Declaration of Melissa Hadden — The Arc of Iowa v. Reynolds (Dkt. 3.4)

Summary

A Declaration of Melissa Hadden, Document 3-4 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 is the mother of a three-year-old in preschool in the Council Bluffs School District who has serious medical conditions and is too young for the currently authorized COVID-19 vaccines. She states that the child's doctor recommended not attending school in person, but the district's 100% remote option is not available for preschool students. She states that at a parents' night on August 19, 2021 and a back-to-school night on August 20 no teachers, staff, or students were wearing 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 3-4 Filed 09/03/21 Page 1 of 2

DECLARATION OF MELISSA

COMES NOW, Melissa Hadden and pursuant to 28 U.S.C. § 1746, declares under

penalty of perjury that the following is true and correct:

1.

My name is Melissa Hadden, and I am over 18 years old. I have personal knowledge of
the facts as stated herein.

I am the mother of V.M.H., who is 3 years old and is in preschool and has been
diagnosed with heart disease, periventricular leukomalacia, autism, cerebral palsy,
cortical digital impairments, and optic nerve hypoplasia. My child is at risk of severe
illness should she contract COVID-19.

Because my child is under the age of 12, my child not eligible to receive any of the
currently authorized Covid-19 vaccines.

My child attends school at the Council Bluffs School District. We live in Pottawattamie
County, Iowa.

The doctor for my child has recommended for medical reasons that it would be best for
her not to attend school in person; if services can be offered one-on-one or remotely, that
would be reasonable. See Exhibit A (Letter from Doctor Jamie Drake).

The Council Bluffs School District for the upcoming school year is offering a 100%
remote learning option; however, the online option is not available for preschool students.
My child, V.M.H., went to preschool in-person last year because masks were required at
Case 4:21-cv-00264-RP-HCA Document 3-4 Filed 09/03/21 Page 2 of 2

none of my child’s teachers wore masks and very few children in the school were
wearing masks.

9. Atthe parents’ night on August 19, 2021, and the back-to-school night on August 20", no
teachers, staff, or students were wearing masks.

10. Since the start of school, no teachers, staff members, or students are wearing masks at the
school. The students are not socially distanced in the classroom.

11. For this school year, I have made the difficult decision to send my child to in-person
school. The school district is not offering online learning for children in preschool. I
work in-person part-time. Homeschooling is not an option for our family.

12. I am diabetic, which makes me more susceptible to Covid-19 if my child were to become
infected at school and bring it home.

13. As a result of lowa’s law, my child is having to take unnecessary risks to her health in
order to get an education.

14. 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 penalty of perjury under the laws of the United States that the foregoing is
true and correct to the best of my knowledge.

Dates this Sa of September 2021, at Council Bluffs, Iowa.


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