I, being sworn on oath state that:

1. I am the petitioner of this action. I am a professor of psychiatry at the University of Minnesota and I engage in research on drug abuse funded by the Federal government which involves the use of animals. This affidavit is given in support of my petition under Minnesota Statute 609.748.

2. Pursuant to Minn. Stat. & Sect; 609. subd. 1, the above respondents have committed the following acts of harassment (the most recent incidents being listed first) by engaging in targeted residential picketing at my home and committing repeated, intrusive and unwanted acts, words and gestures intended to adversely affect the safety, security and privacy of me and my family:

a. On October 31, 1996, 6-8 animal rights protesters knocked on our door, which was answered by my 17 year old daughter. The protesters distributed fliers attached as exhibits A and B which identified their involved organizations as the Animal Liberation Front (A.L.F.) and the Student Organization for Animal Rights (SOAR). They carried signs protesting my research activities. One of their signs is attached as exhibit C, which is in the form of a tombstone and states: "You will never R.I.P. Marilyn the Vivisector". The protesters shouted at my daughter repeatedly saying that your mother kills animals. My daughter called me and I came to the door to tell the protesters to leave. One protester tried to take a photo of me. As I turned away and walked back into the interior of my home, the protesters chanted, "Marilyn, come here, we want to talk to you; stop killing animals". My husband then came to the door to tell the protesters to leave. They asked him if he enjoys torturing animals [Mr. Santi is also a vivisector!] He responded by asking one of the male protesters why he was covering his face with a black cloth. The protester said because he was a member of the A.L.F.. [The person was dressed as an A.L.F. activist for Halloween, and stated so, he did not say he was a member of the A.L.F. -ed.] Then another male in the crowd said something about burning the house down. My husband said, "excuse me, what did you say?" The protester stated that the pumpkins were smoking and if we weren't careful the pumpkins might burn the house down. We considered this a threat and felt very intimidated and harassed by the actions of the protesters. [One of their pumpkins was actually on fire, and the warning was sincere -ed.] In addition, they disrupted our Halloween celebration by interfering with the trick or treat activities of the neighborhood children. We called the police, who arrived just as the protesters were driving away form our house in two cars. The police stopped the vehicles within a block of our house for driving the wrong way on a one-way street. They issued a traffic citation and identified some of the protesters. The police report is attached as exhibit D.

b. On October 8, 1996 at approximately 5:30 p.m., my family returned home from one of my children's extracurricular activities. Several protesters were standing in our driveway caring large signs about 2 by 3 feet and a painted sheet/sign protesting my research activities. There was a large group of about ten neighborhood children in our yard ranging in age from 3 to 17. My neighbor across the street had called the police while we were away to complain that the protesters were harassing the children, making comments such as "your neighbor kills animals". The protesters also had distributed flyers to the children, attached as exhibit B, which identified their organization as SOAR. The police arrived at my home approximately the same time we did and identified the protesters. A copy of the police report is attached as exhibit E.

c. Earlier in the day on October 8, 1996, at about 8 a.m., there were 7 to 9 protesters standing at the foot of our driveway carrying large signs (about 2' by 3') and a painted sheet/sign protesting my research activities. They rang our doorbell but we did not answer the door. We called the police because we needed to leave the house to take my youngest child to school and go to work ourselves, but we did not wish to drive through the protesters blocking our driveway. The protesters left flyers at our house identifying their organization as Student Organization for Animal Rights. A copy of the flyer is attached as exhibit B. Once the police arrived, they informed the protesters that their actions were violating a Mahtomedi City ordinance and the protesters dispersed. A copy of the ordinance is attached as exhibit G. The actions of the protesters delayed our departure from home, causing me to be late for a meeting at work.

d. On the first day of school at the University of Minnesota, September 26, 1996, about 5 animal rights protesters came to my laboratory in Diehl Hall. They carried a video camera and attempted to record activities in the laboratory. We were forced to lock the doors of the laboratory, computer room, and two animal rooms and shut down our research activities until the protesters left. They dispersed after being informed that the police had been called. I believe the protesters were associated with the Student Organization for Animal Rights, which earlier that day had sponsored a protest in front of the new Basic Science Building on the University campus. SOAR distributed flyers at that protest, attached as exhibit B, and carried large signs protesting animal research and identifying me as "vivisector of the month".

e. That same day on September 26, 1996, I received a telephone call in the afternoon from a young woman who did not identify herself. She said she did not like what I was doing to my animals and stated, "how would you like it if you were killed like you are killing your research animals". She asked whether our family had a pet and when I indicated that we have a dog, she made another statement to the effect, "how would you like it if you and your dog were killed like you are killing your research animals". Because this incident occurred on the same day as the protest sponsored by SOAR, and the woman sounded like a young person, I believe she was affiliated with SOAR.

3. Based on this affidavit, I request that an ex parte temporary restraining order be issued granting the following relief: Respondents shall be prohibited from engaging in residential picketing within a 200 yard radius of petitioner's home and further shall be enjoined from any communication with petitioner, in person, over the telephone, via written correspondence or electronic mail.

Marilyn Carroll Santi -- November 4, 1996