You do realise that Allah is literally just the Arabic word for God. Even Christians in Arab speaking countries say Allah because that is just the word.
John Davis
JoinedPosts by John Davis
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Brussels Central station was evacuated Tuesday amid reports of an explosion and at least one man shot who shouted "Allahu Akbar,"
by freemindfade init looks like these attacks in europe are going from weekly, to daily, it literally gives me chills to think about traveling to europe with my family.
that is very unfortunate.
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Hidden Watchtower Database- And the Court Allows it
by John Davis incounty of san diego.
central.
judicial officer presiding: gregory w pollack.
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John Davis
Note Ps stand for Perpetrator Psyudenom it is a numbering system
THE COURT: How many were there, by the way,
how many Ps?
MR. STOREY: Do you know the number?
MR. MCKIM: I don't know offhand.
THE COURT: Roughly, though.
MR. STOREY: 775.
THE COURT: How many?
MR. STOREY: About 775, I think, Ps.
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Hidden Watchtower Database- And the Court Allows it
by John Davis incounty of san diego.
central.
judicial officer presiding: gregory w pollack.
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John Davis
SUPERIOR COURT OF CALIFORNIA,
COUNTY OF SAN DIEGO
CENTRAL
MINUTE ORDER
DATE: 01/06/2017 TIME: 10:00:00 AM
JUDICIAL OFFICER PRESIDING: Gregory W Pollack
CLERK: Terry Ray
REPORTER/ERM: Lorena Barron, CSR#12058, 619-233-2030
BAILIFF/COURT ATTENDANT: L. VVilks
DEPT: C-71
CASE NO: 37-2012-00099849-CU-PO-CTL CASE INIT.DATE: 06/29/2012
CASE TITLE: Lopez vs. Doe 1 Linda Vista Church [IMAGED]
CASE CATEGORY: Civil - Unlimited CASE TYPE: PI/PD/WD - Other
EVENT TYPE: Motion Hearing (Civil)
MOVING PARTY: Watchtower Bible and Tract Society of New York Inc
CAUSAL DOCUMENT/DATE FILED: Motion for Protective Order, 12/13/2016
APPEARANCES
Devin M Storey, counsel, present for Respondent on Appeal,Plaintiff(s).
Francis J McNamara, counsel, present for Defendant(s).
Dean A. Olson, specially appearing for counsel Beth A Kahn, present for
Defendant,Appellant,Plaintiff(s).
Irwin M. Zalkin, counsel, present for Plaintiff(s).
The Court orally advises the parties of its tentative ruling, after which oral argument is conducted. Upon
completion of oral argument, the court makes the below ruling:
1NTRODUCTION.
The issues before the court are the following:
1. The nature and extent of any protective order to govern defendant's production of documents
responsive to item request numbers 5 and 12 in plaintiffs notice of deposition of defendant's person
most qualified; and
2. Whether the production of documents (post-March 2001) now in the physical possession of non-party
CCJW can be compelled through a discovery request on Watchtower, or must plaintiff subpoena the
records directly from CCJW.
PROTECTIVE ORDER
DATE: 01/06/2017 MINUTE ORDER Page 1
DEPT: C-71 Calendar No. 17
CASE TITLE: Lopez vs. Doe 1 unda Vista Church CASE NO: ;S(-2012-00099849-CU-PO-CTL
[IMAGED]
The court has carefully considered all briefings submitted by both sides. In addition, the court
has carefully reviewed the recently published appellatp opinion in this case, Lopez v. Watchtower Bible &
Tract Society of New York, Inc. (2016) 246 Cal.App.4tn 566.
Both sides agree that the production of the subject documents can be properly subject to a
protective order. The dispute is over the precise nature and extent of the "third party" redactions.
The court does believe that a protective order is appropriate. Further, the court does not believe
that Judge Lewis' contemplated redaction of third-party identifying information, upheld by the appellate
court, was limited, or even ought to be limited, to alleged victims. The court adopts Watchtower's
proposed protective order subject to the below-described modifications:
In lieu of paragraph 1 proposed by Watchtower, the following shall constitute paragraph 1:
Defendant Watchtower may redact the following from documents responsive to request number
12, which includes documents responsive to request number 5, in plaintiff Jose Lopez's notice of
deposition of defendant Watchtower's person most qualified ("responsive documents'):
I. All names, addresses, email addresses, telephone numbers, Social Security numbers and
other identifying information of any alleged victim of childhood sexual abuse. Individuals subject to
these redactions shall be referred to by pseudonym, e.g., V1, V2, etc.
2. All names, addresses, email addresses, telephone numbers, Social Security numbers and
other identifying information of any alleged childhood sexual abuse perpetrators who have not
admitted or conceded having committed childhood sexual abuse, have not been reported to a police
agency by Watchtower or a Jehovah's Witness congregation member for committing childhood sexual
abuse, or have not been criminally charged or prosecuted for having committed childhood sexual abuse.
Individuals subject to these redactions shall be referred to by pseudonyms, e.g., P1, P2, etc.
3. Identities of any congregation, except those congregations where membership includes one
or more alleged perpetrators who have admitted or conceded to having committed childhood sexual
abuse, have been reported to a police agency by Watchtower or a Jehovah's Witness congregation
member for having committed childhood abuse, or have been criminally charged or prosecuted for having
committed childhood sexual abuse. Unless coming within one of these exceptions for which redaction is
not permissible, congregations shall be referred to by pseudonyms, e.g., Cl, C2, etc.
4. The names, addresses, email addresses, telephone numbers, Social Security numbers and
other identifying information of any non-victim/non-perpetrator witnesses. Individuals subject to these
redactions shall be referred to by pseudonym, e.g., W1, W2, etc.
The last sentence of paragraph 11 in the proposed protective order of Watchtower is stricken
("Because documents responsive to request no. 12 are responsive to request no. 5, no further response
to request no. 5 is required.").
CCJW DOCUMENTS
CCP §2031.010 requires production of evidence in a party's "possession, custody, or control."
DATE: 01/06/2017 MINUTE ORDER Page 2
DEPT: C-71 Calendar No. 17
CASE TITLE: Lopez vs. Doe 1 Linda Vista Church CASE NO: 37-2012-00099849-CU-PO-CIL
[IMAGED]
That two entities may be related or in some fashion affiliated does not necessarily mean that a document
request served upon one obligates it to produce documents in the possession, custody, or control of
another. For example, in People ex. reL Lockyer v. Superior Court (2004) 122 Cal.App.4t 11 1060,
1076-1077, the court held, in an action by the State of California against vision companies for violation of
statutes governing the practice of optometry, that the vision companies' request for documents served
on the State of California did not require production of documents from any state agency.
CCJW, which evidently has the post-March 2001 documents, is not a party to this action.
Watchtower does not have possession, custody or control over non-party CCJWs documents and
cannot produce them. Watchtower does not have access to or control of the records of the United
States Branch Service Department post-March 2001. Post-March 2001, Watchtower ceased working
with the Service Department, with CCJW taking over that function. CCJW and Watchtower are
separate corporations, each with its own separate and distinct Board of Directors and bank accounts.
Neither has authority over the other. Presumably, they could sue each other.
Should plaintiff wish to obtain documents in the possession, custody, or control of non-party CCJW,
plaintiff will need to proceed by way of a subpoena upon this non-party. However, if post-March 2011
documents were, in fact, sent to Watchtower, of which it now has possession, custody or control, such
documents need to be produced by Watchtower, subject to the redactions specified in section II, supra.
IV,
FUTURE DATES
- March 3, 2017 at 10:00 a.m. — Hearing on plaintiffs motion for sanctions
- April 10, 2017— Deadline to produce category 12 documents
- April 14, 20917 at 10:00 a.m. — Hearing on defendant's motion for summary judgment
- June 15, 2017— Deadline to produce category 5 documents
(1,144k-
Judge Gregory W Pollack
Below is the proposed order
SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF SAN DIEGO
Case No. 37-2012-00099849-CU-PO-CTL
(PROPOSED' ORDER GRANTING
MOTION OF DEFENDANT WATCHTOWER
BIBLE AND TRACT SOCIETY OF NEW
YORK, INC. FOR PROTECTIVE ORDER
Assigned to: Hon. Gregory W. Pollack
Date: January 6, 2017
Time: 10:00 a.m.
Dept.: 71
Trial Date: None
JOSE LOPEZ, an Individual,
Plaintiff,
V.
DOE 1, LINDA VISTA CHURCH; DOE 2,
SUPERVISORY ORGANIZATION; DOE 3,
PERPETRATOR; and DOES 4 through 100,
inclusive,
Defendants
[PROPOSED] ORDER GRANTING MOTION OF DEFENDANT WATCHTOWER BIBLE AND TRACT SOCIETY OF
NEW YORK, INC. FOR PROTECTIVE ORDER
The Motion of Defendant Watchtower Bible and Tract Society of New York, Inc. for a
Protective Order came on regularly for hearing on January 6, 2017 1 at 10:00 a.m., in Department 71
of the above-entitled Court, the Honorable Gregory W. Pollack presiding. Appearances were stated
on the record at the time of the hearing. After consideration of the papers and evidence submitted and
argument of counsel, and good cause appearing therefore, the Motion is GRANTED. The Court
orders as follows:
I. Defendant Watchtower may redact the following from documents responsive to
requests no.12, which includes documents responsive to request no. 5, in Plaintiff Jose
Lopez's notice of deposition of Defendant Watchtower's person most qualified
("Responsive Documents"): information that identifies alleged victims of childhood
sexual abuse, including, but not limited to names, addresses, e-mail addresses,
telephone numbers and social security numbers of third-parties, regardless of whether
such third-party is an entity or natural person.
2. Responsive Documents shall be designated and marked "CONFIDENTIAL" by
Defendant Watchtower in the header and the footer in a manner that will not obscure
the textual content of the document.
3. The Responsive Documents, including any and all documents and information
contained therein, shall be maintained in confidence by Plaintiff's attorneys and shall
be used for the sole and exclusive purpose of Plaintiff's attorneys' preparation for
depositions, as exhibits to motions and/or oppositions and replies to motions, and at
trial of this case. Plaintiff's counsel may inform the Court in other litigation against
Defendant Watchtower that Defendant Watchtower has produced the Responsive
Documents in this case but may not reveal, refer to or characterize the content of the
documents.
4. The Responsive Documents shall not be disclosed or copied in any form to any person
or entity (except to the extent reasonably necessary to Plaintiff's attorneys' regularly
employed staff and contracted personnel subject to the provisions of paragraph 9) for
any other purpose other than those set forth in paragraphs 5, 6 and 7 below.
[PROPOSED) ORDER GRANTING MOTION OF DEFENDANT WATCHTOWER BIBLE AND TRACT SOCIETY
OF NEW YORK, INC. FOR PROTECTIVE ORDER
5. Plaintiffs attorneys may scan, OCR, and/or store digital images of the Responsive
Documents on Plaintiffs attorneys' password-protected in-house and Cloud-based
servers ("the Servers"). The digitized versions of the Responsive Documents may be
downloaded from the Servers to individual desktop or laptop computers owned, or
temporarily leased, by Plaintiff's attorneys' law firm as needed to database, analyze,
code, abstract, prepare exhibits, or otherwise manipulate the data contained within the
Responsive Documents. Plaintiff's attorneys may provide a hard copy version and/or
encrypted electronic copy of the Responsive Documents, or any data analyses or
exhibits created therefrom, to their experts or consultants and may use or transmit
Responsive Documents in an encrypted electronic format for purposes solely related to
this litigation. Plaintiff's experts and/or consultants may similarly store digital images
of the Responsive Documents on their own in-house, Cloud-based, or other servers,
and download such digitized images to desktop or laptop computers owned or leased
by the expert and/or consultant, as reasonably necessary to complete the work
commissioned by Plaintiff in this case.
6. If Plaintiff submits any Responsive Documents to the Court, such Responsive
Documents shall be lodged "CONDITIONALLY UNDER SEAL" as allowed by Rule
2.551(b)(3)(A) of the California Rules of Court. Thereafter, all parties reserve all
rights granted by Rules 2.550-2.551 of the California Rules of Court to file or oppose a
motion to seal or unseal the Responsive Documents.
7. Any Responsive Documents presented at trial shall be lodged "CONDITIONALLY
UNDER SEAL" as allowed by Rule 2.551(b)(3)(A) of the California Rules of Court.
Thereafter, all parties reserve all rights granted by Rules 2.550-2.551 of the California
Rules of Court to file or oppose a motion to seal or unseal the Responsive Documents.
8 Plaintiff's attorneys of record and any other person or entity provided with Responsive
Documents pursuant to paragraphs 3, 4 and 5 above shall return the Responsive
Documents to counsel for Defendant Watchtower, and shall permanently delete the
Responsive Documents from any computer or electronic storage device, upon the later
[PROPOSED] ORDER GRANTING MOTION OF DEFENDANT WATCHTOWER BIBLE AND TRACT SOCIETY
OF NEW YORK, INC. FOR PROTECTIVE ORDER
of:
(a) Thirty (30) calendar days following a written demand for return of the
Responsive Documents. Such written demand may be made at any time following
the conclusion of this case, including any appellate proceedings. For purposes of
this paragraph, notice to Plaintiff's attorneys shall constitute notice to all persons
or entities to whom the Responsive Documents were transmitted; or
(b) Thirty (30) calendar days following the denial of a motion to dissolve or
modify this Protective Order and the exhaustion of any appellate procedures
thereafter. If, however, a motion to dissolve or modify the Protective Order is
granted in such a manner as conflicts in whole or in part with this paragraph, the
subsequent order controls. Any work product referring to Responsive Documents
shall be subject to this Protective Order.
9. Any person, other than the Court or its officers, to whom Responsive Documents are
disclosed or shown pursuant to paragraphs 4 or 5 shall be informed, prior to disclosure
or showing, of the nature and scope of this Protective Order, and of his or her
obligation to keep the Responsive Documents in confidence, and shall sign a statement
and certification agreeing to comply with the terms of this Protective Order.
10. This Court shall have exclusive jurisdiction to hear all disputes, including motions for
sanctions, pertaining to or arising out of violations of this Protective Order and all
parties and their attorneys agree to submit to the jurisdiction of the Court with respect
to any such dispute. This Protective Order shall continue to be binding after the
conclusion of this case except that a party may seek the written permission of
Defendant Watchtower or further order of the Court with respect to dissolution or
modification of this Protective Order.
[PROPOSED] ORDER GRANTING MOTION OF DEFENDANT WATCHTOWER BIBLE AND TRACT SOCIETY
OF NEW YORK, INC. FOR PROTECTIVE ORDER
Dated:
•
II. Defendant Watchtower's compliance with document requests no. 12 in Jose Lopez's
deposition notice of Defendant Watchtower's person most qualified does not require
Defendant Watchtower to produce documents that post-date March 2001. Because
documents responsive to request no. 12 are responsive to request no. 5, no further
response to request no. 5 is required.
IT IS SO ORDERED.
Hon. Gregory W. Pollack
Judge of the Superior Court
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What "Rules" Did The Elders In Your KH Make?
by minimus insome congregations were known as liberal and others were considered very conservative.
back in the 1970s a nearby congregation made all speakers who gave public talks a white shirt to wear.
if a speaker came in wearing anything but white they were brought into the library and were given a white shirt!
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John Davis
Actually, Level the playing field, the issue over copyright is not a CO pet peeve thing. That came from the Branch, there have been reminders that copyrighted material cannot be used without the permission of the copyright owner even if the owner is the Organization. the use of the lyrics, the logo or other items cannot be used without the express permission of the branch or the corporation that owns the copyright.
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Who is benefiting from Watchtower Corporation financially
by John Davis inwho do you believe is financially benefiting from watchtower business dealings.
i know about the gold apple watch, but that is only a small percentage of the billions that they have.
so who do you think is keeping all of this money.
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John Davis
oh it is one of those people. Got it.
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The Alliances for Constitutional Sex Offenders Laws
by John Davis ini was listening to the news today and heard of this organization.
it advocates for the removal of sex offenders registries or at least the reduction of its use and who has to register for it.
just one example of its work is to advocate for what the la district attorney's office is doing by working with sex offenders to get their names off the registry.
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John Davis
I am sorry if I made it sound like you were accusing me of passing judgement or anything like that. I just wanted to clarify it. I completely agree with you, that there has to be a better system. Child abuse is a horrific crime, and people who have committed it may want to engage in it again, but that doesn't mean that a one size fits all punishment system. Even just the accusation of child abuse can ruin someone's life even if it is not true. It is a sad thing that people hurt children but those people are still human and need to be punished for their hurting someone else but they still need to be treated like humans.
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The Alliances for Constitutional Sex Offenders Laws
by John Davis ini was listening to the news today and heard of this organization.
it advocates for the removal of sex offenders registries or at least the reduction of its use and who has to register for it.
just one example of its work is to advocate for what the la district attorney's office is doing by working with sex offenders to get their names off the registry.
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John Davis
I am in no was trying to pass judgement on this organisation. I know that this has been debated for years with regards to the state of limitations for both criminal and civil cases, the use of registries, limits on the where and how people can live and work, and even the use parole or probation. I just never knew that there was an organised effort to look into it. Even in Canada, the Liberal government is trying to fend off attacks the Conservative opposition, when they call the liberals weak and not wanting to protect children because the PM isn't sure if he wants to push through a national sex offenders registry.
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Who is benefiting from Watchtower Corporation financially
by John Davis inwho do you believe is financially benefiting from watchtower business dealings.
i know about the gold apple watch, but that is only a small percentage of the billions that they have.
so who do you think is keeping all of this money.
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John Davis
who is that Alfred?
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The Alliances for Constitutional Sex Offenders Laws
by John Davis ini was listening to the news today and heard of this organization.
it advocates for the removal of sex offenders registries or at least the reduction of its use and who has to register for it.
just one example of its work is to advocate for what the la district attorney's office is doing by working with sex offenders to get their names off the registry.
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John Davis
I was listening to the news today and heard of this organization. It advocates for the removal of sex offenders registries or at least the reduction of its use and who has to register for it. Just one example of its work is to advocate for what the LA District Attorney's office is doing by working with sex offenders to get their names off the registry. I wanted to get your opinion on this organization and organizations like it.
About Us
Our Mission Statement
The Alliance for Constitutional Sex Offense Laws (ACSOL) is dedicated to protecting the Constitution by restoring the civil rights of registrants and their families. In order to achieve that objective, ACSOL will educate and litigate as well as support or oppose legislation.
We Believe
· No sexual abuse is ever acceptable.
· Sex offense laws and policies should be based on sound research and common sense, not fear, panic or paranoia.
· Current laws and policies that paint all sex offenders with one broad brush are counter- productive, wasteful, and cause needless harm.
· Each offense must be judged on its own merits with a punishment that fits the crime and does not waste taxpayer dollars.
· The public sex offender registry and residency restriction laws do not protect children but instead ostracize and dehumanize individuals and their families.
· Money spent on purely punitive measures would be better used for prevention, healing, and rehabilitation.
We do not now nor have we ever had a relationship with the North American Man Boy Love Association (NAMBLA) -
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US Supreme Court strikes down NC sex offender social media ban
by John Davis inus supreme court strikes down nc sex offender social media ban.
raleigh .
the u.s. supreme court has overturned a north carolina law prohibiting registered sex offenders from using facebook or other social networking sites that minors can join.. the challenge was brought by lester gerard parkingham jr., a registered sex offender in north carolina, who faced additional charges after durham police found a facebook page he created under an assumed name.. the case raised questions about whether such laws prohibit sex offenders from participating in web-based forums, which have become virtual town squares, as they re-enter society.. “this case is one of the first this court has taken to address the relationship between the first amendment and the modern internet,” justice anthony kennedy wrote in the majority opinion.
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John Davis
US Supreme Court strikes down NC sex offender social media ban
RALEIGH
The U.S. Supreme Court has overturned a North Carolina law prohibiting registered sex offenders from using Facebook or other social networking sites that minors can join.
The challenge was brought by Lester Gerard Parkingham Jr., a registered sex offender in North Carolina, who faced additional charges after Durham police found a Facebook page he created under an assumed name.
The case raised questions about whether such laws prohibit sex offenders from participating in web-based forums, which have become virtual town squares, as they re-enter society.
“This case is one of the first this Court has taken to address the relationship between the First Amendment and the modern Internet,” Justice Anthony Kennedy wrote in the majority opinion. “As a result, the Court must exercise extreme caution before suggesting that the First Amendment provides scant protection for access to vast networks in that medium.”
The justices sent the case back to the state Supreme Court to reverse its earlier decision.
“In sum, to foreclose access to social media altogether is to prevent the user from engaging in the legitimate exercise of First Amendment rights,” Kennedy’s ruling states. “It is unsettling to suggest that only a limited set of websites can be used even by persons who have completed their sentences. Even convicted criminals – and in some instances especially convicted criminals – might receive legitimate benefits from these means for access to the world of ideas, in particular if they seek to reform and to pursue lawful and rewarding lives.”
The state Court of Appeals ruled the law was too broad and restricted Parkingham’s free speech. The N.C. Supreme Court overturned that ruling, saying in a 4-2 decision that the “incidental burden imposed” upon convicted sex offenders “is not greater than necessary to further the governmental interest of protecting children from registered sex offenders.”
In North Carolina, where 14,268 people are entered in the N.C. Sex Offender and Public Protection Registry database, civil liberty organizations have paid close attention to Packingham’s case.
The 2008 restriction was part of a legislative package that Roy Cooper, the state Attorney General at the time, advocated for many years. Cooper was elected governor last fall.
Packingham argued that prohibiting him from using social media sites is a violation of his rights to “free speech, expression, association, assembly and the press under the First and Fourteenth Amendments.”
Packingham was convicted in 2002 of taking indecent liberties with a child.
In 2010, Durham police began investigating Myspace and Facebook profiles to enforce the law. Investigators said they found a picture of Packingham on Facebook and determined he created the profile page, according to court documents. Packingham was convicted in May 2012 and received a suspended sentence and probation.
The 2008 legislative package came about at a time that state attorneys general across the nation were raising concerns about social media sites such as Facebook and Myspace, hoping to protect users from sexual predators using the networks.
Though many of those sites now are more widely used by adults than children, the North Carolina law makes it illegal for a registered sex offender to access a website where he or she knows minors have personal web pages.
“Even with these assumptions about the scope of the law and the State’s interest, the statute here enacts a prohibition unprecedented in the scope of First Amendment speech it burdens,” Kennedy’s ruling states. “Social media allows users to gain access to information and communicate with one another about it on any subject that might come to mind.”
Glenn Gerding, the Chapel Hill attorney who represented Packingham, argued several years ago that the law as written could make it difficult for a registered offender to engage in routine Internet activity, such as a Google search.
The law defines a “commercial social networking website” as one that derives revenue from membership fees or advertising, facilitates social introductions and allows users to create pages to post information.
Though the law makes exceptions for websites that provide narrow services such as email, the three-judge N.C. appeals court panel that ruled in the case said it could prohibit a registered sex offender from accessing Google, Amazon or even a cooking TV channel website because the sites provide secondary social networking forums.
North Carolina’s sex offender laws require people convicted since 1996 of sexually violent offenses and specific crimes against children to register with the sheriff’s office in the counties where they live. Those on the registry may not live close to schools or daycares. They are barred from working with minors and visiting certain places where children are likely to be present.
In 2013, Gerding said one of his clients had not been able to attend his child’s T-ball games because of the restrictions. The client’s wife had planned to go to the game and use Skype so her husband could watch without being on the premises, but a sheriff told him that would violate the 2008 law.