Declaration of Lidija Geest — The Arc of Iowa v. Reynolds (Dkt. 3.12)

Summary

A Declaration of Lidija Geest, Document 3-12 filed September 3, 2021 in Case 4:21-cv-00264-RP-HCA, made under 28 U.S.C. § 1746 under penalty of perjury. She states that she lives in Davenport, Iowa and is the mother of a six-year-old first grader in the Davenport Community Schools District who is too young for the currently authorized COVID-19 vaccines and has asthma. She states that her request that the school nurse wear a mask when giving the child an inhaler was denied. She states that the district's remote option through Edgenuity is pre-recorded and self-taught, that last year's remote schooling harmed the child's mental health, and that few students wear masks. She states that she seeks to have HF847 blocked so her school can require universal masking.

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Case 4:21-cv-00264-RP-HCA Document 3-12 Filed 09/03/21 Page 1 of 2

DECLARATION OF LIDIJA GEEST

COMES NOW, Lidija Geest and pursuant to 28 U.S.C. § 1746, declares under penalty of perjury

that the following is true and correct:

to

6.

My name is Lidija Geest, I reside in Davenport, lowa and | am over 18 years old. I have
personal knowledge of the facts as stated herein.

I am the mother of K.G. who is six years old and attends first grade at Adams Elementary
in the Davenport Community Schools District.

Because my child is under the age of twelve, he is not eligible to receive any of the currently
authorized COVID-19 vaccines.

K.G. has asthma, which the CDC has identified as a risk factors for severe illness with
COVID-19.

K.G. has a PRN letter with the school for his inhaler. (See Attached Exhibit A). At times
the school nurse must administer the inhaler; however, | have knowledge that she does not
wear a mask. | requested that she be masked when administrating the inhaler, because K.G.
cannot be. This request was denied.

His doctor has informed me that my child is at risk for severe complications if he contracts
a COVID-19 infection. According to his doctor, to decrease his risk, he, and everyone
around him should observe strict COVID-19 safety protocols and wear a mask indoors.
(See Attached Exhibit B).

This year Davenport is offering a remote learning option through a third-party provider.
Edgenuity. This online program is pre-recorded and self-taught, and does not provide the

necessary supports, services and accommodations, including live teacher instruction. I do
Case 4:21-cv-00264-RP-HCA Document 3-12 Filed 09/03/21 Page 2 of 2

not believe this option provides sufficient support. or the necessary accommodations for
my child.

8. Last year K.G was remote, but his mental health suffered greatly, and this fall we have
made the difficult decision to send him back in person. I am in the horrible position of
deciding between my child’s physical safety and mental health.

9. Prior to the start of the school year, we sought an accommodation through the teacher to
have her wear a mask when at least she was working with K.G. on a one-on-one basis.

10. After his first week in person, I am even more concerned for K.G.’s health at school. He
has informed me that his teacher is not wearing a mask when interacting with him one-on-
one. Very few students are wearing masks in school. Furthermore, in gym class the
instructor even made K.G. take off his mask to run indoors.

11. I believe that if everyone was wearing a mask and the school was following the guidance
and recommendations from the CDC, my child would be safe in school.

12. 1 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 od day of September 2021, at Davenport, lowa.

bo


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