IN THE UNITED STATES DISTRICT COURT

FOR THE MIDDLE DISTRICT OF TENNESSEE

AT NASHVILLE

PROMISE DOE, KIMBERLY C. )

and RUSS C., and SMALL WORLD )

MINISTRIES, INC., )

)

Plaintiffs, )

)

v. ) No. 3-96-0599

) JUDGE NIXON

DONALD SUNDQUIST, Governor )

of the State of Tennessee, in his )

official capacity; CHARLES )

BURSON, Attorney General of the )

State of Tennessee, in his )

official capacity; and LINDA )

RUDOLPH, in her official capacity )

as the Commissioner of the )

Department of Human Services for )

the State of Tennessee, )

)

Defendants. )

AFFIDAVIT

STATE OF MISSOURI )

)

COUNTY OF WRIGHT )

I, BONNIE BLACKWELL, being first duly sworn according to law, do hereby depose and state as follows:

1. I am an adult citizen and a resident of Missouri. I have previously submitted an affidavit in this matter urging my support of T.C.A. § 36-1-101, et seq. I had a male child in Nashville, Tennessee in 1956 whom I gave up for adoption at that time. All records of his adoption have remained in Tennessee, the access of which are subject to Tennessee law.

2. I have always felt hurt over the loss of my son, and have searched for him. In addition to my desire to find my son because of these feelings of loss, I have medical reasons for wanting to find him. My family has a strong history of different types of cancer, including that of the lungs, colon and stomach. It is vital that I be able to share this medical information with my son so that he can possibly avoid these illnesses for himself and any children he may have.

3. Thus, it is extremely important that I find my son as soon as possible. Otherwise, he could be living with a disease of which he is not aware, or could develop such a disease, and thus, would not be seeking treatment or taking preventative measures.

4. I believe that, because this particular history of cancer in my family, any delay in the enforcement of T.C.A. § 36-1-101 et seq. could cause irreparable harm to my son. If I were given access to his adoption records, I would immediately inform him of these health risks unique to my family.

_________________________________

BONNIE BLACKWELL

Sworn to and subscribed before me this _____ day of August, 1996.

________________________________________

Notary Public

My Commission Expires: