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Deborah A. Ferguson, ISB No. 5333 The Law Office of Deborah A. Ferguson, PLLC 202 N. 9th Street, Suite 401 C Boise, Idaho 83702 Tel.: (208) 484-2253 d@fergusonlawmediation.com Craig Harrison Durham, ISB No. 6428 Durham Law Office, PLLC 405 S. 8th Street, Ste. 372 Boise, ID 83702 Tel.: (208) 345-5183 craig@chdlawoffice.com Shannon P. Minter Christopher F. Stoll National Center for Lesbian Rights 870 Market Street, Suite 370 San Francisco, California 94102 Tel.: (415) 392-6257 sminter@nclrights.org Attorneys for Plaintiffs UNITED STATES DISTRICT COURT FOR THE DISTRICT OF IDAHO SUSAN LATTA and TRACI EHLERS, LORI WATSEN and SHARENE WATSEN, SHELIA ROBERTSON and ANDREA ALTMAYER, AMBER BEIERLE and RACHAEL ROBERTSON, Plaintiffs, v. C.L. "BUTCH" OTTER, as Governor of the State of Idaho, in his official capacity, and CHRISTOPHER RICH, as Recorder of Ada County, Idaho, in his official capacity, Defendants.

Case No. 1:13-cv-00482-CWD

DECLARATION OF PLAINTIFF ANDREA ALTMAYER IN SUPPORT OF PLAINTIFFS MOTION FOR SUMMARY JUDGMENT

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I, Andrea Altmayer, hereby declare and state as follows: 1. I am one of the Plaintiffs in this action, along with my life partner of

sixteen years, Shelia Robertson. I am 44 years old and live in Boise, Idaho. I have personal knowledge of the matters stated in the declaration and could and would competently testify to these facts. 2. I was born in Akron, Ohio. My family moved to Billings, Montana when I

was seven years old. My parents divorced after nineteen years of marriage when I was twelve. I lived with my mother and my two siblings until I graduated from high school. 3. In 2004 I received my B.S. in Health Sciences from Boise State

University. I am a certified massage therapist, having attended the Idaho Institute of Wholistic Studies in 1996-1997. 4. I have been self-employed as a massage therapist for seventeen years, with

an established practice and clients. I find my work very fulfilling, and enjoy helping my clients with their health and well-being. I was very private about my sexual orientation in my practice for many years, as I was concerned it might offend my clients. After my sons birth, I have been more open about the fact that Shelia and I are life partners. 5. I didnt come out to my parents until I was in a committed relationship

with Shelia. I told my sister I am a lesbian before I told my parents. My mom is very supportive of Shelia and me and our son. My mom recently moved from Montana to Boise to be closer to us. Her support has been essential in raising our son, and she is a huge part of our family. My dad struggles with the fact I am a lesbian, but is loving to me and his grandson and wants to be a part of our lives. I think if Shelia and I were married, it would be easier for my father and extended family to appreciate and understand the

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depth of our relationship, and our commitment to it, and would help them in explaining our family relationship to others. 6. Shelia and I were introduced through a mutual friend, and we hit it off

immediately. I asked Shelia on a second date, and she said yes. We fell in love and had a long-distance relationship for 10 months when Shelia lived and worked in Gooding, Idaho. We decided to live together in Boise, and Shelia moved into my home. We have known each other for over sixteen years and have been in a committed, exclusive relationship since that time. Shelia is my life partner. She accepts me for who I am. I love her, and we want to spend the rest of our lives together, and we wish to marry in Idaho. 7. In 2003, we bought a home together. Early in our relationship, we

discussed having children. We waited until we had been together as a couple for several years before we decided to start a family. I agreed I would carry our child. We made several attempts at getting pregnant through artificial insemination. After three years of trying to conceive, on and off, I did get pregnant, but we lost the baby, which was very difficult for both of us. I became pregnant again two years later by artificial insemination, and our son was born in 2009, with Shelia at my side. 8. Our nurse helped us fill out his birth certificate and listed Shelia as a

parent. However, when the birth certificate was returned to us from the State of Idaho, Shelias name had been removed, which was very sad and frustrating for both of us. Being a mother has changed my life; I never imagined having a child would have given my life and my relationship with Shelia so much depth. I love how Shelia and I are learning from each other as we parent our son.

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9.

Because Idaho law excludes Shelia and me from marriage, as a same-sex

couple, my son and I are denied the security, recognition and protection that Idaho law provides to married opposite sex couples and their children. Had Shelia and I been permitted to be married at the time of our sons birth, Shelia would have been presumed our sons parent, without need of any court proceedings. Instead, Shelia is not recognized as our sons parent. This has sweeping ramifications in legal, educational and medical settings and is detrimental to him and us as a family. For example, Shelia cannot consent to medical treatment for him. It also creates a burden upon us as a family because Shelia cannot share numerous important parental responsibilities with me. I do not want our son to grow up thinking that there is something wrong with his family or having difficulty understanding the integrity or closeness of his family because Shelia and I cannot get married. We have participated as plaintiffs in this case in the hope that as his parents, we can be married in Idaho. 10. I want to marry Shelia in Idaho to solidify our relationship and our life-

long commitment to each other as partners and our sons parents. I would like to have the same benefits and responsibilities as other married couples, and the recognition, stability and protection marriage provides. Shelia and I have been through so much as a couple. It does not seem right to me that we would have to travel outside Idaho to marry, after I have lived in Idaho almost twenty-three years. 11. Not having the right to marry one another negatively impacts our family in

many ways. For example, neither our son nor I can obtain health insurance coverage through Shelias employer. Shelia has no recognized legal relationship to our son, even though she supported me through my pregnancy and has raised him with me since his

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birth. We do not have the right to visit one another, or direct one anothers care, if either of us needs medical care and cannot express each others wishes if one of us becomes incapacitated. Instead, that right belongs to our elderly parents. Likewise, Shelia is not able to take family leave for our son or me. She is also unable to take bereavement leave for a death in our extended family. This situation presented itself to our family when my brother passed away unexpectedly. We cannot file our taxes jointly, and the property we have acquired together is not considered community property. We also have to take additional and costly legal steps to protect one another and our son in the event either one of us were to die. 12. On November 6, 2013, Shelia and I went to the Ada County Recorder at

the Ada County Clerks Office in Boise to apply for a marriage license. Other than the fact that Shelia and I are both women, we meet all the legal requirements for marriage in Idaho. The Recorders office did not issue us a license, and the experience of being denied a license was demeaning. The Recorders office employee stated that it would be contrary to Idaho Code, and we were turned away. I sign this Declaration under penalty of perjury under the laws of the United States. DATED the 14th day of February 2014.

_______/s/_____________ Andrea Altmayer ! !