Exhibit E: Affidavit of Jill Shudak (Iowa District Court for Polk County) — The Arc of Iowa v. Reynolds (Dkt. 28.5)

Summary

Exhibit E, an Affidavit of Jill Shudak filed as Document 28-5 on September 10, 2021 in Case 4:21-cv-00264-RP-SBJ. The affidavit carries the caption of a case in the Iowa District Court in and for Polk County, Case No. EQCE086981, against the Iowa Department of Education, the State of Iowa and other defendants. Jill Shudak states she is a member of the Council Bluffs Community School District School Board. She states that under Iowa Code Section 280.31 she is not able to issue a facial covering mask mandate for students and school personnel, and that she would prefer to be able to consider one. She states that the local school board would be better positioned to enact appropriate mask measures than a state law blocking a mandate.

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Case 4:21-cv-00264-RP-SBJ Document 28-5 Filed 09/10/21 Page 1 of 2

EXHIBIT E
IN THE IOWA DISTRICT COURT IN AND FOR POLK COUNTY
FRANCES MIERZWA PARR, individually,
as mother and next friend of M.C.P. and CASE NO. EQCE086981
B.E.P,
Plaintiffs,
V. AFFIDAVIT OF JILL SHUDAK

IOWA DEPARTMENT OF EDUCATION;
ANN LEBO, in her Official Capacity as
the Director of the lowa Department of
Education; THE STATE OF IOWA;
KIMBERLY REYNOLDS, in Her Official
Capacity as the Governor of the State of
lowa; IOWA DEPARTMENT OF PUBLIC
HEATH; KELLY GARCIA, in Her Official
Capacity as the Director of the lowa
Department of Public Health.

Defendants.
STATE OF | Qu. )

| Jill Shudak state that | am a member of the Council Bluffs Community School

District School Board. | am aware that pursuant to lowa Code Section 280.31, that as a

member of the Council Bluffs Community School District, | am not able to issue a facial

covering/ mask mandate for students and school personnel in the Council Bluffs

Community Schools. As a member of the Council Bluffs Community School Board |

would prefer to be able to consider a facial covering mask mandate for our school

district. | believe that the local school board would be more aware of local developments

concerning COVID-19 and the Delta Variant and would be in a better position to enact

Exhibit
"6"
Case 4:21-cv-00264-RP-SBJ Document 28-5 Filed 09/10/21 Page 2 of 2

appropriate mask measures to protect our students than the a state law blocking a

mask mandate.

| have personal knowledge of the above and am competent to so testify.

4

JILL SHUDAK

Subscribed and sworn to before me by JILL SHUDAK this Ea day of
Se OL , 2021.

Calen Ely : A

My Commission Expires c

° September 10, 2022 Notary Public


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