana Caivano emailed Dr. Radulic back saying, “I thought we said this morning that I would respond to the parent with the draft I shared and add that I would put the books behind the desk and give them out upon request. I thought we were going to wait and see if this would appease her before we suggested the challenge form.”

13. Dr. Loretta Radulic emailed Caivano back and wrote, “Upon review with Dominick and Chuck and taking a look at the books, our directed [sic] changed a bit.”

14. Jonathan Evison, the author of Lawn Boy told the Washington Post that he “never meant for his book to be placed in school libraries.”

15. Jonathan Evison further told the Washington Post that Lawn Boy is “meant for adults.”

16. Jonathan Evison then added, “If schools want to offer the text, he said, they should restrict access to older students.”

17. On August 31, 2022, Defendant, Christina Balestriere, emailed Roxana Caivano, with her concerns that these books were available to all ages.

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18. In response, on September 9, 2022, Roxana Caivano responded and confirmed that all three books are in fact in the Roxbury High School Public Library. She explicitly stated, “...yes, I have read them all myself.”

19. Roxana Caivano sends twitter messages under the Twitter handle, “Roxbury Media” using @roxburymedia.

20. On September 19, 2022, Roxana Caivano sent a tweet out explicitly recommending that readers read five books, including the three previously identified: “This Book is Gay,” “Lawn Boy,” “Gender Queer,” “Fun House,” and “All Boys Aren’t Blue.”



21. The purpose of display of books in a library is to draw attention to books and suggest they be read.

22. On or before September 19, 2022, Roxana Caivano created an “end cap” display for the library to promote and encourage children to read these 5 books and others.

23. This new library display from Roxana Caivano included other books, such as “Let’s Talk About It.”

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24. Let’s Talk About It includes diagrams showing the following, labeled “Things to Try:”



25. Through the Twitter post and the library display, Roxana Caivano encouraged children as young as age 13 to read Let’s Talk About It, and thus, encouraged children as young as 13 to “have an assload of fun with a healthy helping of lube.”

26. Through the Twitter post and the library display, Roxana Caivano encouraged children as young as age 13 to read This Book Is Gay, and thus, encouraged children as young as 13 to learn how to access “Sex Apps” including Grindr.

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27. According to the Grindr terms of service, the app prohibits anyone under the age of 18 from accessing, directly or indirectly, viewing, downloading, or otherwise using Grindr services.

28. While the Grindr app is specifically identified in This Book is Gay, upon information and belief, the terms of service for all other sex apps prohibit use by minors.

29. Also, by encouraging children as young as 13 to read This Boy is Gay, Roxana Caivano encouraged them to learn such terms as:



30. Through the Twitter post and the library display, Roxana Caivano encouraged children as young as age 13 to read “Gender Queer.”

31. Amazon.com lists Gender Queer as appropriate for ages “18 years and up.”

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32. Gender Queer includes illustrations where the under-age narrator fantasized about an adult man pulling the penis of a child as the child pulls the adult male to him.



33. Gender Queer also includes illustrations of a librarian “sexting” or sending and receiving sexual messages in a public library.



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34. As depicted in the illustration promoted by Roxana Caivano to children as young as 13, the librarian receives a message “I can’t wait to get your cock in my mouth—I’m going to give you the blow job of your life.”

35. Another illustration from the Gender Queer book promoted by Roxana Caivano to children as young as 13 depicts the acts from the librarian’s sexting from the prior panel.




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36. Another of the books promoted by Roxana Caivano to children as young as 13 was Lawn Boy, which depicts various set acts involving children as young as ten:

“What if I told you I touched another guy’s dick?” I said. ...“What if I told you I sucked it?” ...“I was ten years old, but it’s true. I put Doug Goble’s dick in my mouth.”
...
“All I could think about while he was chatting me up over the rim of his cappuccino was his little salamander between my fourth-grade fingers, rapidly engorging with blood.”

37. In response, Christina and Kristen spoke at the Roxbury Board of Education meetings on September 19, 2022 where Kristen, a licensed clinical social worker, with a specialization in children and families from Fordham University, referenced legal prohibitions against displaying certain materials to children.

38. Kristen cited N.J.S.A. 2C:24-4B(5)(B). “Endangering the Welfare of a Child” which states that it is unlawful to knowingly view or possess any media, including video games, that depict a child engaged in a sexual act. The law applies to simulations and actual acts. It also states that exposing a minor to sexual activity in a manner that may debauch or impair his or her morals is a third-degree offense that carries a sentence of up to five years in prison. If the act is committed by a parent or by one who has authority over a child, the crime escalates into a second- degree offense.

39. Christina and/or Kristen attended the subsequent Board of Education meetings to repeatedly ask the school board to remove these sexually explicit materials from the library.

40. Roxana Caivano has refused to stop promoting those books, containing the passages outlined above, to children as young as 13, and continues to do so to this day.

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41. As recently as May 19, 2023, she widely disseminated an email trying to rally
people to come to the May 23, 2023 Roxbury School Board meeting to “ show up in support so we can silence them” referring to Christina and Kristen.

42. At the School Board Meeting, after triumphantly raising her arms, Roxana Caivano and Anthony Caivano walked down the aisle yelling at parents and pointing at them, including Christina and Kristen.



43. Roxana Caivano even concluded by hitting the sign of a seated person exercising their First Amendment Rights to petition the government for redress.




Defamatory Statements

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February 1, 2023 Posting

44. On February 1, 2023, Third-Party defendant Anthony “Tony” Caivano posted a message in a Facebook chat stating that his wife Roxana Caivano “has had multiple book challenges this year from a posse of book burners,” referring to Christina and Kristen.

45. The message was on a chat that was shared with multiple recipients from the conversation and was seen and commented on by others.

46. Anthony Caivano further stated, “We are going to defeat this reactionary bullshit.”

47. Anthony Caivano made those statements knowingly referring to Christina and Kristen.

48. Anthony Caivano made those statements with the intention that a reasonable person would understand them to refer to Christina and Kristen.

49. According to the United States Holocaust Museum(1):
Book burning has a long and dark history.
Book burning refers to the ritual destruction by fire of books or other written materials. Usually carried out in a public context, the burning of books represents an element of censorship and usually proceeds from a cultural, religious, or political opposition to the materials in question.
The burning of books under the Nazi regime on May 10, 1933, is perhaps the most famous book burning in history.

50. The term “book burners” as used by Anthony Caivano to refer to Christina and Kristen was a reference to the practice from Nazi Germany of burning books:
____________________
(1) https://encyclopedia.ushmm.org/content/en/article/book-burning

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51. By referring to Christina and Kristen as “Book Burners,” Anthony Caivano intended for the readers of his message to associate Christina and Kristen with Nazis.

52. Anthony Caivano made these statements with the intention that a reasonable person would understand them to refer to Christina and Kristen.

53. Anthony Caivano made the statements about Christina and Kristen with knowledge that they were not Nazis or with reckless disregard for the truth that they were not Nazis.

February 1, 2023 Second Posting

54. On February 1, 2023, Roxana Caivano referred to parents who question these books as “fascists” on Tony Caivano’s public Facebook page.

55. Roxana Caivano made those statements knowingly referring to Christina and Kristen.

56. Roxana Caivano made those statements with the intention that a reasonable person would understand them to refer to Christina and Kristen.

57. By calling Christina and Kristen Book Burners and Fascists in a single chat, Roxana Caivano and Anthony Caivano worked together toward a single goal of having the readers identify Christina and Kristen as Nazis.

April 27, 2023 Interview

58. In a televised interview with ABC news on April 27, 2023, Roxana Caivano stated that the
parents she is suing, referring to Christina and Kristen, “called me a pornographer.”

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59. Roxana Caivano knew that the statement that Christina and Kristen called her “a pornographer” was false, or with a reckless disregard for the truth of the statement.

60. Roxana Caivano knew that the April 27, 2023 interview would be broadcast, intended for it to be broadcast, and it was broadcast on television.

61. It also remains on the ABC7NY.com website as a streaming video clip today.

April 27, 2023 Postings

62. On April 27, 2023, in the Tap Into Roxbury public comments section, Anthony Caivano wrote “...no one has a right to call any librarian a criminal, a groomer or a pornographer, which is precisely what the Roxbury crew did to Roxana.”

63. Anthony Caivano made his statements knowing, or with a reckless disregard for the truth, that Christina and Kristen did not call Roxana Caivano a “criminal.”

64. Anthony Caivano made his statements knowing, or with a reckless disregard for the truth, that Christina and Kristen did not call Roxana Caivano a “pornographer.”

65. Anthony Caivano made his statements knowing, or with a reckless disregard for the truth, that Christina and Kristen did not call Roxana Caivano a “groomer.”

May 9, 2023 Interview

66. Roxana Caivano was interviewed for an article posted on NJ 101.5.

67. Roxana Caivano stated that Christina and Kristen objected to the books described above
“because of its LGBTQ content.”

68. Roxana Caivano knew, or had a reckless disregard for the truth, that Christina and Kristen objected to the books based on their sexual content, not because of the LGBTQ content.

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May 25, 2023 NJ Spotlight News Q&A

69. Roxana Caivano was interviewed for the NJ Spotlight News Q&A article on or about May 24, 2023.

70. In the article posted at https://www.njspotlightnews.org/2023/05/q-a-roxana-russo- caivano-librarian-in-nj-book-ban-fight/, Roxana Caivano falsely stated that she was called vile names by members of the Roxbury community and that she has sued the group of parents.

71. Roxana Caivano made that statement knowing it would be publicized.

72. Roxana Caivano knew, or had a reckless disregard for the truth, that Christina and Kristen
did not call her “vile names.”

73. Roxana Caivano made that statement intending for others to understand it to be referring to Christina and Kristen.

74. It was reasonable for people reading the NJ Spotlight News online article to believe the Roxana Caivano was referring to Christina and Kristen.

75. Collectively the February 1, 2023 Posting, February 1, 2023 Second Posting, April 27, 2023 Interview, April 27, 2023 Postings, May 9, 2023 Interview, and May 25, 2023 NJ Spotlight News Q&A are referred to hereinafter as the Defamatory Statements.

FIRST COUNT

(Libel and Defamation)

76. Christina and Kristen repeat and reallege their allegations in the prior paragraphs as if fully
set forth herein.

77. Roxana Caivano and Anthony Caivano made the Defamatory Statements as alleged facts regarding Christina and Kristen.

78. The Defamatory Statements were published to third persons orally and in writing.

20

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79. Roxana Caivano and Anthony Caivano made the Defamatory Statements with negligent disregard for the truth of the statements.

80. Roxana Caivano and Anthony Caivano made the Defamatory Statements with careless disregard for the truth of the statements.

81. Roxana Caivano and Anthony Caivano made the Defamatory Statements with reckless disregard for the truth of the statements.

82. Roxana Caivano and Anthony Caivano made the Defamatory Statements intentionally knowing the statements were untrue.

83. Roxana Caivano and Anthony Caivano made the Defamatory Statements intending to cause harm to Christina and Kristen.

84. As a result, Christina and Kristen suffered harm to their reputation, standing, professional and personal capacity, and have been cast in a false light.

85. Kristen has had clients cancel her services as a result of the defamatory statements from Roxana Caivano and Anthony Caivano.

86. The Defamatory Statements were defamatory per se.

87. As a result, Christina and Kristen have been damaged.

     WHEREFORE, Christina and Kristen demand judgment against Roxana Caivano and
Anthony Caivano, individually, jointly, and severally, for compensatory damages, punitive damages, interest, and costs of suit.

SECOND COUNT

(Intentional Infliction of Emotional Distress)

88. Christina and Kristen repeat and reallege their allegations in the prior paragraphs as if fully
set forth herein.

21

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89. As a direct and proximate result of the Defamatory Statements, Christina and Kristen suffered and continued to suffer emotional distress.

90. As a result, Christina and Kristen suffered harm to their reputation, standing, professional and personal capacity, and have been cast in a false light.

91. Kristen has had clients cancel her services as a result of the defamatory statements from Roxana Caivano and Anthony Caivano.

92. As a result, Christina and Kristen were damaged.

     WHEREFORE, Christina and Kristen demand judgment against Roxana Caivano and Anthony Caivano, individually, jointly, and severally, for compensatory damages, punitive damages, interest, and costs of 
suit.

DEMAND FOR ANSWERS TO INTERROGATORIES

Pursuant to Rule 4:17-1, Defendants/Third-Party Plaintiffs/Counter-Claimants Christina Balestriere and Kristen Cobo serve the following requests for answers to interrogatories with this pleading. Responses are due within the time calculated in Rule 4:17-4(b), 60 days after service of the summons and complaint:

1 Identify the “vile names” that you contend that Christina and Kristen called you and for each alleged occasion, set forth:

     a. Whether the statement was made in print or orally;

     b. The date and time of the utterance;

     c. The location of the utterance;

     d. All persons who were present when the statement was made or who heard the statement.

     e. If the statement was written, where the statement was printed and the location thereof.

2 Set forth all facts to support the statement that Christina and Kristen are “book burners.” 

22

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3 Identify all instances when Christina and/or Kristen burned books and for each alleged occasion, set forth:

     a. The date and time of the book burning;

     b. The location of the book burning;

     c. All persons who were present when Christina and/or Kristen burned books.

     d. Identify any and all photographs, videos, or other media depictions of Christina and/or Kristen burning books.

4 Set forth all facts to support the statement that Christina and Kristen objected to the
books identified in the Counter-Claim and Third-Party Complaint “because of its LGBTQ content.”

5 For each for each alleged instance where Christina and Kristen objected because of the book’s LGBTQ content, set forth:

     a. Whether the statement was made in print or orally;

     b. The date and time of the utterance;

     c. The location of the utterance;

     d. All persons who were present when the statement was made or who heard the statement.

     e. If the statement was written, where the statement was printed and the location thereof.

6 Set forth all facts to support the statement that Christina and Kristen called Roxana a “pornographer” and for each alleged occasion, set forth:

     a. Whether the statement was made in print or orally;

     b. The date and time of the utterance;

     c. The location of the utterance;

     d. All persons who were present when the statement was made or who heard the statement.

     e. If the statement was written, where the statement was printed and the location thereof.

7 Set forth all facts to support the statement that Christina and Kristen called Roxana a “criminal” and for each alleged occasion, set forth:

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     a. Whether the statement was made in print or orally;

     b. The date and time of the utterance;

     c. The location of the utterance;

     d. All persons who were present when the statement was made or who heard the statement.

     e. If the statement was written, where the statement was printed and the location thereof.

8 Set forth all facts to support the statement that Christina and Kristen called Roxana a “groomer” and for each alleged occasion, set forth:

     a. Whether the statement was made in print or orally;

     b. The date and time of the utterance;

     c. The location of the utterance;

     d. All persons who were present when the statement was made or who heard the statement.

     e. If the statement was written, where the statement was printed and the location thereof.

9 Identify and set forth the factual basis for your assertion in paragraph 3 of the Second Count of the Complaint that Christina and Kristen engaged in a civil conspiracy to jointly attack the plaintiff’s reputation, slander, and libel the plaintiff, defame the plaintiff, deprive the plaintiff of her constitutionally guaranteed rights.
    
10 Set forth the ways in which Roxana’s relationship with her employer has been impacted as set forth in paragraph 3 of the Second Count of the Complaint.

11 Set forth the emotional distress that Plaintiff alleges to have suffered as a result of the conduct alleged in her complaint to have been committed by Christina and Kristen.

12 Set forth the physical manifestations of the emotional distress that Plaintiff alleges to have suffered as a result of the conduct alleged in her complaint to have been committed by Christina and Kristen.

13 IdentifyallmedicalproviderswhoPlaintiffhastreatedwithasaresultoftheemotional distress that Plaintiff alleges to have suffered as a result of the conduct alleged in her complaint to have been committed by Christina and Kristen.

     a. For each provider identified in the answers to the prior interrogatory, execute a HIPAA authorization for the release of medical records.

24

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14 Set forth all damages alleged to have been sustained by Plaintiff to her reputation as a result of the conduct alleged in her complaint to have been committed by Christina and Kristen.

15 Set forth all damages alleged to have been sustained by Plaintiff to her personal reputation as a result of the conduct alleged in her complaint to have been committed by Christina and Kristen.

16 Set forth all damages alleged to have been sustained by Plaintiff to her employment as a result of the conduct alleged in her complaint to have been committed by Christina and Kristen.

17 Set forth all facts to support the allegations in the Fifth Count of the Complaint that Christina and Kristen engaged in “purposeful malicious conduct” to interfere with Plaintiff’s employment.

18 Set forth all facts to support the allegations in the Fifth Count of the Complaint that Christina and Kristen engaged in “purposeful malicious conduct” to interfere with Plaintiff’s prospective economic opportunities.

19 Identify any and all prospective economic opportunities that Plaintiff has lost as a result of the conduct alleged in her complaint to have been committed by Christina and Kristen.

20 Identify any and all injuries that have been inflicted on Plaintiff as a result of the conduct alleged in her complaint to have been committed by Christina and Kristen.

21 Identify all persons with relevant knowledge of the claims in the Complaint, or your affirmative defenses raised in response to this Counter-Claim and/or Third-Party Complaint and for each person identified, set forth:

     a. Their address and telephone number;

     b. The basis of their knowledge;

     c. A description of their knowledge.


DEMAND FOR PRODUCTION OF DOCUMENTS

Pursuant to Rule 4:18-1, Defendants/Third-Party Plaintiffs/Counter-Claimants
Christina Balestriere and Kristen Cobo serve the following requests for the production of documents with this Complaint. Responses are due within the time calculated in Rule 4:18- 1(b)(2), 50 days after service of this pleading:

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     1 Produce a copy of all documents sufficient to identify when the book “Gender Queer” was purchased for the Roxbury Library.

     2 Produce a copy of all documents identified or referenced in your answers to interrogatories.

Dated: May 31, 2023
COYLE & MORRIS LLP
s/ John D. Coyle
John D. Coyle
Attorney ID: 029632001
201 Littleton Road, Suite 210 
Morris Plains, NJ 07950
(973) 370-3519 
jcoyle@coylemorris.com 
Attorneys for Defendants/Counter- 
Claimants/Third-Party Plaintiffs 
Christina Scarbrough Balestriere 
and Kristen Cobo

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Civil Case Information Statement

Case Details: MORRIS | Civil Part Docket# L-000485-23

Case Caption: RUSSO CAIVANO ROXANA VS SERETIS THOMAS
Case Initiation Date: 03/17/2023
Attorney Name: RONALD T NAGLE
Firm Name: RONALD T. NAGLE, PC 
Address: 52 SOUTH STREET 
MORRISTOWN NJ 079600000 
Phone: 9732676780
Name of Party: PLAINTIFF : BALESTRIERE, CHRISTINA, S 
Name of Defendant’s Primary Insurance Company
(if known): None
Case Type: DEFAMATION
Document Type: Answer W/Jury Demand
Jury Demand: YES - 6 JURORS
Is this a professional malpractice case? NO
Related cases pending: NO
If yes, list docket numbers:
Do you anticipate adding any parties (arising out of same transaction or occurrence)? NO
Does this case involve claims related to COVID-19? NO
Are sexual abuse claims alleged by: ROXANA M RUSSO CAIVANO? NO
Are sexual abuse claims alleged by: CHRISTINA S BALESTRIERE? NO
Are sexual abuse claims alleged by: KRISTEN COBO? NO
 
THE INFORMATION PROVIDED ON THIS FORM CANNOT BE INTRODUCED INTO EVIDENCE
CASE CHARACTERISTICS FOR PURPOSES OF DETERMINING IF CASE IS APPROPRIATE FOR MEDIATION
Do parties have a current, past, or recurrent relationship? NO
If yes, is that relationship:
Does the statute governing this case provide for payment of fees by the losing party? NO
Use this space to alert the court to any special case characteristics that may warrant individual management or accelerated disposition:

Do you or your client need any disability accommodations? NO 
If yes, please identify the requested accommodation:

Will an interpreter be needed? NO If yes, for what language:

Please check off each applicable category: Putative Class Action? NO Title 59? NO Consumer Fraud? NO

I certify that confidential personal identifiers have been redacted from documents now submitted to the court, and will be redacted from all documents submitted in the future in accordance with Rule 1:38-7(b)

MRS--L--000485--23 08//02//20232::48::4379PM Pg 2 of 2 TTrarnasnsIDID: L: CLCVV20220322323293895855

08/02/2023 
Dated

/s/ RONALD T NAGLE
Signed


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Friday, December 15, 2023

Tennessee Walking Horses - TN Parents Astroturfed by ALA Use High Stepping Lies to Overwhelm Rutherford County Library Board; It's an ALA Pattern Nationwide

American Library Association [ALA] creates, funds, fund raises for, and advertises local groups to appear as if they were grassroots.  This is called astroturfing as in fake grass.  In reality, local groups just do what ALA wants.  

In Tennessee, like Tennessee Walking Horses, parents are trained to high step ALA's lie that children have a First Amendment right to anything whatsoever, such as books that guide children how to meet a man for a night using the Grindr app.  They explicitly rely on ALA's "Library Bill of Rights" that makes it age discrimination to keep anything from children, although in all other areas of society children are given limited access, like tattoos, voting, drinking, driving, video games, music, etc.  Then, as trained by ALA such as with Unite Against Book Bans, they claim people oppose homosexuality, not that children are receiving CSAM from public libraries. 

So, in Tennessee, there's the "Rutherford County Library Alliance."  It is an ALA astroturfed organization.  Here's where the astroturfing is documented, and when reading EveryLibrary (and its Fight For the First), know that's just a crypto ALA organization created by and working closely with ALA to do what ALA cannot do directly.  See: Rutherford County Library Alliance.  One of its members, for example, is "TM,"—notice how membership is hidden.  TM is Tasslyn Magnusson, pictured below.  She has her "Book Censorship Database by Dr. Tasslyn Magnusson" prominently displayed at EveryLibrary, with her name even in the URL itself: www.everylibraryinstitute.org/book_censorship_database_magnusson

So it's astroturfed.  Faked grass roots.  Created by ALA.  With one of its own members as a member of a local astroturfed organization, someone who helped create the web site, "Support Teachers CRT Toolkit."  

Is this person's views even known?  Do they represent the local community in Tennessee?  ALA features her in a blog post.  Look what she says, because she's targeting parents groups who oppose the indoctrination of school children by librarians and teachers and decries "censorship":

Tasslyn Magnusson is an educator and a member of children’s literacy organizations who has worked to create the website CRT Toolkit to support educators, parents, and community members who are concerned about misrepresentations and attempts at unjust censorship. 

She said that when googling Critical Race Theory, she found “fear-based ‘toolkits’ for parents to get active at their school boards and in their kids’ classrooms created by organizations with names like Heritage Action for America and Citizens for Renewing America.  And they were very much NOT trying to support educators and books and stories that represented all of American history and diverse stories.  I was astonished by the instructions and detail these toolkits gave to parents—and appalled by the disinformation throughout the kits.”

“I decided if I needed tools—other parents and community members might need them too.”


She's got tools, alright.  And she's turned them against local communities by appearing AS A MEMBER of that local community.  She doesn't like "Heritage Action for America" nor "Citizens for Renewing America," but she's okay with being a member of "Rutherford County Library Alliance."  She's no Tennessee Walking Horse, she's an ALA stalking horse.

As I go on, know this: many "parents" groups around the nation pressuring libraries to keep children exposed to inappropriate material are actually astroturfed creations of ALA, the very out-of-state organization exposing children to harm.  It's an ALA pattern nationwide.  Is your library getting a lot of out-of-towners pressuring your library board into what the community supposedly opposes?  Good chance it's an ALA astroturf mob.  Sort of like when school librarian Martha Hickson handed out trademarked logos of ALA in a New Jersey school board meeting, but I digress. 


Supporter Angela Frederick, an area representative for the Tennessee Association of School Librarians [TASL], writes on Facebook in support of the astroturfed parent group to get them to get out huge numbers, and the books she's talking about that the library removed are "Gender Queer," "Flamer," (detailed above in a post by Asra Nomani to give an example of what a school librarian is defending and how it and books like it are promoted by any means necessary, including as a substitute Bible for being sworn in on a school board—it also illustrates how political activists like someone from Media Matters for America will get on boards simply to promote political agendas, similar to what ALA astroturfed groups are doing to pressure boards) "Let’s Talk About It," and "This Book is Gay," books that promote kink and pedophilia:

TN Public Library Supporters:

I am writing today to let you know of a situation currently affecting the Rutherford County Library System. 

Several books were removed from the collection by the RCLS Library Board back in August.  The steering committee of the Rutherford County Commission met in November and stated that the library board had sought their help in ensuring that the library staff didn't purchase any other objectionable materials using taxpayer funds.  The steering committee directed the library board to come up with a plan to prevent these purchases, and stated that if such a plan was not acceptable to them, they would pull county funding from RCLS. 

Currently Rutherford County funds 60% of RCLS's budget, so no county funding will essentially close the libraries.  This would obviously be a travesty for the residents of Rutherford County. 

If you are a resident of Rutherford County, please contact the steering committee and let them know how a defunded public library would affect our community.  You can copy and paste these addresses to contact them directly:  (district8@rutherfordcountytn.gov, district13@rutherfordcountytn.gov, jbeverly@rutherfordcountytn.gov, district18@rutherfordcountytn.gov, district7@rutherfordcountytn.gov, craigharris@rutherfordcountytn.gov, district3@rutherfordcountytn.gov)  

Another way to help is to attend the next meetings of both the library board and the steering committee.  The library board will have a specially called meeting on Monday, December 18th at 5:00 p.m. at the Rutherford County Courthouse.  The next steering committee meeting is on Monday, January 8th at 5:30 p.m. at the Historic County Courthouse Commission Chamber.  We need all the attention we can get on these two meetings. 

Helpful links:
Interview with Rutherford County Library Alliance members: https://www.youtube.com/watch?v=Zisf2MWKcLk&t=29s

Thank you,
Angela Frederick
TASL Member
[Ed: TASL Area Representative, Buffalo River Region, term ends 2024]
-- 
Angela Frederick
angela.frederick@gmail.com

See that?  "The steering committee directed the library board to come up with a plan to prevent these purchases, and stated that if such a plan was not acceptable to them, they would pull county funding from RCLS."  That's a double standard, meaning a lie.  Librarians brag about pulling funding from libraries in states that adopt the "Right to Read Act" that explicitly makes ALA's "Library Bill of Rights" into state law without any discussion of its radical 60s roots.  They are gleeful about that.  See: "To Fight So-called Book Bans, Some States are Threatening to Withhold Funding," All Things Considered, NPR, 14 December 2023.

But here a library is going to pull funding if the librarians keep buying CSAM, and suddenly this ALA astroturf group led by a CRT Toolkit creator from out-of-state is crying about a denial of rights.  Double standard.  

The whole astroturf published on Facebook was about "defunding" the library because CSAM was removed and they feign fear more will be removed.  They want people to write to the board.  They want people to attend the meetings.  "We need all the attention we can get on these two meetings."  

But it's not locals who want this.  It's ALA!  ALA is using an astroturf group they created, funded, and gave publicity!  

So if Tennessee wants to see Tennessee Walking Horses putting on a show after being trained by ALA with direction to make excuses for CSAM by claiming children have a First Amendment right to that, then go watch the circus in action.  Do go, to support the board against the ALA's astroturfed group.  But the board should stay on course and serve common sense, community standards, and the law, and not some Marxist-led group of librarians from Chicago, Illinois, who created a local group to pressure and bully the board.  

So now the board knows the truth.  Now we know Rutherford County Library Alliance is a stalking horse for American Library Association, being used to obtain a temporary advantage so that out-of-state ALA can target what it really wants: children in Murfreesboro, TN.

And this kind of circus set up by ALA is happening in community after community, set up by ALA.  Everyone, not just Tennessee, should learn about and ignore/defeat the ALA astroturfed acolytes.

I'll be sending this to the email addresses I learned from the astroturfers.

By the way, here's ALA targeting children, because if a board allows an ALA astroturf group to pressure it, it might as well see what ALA wants—children:




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Wednesday, May 10, 2023

Plainview ISD TPIA-FOIA Request

Plainview ISD
2417 Yonkers St
Plainview TX 79072
806-293-6000
10 May 2023

Via email to: ivan.monarrez@plainviewisd.org, rosie.licerio@plainviewisd.org

PROJECT CODE: PLAINVIEW ISD TPIA REQUEST #001

Dear Plainview ISD TPIA Officer:

This is a noncommercial FOIA request from a member of the news media for electronic production of documentation per the Texas Public Information Act, §6252-17a et seq. (TPIA), to this email address, to my attention, using the above-referenced research project code.

TPIA requires that you "promptly produce" the requested records unless, within 10 days, you have sought an Attorney General's Opinion. If you deny any or all of this request, please cite each specific exemption you feel justifies the refusal to release the information and notify me of the appeal procedures available to me under the law.

All documentation should be produced as PDFs or CSV files, with the exception of photographs (which should be JPEG), audio files (which should be MP3), and video (which should be MP4 or MOV). If documentation files are too large to transmit in an email, transmit them to me either using a free file sharing service (such as Dropbox) or by sending multiple emails (as many as needed).

I seek the following numbered categories of documentation for my research pursuant to news articles and a book I am writing that has interest and value to the public:

1) Documentation of a listing of all materials in the school’s library or libraries that are for the educational use of school children. This could be a printout of a database containing all records of what books or other learning materials are contained within the library or libraries. Do not include any records of a personal nature about any individual. Librarians or media specialists maintain databases that comprise such lists. This should be a simple export to a computer file of the records contained in that database in comma separated variable format. I expect this export to take at most five minutes.

2) Documentation of a listing of all materials in the school’s library or libraries online databases like SORA, OverDrive, EBSCO, Gale, etc., that are for the educational use of school children. This could be a printout of a database containing all records of what books or other learning materials are contained within the library or libraries online resources. Do not include any records of a personal nature about any individual. Librarians or media specialists maintain databases that comprise such lists of what’s available online. This should be a simple export to a computer file of the records contained in that database in comma separated variable format. I expect this export to take at most five minutes.

3) Documentation of the "status" of the "Texas Educator Certificate" of each librarian or media specialist. I expect this export to PDF to take at most five minutes per employee and that such information would be available from https://tealprod.tea.state.tx.us/ECOS-External/EcosOnline/VirtCert

4) Documentation of each librarian and media specialist’s curriculum vitae (CV). I expect this to take at most five minutes per individual.

5) Documentation of each librarian and media specialist’s membership in American Library Association (ALA) and ALA’s American Association of School Librarians (AASL). I expect this to take at most five minutes per individual.

6) Documentation of each librarian and media specialist’s membership in Texas Library Association (TXLA) and TXLA’s Texas Association of School Librarians (TASL). I expect this to take at most five minutes per individual.

7) Documentation of each librarian and media specialist’s attendance online or in person of all ALA and AASL events, including the name of all events attended. I expect this to take at most ten minutes per individual.

8) Documentation of each librarian and media specialist’s attendance online or in person of all TXLA and TASL events, including the name of all events attended. I expect this to take at most ten minutes per individual.

9) Documentation of the presence of the following book within the school libraries, school classroom libraries, and any other collection of books within the school: Gender Queer: A Memoir by Maia Kobabe. I expect this to take at most five minutes per library.

10) Documentation regarding the following book within the school libraries, school classroom libraries, and any other collection of books within the school: Flamer by Mike Curato. I expect this to take at most five minutes per library.

11) Documentation of the presence of the following book within the school libraries, school classroom libraries, and any other collection of books within the school: This Book Is Gay by Juno Dawson. I expect this to take at most five minutes per library.

12) Documentation of the presence of the following book within the school libraries, school classroom libraries, and any other collection of books within the school: This Book Is Gay by James Dawson. (This request is framed this way merely to avoid gamesmanship in responding to the previous question.) I expect this to take no time at all if the above is honestly answered.

13) Documentation of lists of recommended books provided to teachers by the school’s librarians and media specialists. I expect this to take at most five minutes per individual.

14) Documentation of any financial donations or gifts or awards to the school system by ALA, AASL, TXLA, TASL. I have to ask this since ALA makes a habit of influencing local communities with quiet money. In Highland Park, TX, for example, Freedom to Read Foundation (FTRF), an ALA entity now with Texas connection Dorcas Hand on the board, gave $5,000 dollars to local advocates of ALA’s political positions. See page 10: http://www.ala.org/aboutala/sites/ala.org.aboutala/files/content/governance/officers/eb_documents/2014_2015ebdocuments/ebd12_12_exec_dir_rpt_11dec14.pdf. I expect this to take at most five minutes.

15) Documentation of all communications of the school librarians and media specialists from the date of the incident of the first graders forcing another first grader to engage in oral sex while another first grader filmed the event to present. I expect this to take at most five minutes per individual given to super limited time nature of this request.

I am a reporter on library matters where I publish on SafeLibraries®. As such I may publish anything you send me. Thus, I ask that all fees for the production of TPIA responses be waived: "If a governmental body determines that producing the information requested is in the 'public interest' because it will primarily benefit the general public, the governmental body shall waive or reduce the charges." "Shall," not "may." Source: https://www.texasattorneygeneral.gov/sites/default/files/2018-06/PIA_handbook_2018_0.pdf 194; Gov’t Code § 552.267(a). That this is a matter of public interest is evident by the international media attention the school has received as a result of the first grader being raped in school by other first graders in a manner consistent with the visual images displayed in school books like Gender Queer: A Memoir by Maia Kobabe, Flamer by Mike Curato, and This Book Is Gay by Juno Dawson.

Where emails are involved, also provide the BCC as well as the CC and the TO. As you know, BCC is for the convenience of the sender, not for circumventing public information laws. If senders/recipients include distribution lists the school created, then please provide the document that lists the individual recipient email addresses in any distribution list; again, distribution lists are for the convenience of the sender, not for circumventing the law. Further, if school business has been conducted via the use of personal emails, then please provide those emails as well. Conducting school business on personal emails is not a valid means for circumventing TPIA.

Any document written or recorded is included as well. That includes voice mails, audio recordings, video recordings, transcripts or minutes of any public meetings. School board executive session recordings or minutes are not included in my request if they have not already been made public.

Written or recorded documents also include those made in any telephonic, electronic, or physical meeting with anyone acting on behalf of any library association such as the ALA. ALA trains librarians that written or recorded documents from ALA-provided trainings, meetings, conferences, etc., are ALA proprietary and may not be released publicly. That ALA claim is false. TPIA controls, not ALA. If a public employee attended anything at public expense, then anything learned/recorded at such an event or as a result thereof has been made public and is discoverable under TPIA no matter what ALA claims. The public has a right to know what business has been conducted at public expense, especially where the school goofed, allowing a first grader to force another into oral sex.

Be clear ALA top leadership uses personal email to direct librarians to destroy public documents precisely to prevent production under state sunshine laws like TPIA. Example from the private email of the current Director Deborah Caldwell-Stone, Esq., of the ALA Office for Intellectual Freedom: “Subject: URGENT - must delete all documents related to 17 Dec crisis communications workshop .… Remove these from your servers today and destroy hard copies. This is an attempt by two individuals to obtain privileged information …. we cannot allow anything from 17 Dec to be produced in response to FOIA.” See: “Librarians Ordered to Destroy Public Documents Revealing Homophobia at American Library Association and Crime in Libraries,” by Dan Kleinman, SafeLibraries®, 26 April 2018, https://safelibraries.blogspot.com/2018/04/librarians-ordered-to-destroy.html

To bring it home to Texas, TXLA advises librarians to use personal emails as well, precisely to attempt to evade Texas law, precisely to keep parents in the dark, precisely about the sexualization of their children in school, and here we are with first graders acting out something they’ve obviously seen somewhere—while librarians are trained to hide public records from the public:

Kleinman, Dan. “School Librarians Train to Violate FOIA Law to Keep Parents In the Dark About Sexualizing Children.” SafeLibraries® (blog), December 5, 2022. https://safelibraries.blogspot.com/2022/12/school-librarians-train-to-violate-foia.html.

Thank you very much for your attention to this matter.

NOTE: If anyone wishes to contact me privately/confidentially, perhaps to provide some of this documentation, use SafeLibraries@pm.me.

Sincerely,

Dan Kleinman



NOTE ADDED 19 MAY 2023:

Kleinman, Dan. “Click Here to Give Now to FOIA Fees for Plainview ISD Texas by Dan Kleinman.” GiveSendGo.com, May 17, 2023. http://www.givesendgo.com/HiddenInPlainview.