Darla Kaye Wynne
44 Walnut Street
Great Falls, SC 29055
(803) 482-6450
Fax: (803) 482-6475

IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF SOUTH CAROLINA
ROCK HILL DIVISION

DARLA KAYE WYNNE

Plaintiff,

vs.

Town of Great Falls, Henry
Starnes, Mayor; Joe V. Pendergrass,
Councilman; John Broom,
Councilman; Barbara Hilton,
Councilwoman; and Raymond H.
Baker, Councilman Civil Action No. 0:01-3409-19BC

Defendants
________________________________
Affidavit of Paul Dean Harris, Jr.
Personally appeared before me, Paul Dean Harris, Jr., who being first duly sworn hereby deposes and says:
1. Paul Dean Harris, Jr, 300 Sunset Avenue, Apartment 19, Great Falls, SC 29055, (803) 482-3333 and currently twenty-eight (28) years of age.
2. I have been a resident of Great Falls, South Carolina for approximately twenty-eight (28) years.
3. I am of Jewish heritage, but do not adhere to Judaism. I am not Christian, however I was raised Baptist until about the age of thirteen (13) years of age, and I am now of the Pagan belief system and have been so for about fifteen (15) years.
4. I am a gay Jewish male.
5. I am an Assistant Manager with Defender Services, Inc., of the Springs Frances site.
6. I am not very accepted within the Town of Great Falls, South Carolina, but have attempted to become involved with our community by going to the Town Council Meetings, of which, I have attended to date thirteen (13).
7. I have personally witnessed the name of Jesus Christ being invoked twelve (12) of the Town Council Meeting I have attended.
8. On April 15, 2002, J.C. Broom began the invocation at the request of the Mayor, but began with, "In the name of our Father," which is unusual because he has always said in the name of Jesus Christ, but still he stated tonight at the ending of the prayer, "In Christ name we pray."
9. I believe a legislative body may not constitutionally conduct a sectarian prayer. See County of Allegheny v ACLU, 492U.S.573, 602-03 (1989); cf., Marsh v Chambers, 463 U.S. 783, 793-795 (1983). The court in Allegheny explained that "not even the 'unique history' of legislative prayer can justify contemporary legislative prayers that have the affect of affiliating the government with any one specific faith or belief." Allegheny 492 U.S. at 603. Prayers with reference to Jesus Christ impermissibly affiliate the government with Christianity. See id. In Stein v Plainwell Community Schools, 822 F.2d 1406, 1410 (6th Cir. 1987), the Sixth Circuit also concluded those legislative prayers that contain "the language of Christian theology and prayer" or "expressly invoke the name of Jesus as the Savior" are unconstitutional. Id. The Town Council's references to Jesus in its prayers are unconstitutional.
10. The Town Council represent all members within our community, not only those that adhere to the majority religious tradition.
11. The Town Council prayers are conducted in a manner that coerces members of the public who attends council meeting to take part in an unwelcome religious exercise.
12. The prayer that is currently being given at the Town Council Meetings makes me uncomfortable because I am not a Christian. I feel that they further ostracize me from my community by purposely coercing me to participate, or respect my own beliefs and not participate within the Christian ritual prayer at the Town Council Meetings.
13. Due to the ostarcization I feel that is occurring at the Town Council Meetings, I jam not comfortable attending these meetings. In order for me to be a productive member of the community of Great Falls, South Carolina and to show people that although I am gay, I am also a viable part of this community. I have the same concerns and interest as them. I must be able to participate within our governmental process without feeling like an unwelcome guest.
14. I am giving this statement to be used as evidence in the above captioned case and it is based upon my knowledge of facts.
____________________________________________ Date : ________________________________
Paul Dean Harris, Jr.

I attest that the above individual signed this document before me:

Notary Signature: ___________________________________ Date: _______________________________

My Commission expires on ____________