STATEMENT OF INTEREST OF AMICI CURIAE

Jane Doe is a pseudonym for an undergraduate woman student at the University of Michigan who was in a class with defendant Jake Baker. Baker made pornography of amicus curiae's real name, with physical description, in which she is sexually violated, tortured and murdered. Through the Internet, he gave access to use of this pornography of her to an estimated several hundred thousand consumers. Her address was supplied in other pornography Baker made of her. Defendant's behavior was and is threatening to amicus.

Amicus curiae The National Coalition Against Sexual Assault (NCASA) is a voluntary organization with a diverse membership of over 450 rape crisis centers and individuals from all over the United States. From its inception in 1978, NCASA has been recognized as a major forum and force for eliminating sexual violence. NCASA exists to end sexual assault through organizing, education, and legislation and to ease the suffering and facilitate the recovery of all sexual assault survivors -- children and adults, women and men -- by educating and supporting direct service providers. It pursues its goals through assisting victims, raising public awareness, strengthening laws and law enforcement, and supporting research.

NCASA's activities include an annual conference covering treatment, research, awareness, and program development. It publishes NCASA NEWS, fact sheets, regional newsletters, and public policy alerts. The information it circulates is based on survivor reports, expert literature, and NCASA oversight of the legal system. NCASA provides current, accurate, and comprehensive information on sexual assault to victim service providers, public policy makers, media, members, and the public. Through its Public Policy Committee, NCASA educates policy makers, networks with other organizations, and issues policy statements. Through NCASA State Contacts and Regional Representatives, NCASA also monitors the enactment and enforcement of national and state laws that have an impact on sexual violence.

Through its members and activities, NCASA has learned that sexual threats are often precursors to sexual violence, and that sexual violence can be actively inflicted and promoted through pornography. NCASA works to prevent sexual assault by eliminating all social practices that support its occurrence.

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