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 TENNESSEE )

)

COUNTY OF DAVIDSON )

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

1. I am an adult citizen and a resident of Tennessee. I have previously submitted an affidavit in this matter urging my support of T.C.A. § 36-1-101, et seq. I had a female child in Chattanooga, Tennessee in 1963 whom I gave up for adoption at that time. All records of her 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 daughter, and have searched for many years to find her. In addition to my desire to find my daughter because of these feelings of loss, I have medical reasons for wanting to find her. I have peripheral neuropathy, which is a genetic condition. It is vital for me to find my daughter and share this medical information with her so that she knows of this predisposition to peripheral neuropathy.

3. Thus, it is extremely important that I find my daughter as soon as possible. Otherwise, she could be living with a predisposition to a disease of which she is not aware which could possibly be avoided or detected through lifestyle changes and preventative medical care.

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

_________________________________

BETTY SARVIS

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

________________________________________

Notary Public

My Commission Expires:

______________________