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EXHIBIT 38
Case 2:OO—cv—O1118-NVW Document 111-10 Filed O3/28/2007 Page1 of 2

DECLARATION of
CHARLES I. BEAULIEU
1. I remember Steven James when we were children. We were in the same grade at
Campo Bello Elementary School. I first remember him in third or fourth grade. We
were definitely in the same class in fourth grade.
2. Steven was a little different from the other kids at the elementary school. He was
intellectually slower, a little behind everyone else. He was also overweight.
3. Other kids called Steven names and picked fights with him. I recall that I stuck up
for him a couple of times.
4. I remember going to a birthday party at Steven’s house. There were only two kids
there, Kyle Cooper and myself. It was a sad situation. Kyle and I may have been
his only friends.
5. The couple raising Steven were older. I thought that maybe they were his
grandparents.
6. Steven and I both went to Greenway Middle School. I remember an incident in 7"‘
or Sm grade gym class. The gym teacher required us to take a shower after class
and Steven refused, not wanting to be naked in front of other boys. In the end, he
took the shower wearing his underpants. It made me wonder if there was
something wrong with his private parts, or if he was embarrassed about the size of
his penis.
I declare under penalty of perjury that the foregoing is true and correct.
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1+: B ·
Executed on "‘ V , 2007 k __ ¢»=-,..e4.·..’.%a h
CH RLES J. E IEU
Case 2:OO—cv—O1118-NVW Document 111-10 Filed O3/28/2007 Page 2 of 2

Case 2:00-cv-01118-NVW

Document 111-10

Filed 03/28/2007

Page 1 of 2

Case 2:00-cv-01118-NVW

Document 111-10

Filed 03/28/2007

Page 2 of 2