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 WASHINGTON )

)

COUNTY OF SKAGIT )

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

1. I am an adult citizen and a resident of Washington. I have previously submitted an affidavit in this matter urging my support of T.C.A. § 36-1-101, et seq. I was born in Tennessee, and given up for adoption in 1966. All records of my adoption have remained in Tennessee, the access of which are subject to Tennessee law. I am an adult citizen and a resident of Tennessee.

2. I have always felt a desire to know my birth parents, and have searched for many years to find them. In addition to my desire to find my parents because of these feelings of loss, I have medical reasons for wanting to find them. I am legally blind, and also had cervical cancer when I was 27. In addition, I have kidney problems that, I understand, could lead to a need for dialysis and possible transplant in the future. I am only 29 years old now, and may have children in the future. I feel it is vital to have information about my biological parents' medical history so that I know if there is a history of blindness or cancer in the family before I have children.

3. It is therefore extremely important that I find my birth parents as soon as possible. I am deeply concerned about this issue of my medical problems, and whether they are part of a pattern in my family.

4. I believe that, because of the facts stated above, any delay in the enforcement of T.C.A. § 36-1-101 et seq. could cause irreparable harm to him. If I were given access to my medical records, I would obtain them so that I would have this important medical information.

_________________________________ KARI TEGETHOFF

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

________________________________________

Notary Public

My Commission Expires: