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

Exhibit 4

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

 

UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF LOUISIANA

JANE DOE I. JANE DOE II and CIV
DOE IL ACTION N0. 16-14876

VERSUS JUDGE BARBIER

JUANA MARINE-LOMBARD, in her
of?cial capacity as Combsiouer, MAGISTRATE JUDGE ROBY

Louisiana Of?ce of Alcohol and Tobacco
Control

DECLARATION OF PLAINTIFF JANE DOE 

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

I.  - I am over 18 years ofage and competth to give testimony in this matter.
2. I have personal knowledge of the facts set forth in this declaraiion.
3. I am a resident of New Orleans, Louisiana, I am nineteen (19) years old, and I am
a woman.

4. I have a one-year-old daughter and I am ?nancially responsible for both myself
and my daughter.

5. I began working as an erotic dancer in or around September 2015, and speci?cally
worked as an erotic dancer in Baton Rouge, Louisiana from approximately January 2016 until Act
No. 395 went into effect on August 1, 2016.

6. I was forced to stop working as an erotic dancer on August 1, 2016, the date that

Act No. 395 went into effect. I then began to work as a shot girl at the club where I formerly

danced.

PD.20449949. I

Case Document 57-4 Filed 02/02/17 Page 3 of 3
7, 01110me

of caution. I Wear cocbail dresses to work, in order to ensure compliance with Act No. 395?s

vaguelydra?ed restrictions on attire for eighteen-, nineteen-, and twenty-year-old adults working

in establishments that are licensed pursuant to Title 26 of Louisiana?s Revised Statutes.

8. Since I have been forced to stop working as an erotic dancer, my income has

dropped by more than half. If Act No. 395 is repealed or otherwise rendered unenforceable, I

would immediately return to erotic dancing as my preferred vocation.

9. During my time as an erotic dancer and shot girl, I have never felt unsafe. I have

messed any behavior in my workplace that could be characterized as human traf?cking,

victimized. I believe that the strict safety

never wi
and I have never known any erotic dancer who has been
lub, dancers, personnel, and customers safe.

my that the

protocols of my workplace keep the 
10. Pursuant to 28 U.S.C. 1746, I declare under penalty of petj

foregoing is true and correct.

Executed this I 0' day of November, 2016.