Page:Spencer v. Nigrelli.pdf/6

 Declarant Charlene Pruitt is a member of the Church. Dkt. 13-2, ¶ 3. She attends services “at the Church’s main campus in Horseheads, New York.” Id. Pruitt holds a license to carry concealed firearms that is “current and valid” under New York law. Id. ¶ 4. Before “New York enacted and began enforcing” the houses of worship exclusion, Pruitt “regularly carried a concealed pistol on the Church’s Horseheads campus.” Id. ¶ 6. Specifically, she “volunteered to help oversee security at the church.” Id. ¶ 9. This included performing numerous tasks such as “watch[ing] over the children’s wing while legally armed,” and keeping “watch for security incidents during church services, classes and special events.” Id. ¶ 10. When volunteering, Pruitt “typically [has] a radio so that [she] can inform church staff of any security issues.” Id.

Like Pastor Spencer, Pruitt believes that she has “a moral and religious duty to take reasonable measures to protect the safety of those who enter the Church.” Id. ¶ 14. She also believes “that the Bible calls the Church” to “love, serve, and protect one another.” Id. ¶ 15. Her “desire to continue carrying a concealed pistol at the Church stems from these religious beliefs” as well as her desire to provide protection from “the kind of violence that has impacted other houses of worship across the country.” Id. ¶ 16. She believes that “someone planning to harm or kill” her “fellow churchgoers will not be deterred by” the houses of worship exclusion, and “may in fact be emboldened by the ban because it leaves” the “Church defenseless against those bent on doing violence to people of faith.” Id. ¶ 17.