DECLARATION OF LISA HARDISTY SITHONNORATH
COMES NOW, Lisa Hardisty Sithonnorath and pursuant to 28 U.S.C. § 1746, declares under
penalty of perjury that the following is true and correct:
1. My name Lisa Hardisty Sithonnorath, I am a resident of Des Moines, Iowa. and I am over
18 years old. I have personal knowledge of the facts as stated herein.
2. 1 am the mother of two children who attend Jefferson Elementary School in the Des Moines
Public Schools.
3. J.S. is seven years old and is enrolled in the second grade.
4. A.S. is five years old and is enrolled in kindergarten.
5. Because my children are under the age of twelve, they are not eligible to receive any of the
currently authorized COVID-19 vaccines.
6. A.S. is diagnosed with Down syndrome, hypothyroidism and has a previous history of viral
induced asthma.
7. The CDC has identified these conditions as risk factors for severe illness from COVID-19.
8. A.S. has had an assistant who is assigned to help her with medical and cognitive issues
from her Down syndrome.
9. As a pediatric doctor myself, I am aware of the risks of complications from COVID-19 for
my child with Down syndrome.
10. A.S.'s treating doctor has also informed me that my child is at risk for severe complications
if she contracts a COVID-19 infection. According to her doctors, to decrease her risk.
everyone around her should observe strict COVID-19 safety protocols and wear a mask
indoors. (Sce Attached Exhibit A).
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11. Because of A.S. 's medical and cognitive issues, she will mimic behavior and cannot follow
instructions easily.
It is much more difficult for her to adhere to current mitigation
slrategies, such as wearing a mask, handwashing independently, or social distancing. so it
is even more important that others wear a mask and follow CDC guidelines around her.
12. Last year A.S. was enrolled in the remote option and I witnessed serious negative
consequences to the point that I had to hire an assistant who would come home and work
with A.S. throughout the day for individualized instruction. This person is no longer
available to assist us with A.S.," remote learning, and it is difficult to find someone who
could help with all of A.S. needs.
13. A.S. could not access education through virtual instruction because children with Down
syndrome tend to be visual and hands on rather than verbal learners and have difficulty
with focusing for long periods of time, and unfortunately, visual instruction is near
impossible to accommodate for a student with Down syndrome in a remote setting. A.S.
has regressed in several areas, even with significant parental involvement in both
curriculum development and dedicated learning time.
14. A.S. also experienced significant expressive communication regression since she did not
have everyday access to her peers at school.
15. This year Des Moines Public Schools is offering an online program through Edgenuity.
This online program is pre-recorded and self-taught, and does not provide the necessary
supports, services, and accommodations, including direct instruction for child with
disabilities.
16. Because of A.S.'s individualized needs, this fall we believe it important to send our
children back to school in person.
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17.1 am very anxious about sending my children to school for in person instruetion and the
thought that they might contract COVID-19. especially with A.S.'s medical history
18. My son. J.S. has also been anxious about getting COVID-19 at school and exposing others
in our household.
19. We also have a medically fragile family. I have asthma, which puts me at risk for severe
illness from COVID-19 ifour children were to bring it home from their sehool. My husband
is a former smoker which also places him in the high-risk category
20.I believe that if everyone was wearing a mask and the school was following the guidance
and recommendations from the CDC, my children would be safe in school.
21. My child is having to take greater risks - and unnecessary risks - to get her education
than other students. I think this unfair.
22. I am seeking to have HF847 blocked so that my school will be able to require universal
masking as necessary to meet its obligations to my child.
I swear under the penalty of perjury under the laws of the United States that the foregoing is
true and correct to the best of my knowledge.
Dated this day of September 2021., at Des Moines.wa,
aHdsSehomorath
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