Case Document 57-3 Filed 02/02/17 Page 1 of 4

Exhibit 3

Case Document 57-3 Filed 02/02/17 Page 2 of 4

UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF LOUISIANA

JANE DOE I, JANE DOE II, and CIVIL ACTION NO. 16-14876
JANE DOE 

VERSUS JUDGE BARRIER

JUANA MARINE-LOMBARD, in her

of?cial capacity as Commissioner, MAGISTRATE JUDGE ROBY
Louisiana Of?ce of Alcohol and Tobacco
Control

DECLARATION OF PLAINTIFF JANE DOE II

1, Jane Doe II, declare under penalty of perjury that the following is true and correct:

1. I am over 18 years of age and competent to give testimony in this matter.

2. have personal knowledge of the facts set forth in this declaration.

3. I am a resident of Baton Rouge, Louisiana, I am eighteen (18) years old, and I am
a woman.

4- I am a student at Louisiana State University 

5. Both of my parents died of cancer, so I am entirely independent. For a period of

time after my parents? deaths, I received social security bene?ts, but those benefits ceased when I
graduated from high school. I

6. In June 2016, I began working as an erotic dancer in order to ?nance my college
education and living expenses. I planned to save enough money over the summer through my
work as a dancer so that at the start of the school semester, I could concentrate fully on my

studies.

PD.20449812.1

Case Document 57-3 Filed 02/02/17 Page 3 of 4

7. On July 30, 2016, the club at which I danced informed me that due to Act No.
395, I could not return to work as an erotic dancer. I stopped dancing at the Act?s effective date,
and instead began working as a ?shot girl,? that is, as a server who circulates throughout the club
and offers patrons shots of alcohol for purchase. After Act No. 395 went into effect in Baton
Rouge on August I, 2016, my income decreased by more than 50%, which may cause me to take
a second job to meet my financial obligations.

8. In addition to the lost income and inability to express myself through erotic dance,
I have suffered further expenses as a result of Act No. 395. Speci?cally, because the language of
Act No. 395 regarding what attire is prohibited for eighteen-, nineteen?, and twenty?year?old?
adults working in establishments that are licensed pursuant to Title 26 of Louisiana?s Revised
Statutes is so vague, I am unsure precisely what attire violates the law. I am responsible for
providing my own attire while at work and I have had to update my wardrobe several times at my
own expense to attempt to comply with the law.

9. I do not believe I am susceptible to becoming the Victim of human traf?cking
through my work as an erotic dancer, and, in fact, I feel safer at the club than at home due to the
club?s strict safety protocols.

10. I have discussed the effects of Act No. 395 with other women under the age of
twenty?one who formerly performed as erotic dancers, and some of those women report that they,
will seek income through prostitution now that they have lost their legal jobs as erotic dancers. I
believe that Act No. 395 makes adults aged eighteen, nineteen, and twenty more susceptible to
harm from traffickers, pimps, and prostitutes, because it eliminates a legal job with high pay and

?exible hours.

PD.20449812.1

 

Case Document 57-3 Filed 02/02/17 Page 4 of 4

1 1. Pursuant to 28 U.S.C. 1746, I declare under penalty of perjury that the
foregoing is true and correct.

Executed this i; 7 day of November, 2016.

bee, 

JANE DOB 11

 

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