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 HAWKINS )

I, DEBBIE COLLINS, 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 Nashville, Tennessee in 1968 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 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 am a blind woman with a genetic allergy to a kidney dye called Optiray. Injection of this dye into a person with this allergy can cause severe shock to the system. My physician has informed me that this allergy is hereditary in nature.

3. I also have heart problems that are caused by genetic high blood pressure. My brother had a heart attack when he was 27. Though he is still living, and is in his 40's, his condition must be controlled with medication.

4. It is vital to find my daughter and share this medical information with her so that she can avoid Optiray in case she has a medical condition causing her to need kidney dye. In addition, I would hope that she could possibly avoid heart problems and high blood pressure for herself and any children she may have.

5. Thus, it is extremely important that I find my daughter as soon as possible. Otherwise, she could be living with an allergy of which she is not aware, and thus, would not know to avoid such a substance in receiving medical treatment. In addition, she could have a predisposition to heart disease and high blood pressure which could possibly be avoided or detected through lifestyle changes and preventative medical care.

6. 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 daughter. If I were given access to her adoption records, I would immediately inform her of these health risks unique to my family.

_________________________________

DEBBIE COLLINS

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

________________________________________

Notary Public

My Commission Expires: