Declaration of Erin Vercande — The Arc of Iowa v. Reynolds (Dkt. 3.6)

Summary

A Declaration of Erin Vercande, Document 3-6 filed 09/03/21 in Case 4:21-cv-00264-RP-HCA, made under 28 U.S.C. § 1746 under penalty of perjury. She states that she is a resident of Decorah, Iowa, a member of the Arc Iowa, and the mother of three children in the Decorah school district, all under twelve and not eligible for the currently authorized COVID-19 vaccines. She states that one child has serious medical conditions and is nonverbal, so it is more important that others wear a mask around him. She states that her requests to the principal and superintendent for the accommodations the school provided last year, including masked staff, were denied, so she pulled the child out of school.

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DECLARATION OF ERIN VERCANDE

COMES NOW. Erin Vercande and pursuant to 28 U.S.C. § 1746, declares under penalty of perjury
that the following is true and correct:
|. My name is Erin Vercande, I am a resident of Decorah, lowa, and I am over 18 years old
| have personal knowledge of the facts as stated herein.

> Tam the mother of three children, S.V., C.V., and R.V. who attend school in the Decorah

— ©

School District.

3 Tamamember of the Arc lowa.

4. S.V. is ten years old and should be enrolled in the fourth grade at Decorah Middle School.

5. CV. is seven years old and is enrolled in first grade at John Cline Elementary School.

6. R.V. is three years old and 1s enrolled in preschool at Little Farmers Pre-school.

7 Because my children are under the age twelve, they are not eligible to receive any of the

currently authorized COVID-19 vaccines.

g SV. has a brain injury, cerebral palsy, and a history of strokes and epilepsy.

Bethe COC has identified strokes and cerebrovascular diseases as risk factors for severe

‘IIness from COVID-19.

oughout the school day. (See Attached Exht

including transfers thr
at because of his underlying

11. S.V.’s treating doctors and specialists have informed me th
him should observe strict COVID-I9 safety protocols and wear a mask indoors
(See
Attached Exhibit B and C)

1? Because of S.V.’s medical and cognitive issues, and the fact that he is nonverbal, he cannot
follow instructions easily. It is much more difficult for him to adhere to current mitigation
strategies, such as wearing a mask, handwashing independently, or social distancing, so tt
is even more important that others wear a mask and follow CDC guidelines around him.

13. Last year we had our children enrolled in person because the school provided S.V. with the

necessary accommodations to remain safe, including that all staff were required to be

masked.

14.1 have had phone calls with the principal and superintendent to seek these same

accommodations for this school year, but my requests have been denied.

15.1 am faced with an impossible choice between my child’s safety and education. Because

the school is not providing necessary modifications, I have had to make the extremely

difficult decision to pull S.V. out of school to avoid sending him in person in an unmasked

environment, which would be a very high risk given his medical conditions, as well as

against the recommendations of his doctors and the CDC.

16. My husband and I are terrified of sending our children back to school, especially with all

of S.V.’s health complications. We have really struggled with the decision, but we do not

feel like we have any option.

ol was following the ouidance

17. I believe that if everyone was wearing a mask and the scho

| 1 would be safe in school.

that my school will be able to require universal

masking as necessary to meet its obligations to my child.
Case 4:21-cv-00264-RP-HCA Document 3-6 Filed 09/03/21

I swear under the penalty of perjury under the |

true and correct to the best of my knowledge,

Page 3 of 3 _


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