SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK

x CITIZENS DEFENDING LIBRARIES, : EDMUND MORRIS, ANNALYN SWAN, : STANLEY N. KATZ, THOMAS BENDER,: Index No.: 65242712013 DAVID NASAW, JOAN W. SCOTT, CYNTHIA M. PYLE, CHRISTABEL GOUGH, and BLANCHE WEISEN COOK, Plaintiffs, - against - DR. ANTHONY MARKS, NEIL L. RUDENSTINE, BOARD OF TRUSTEES : OF THE NEW YORK PUBLIC LIBRARY, : NEW YORK PUBLIC LIBRARY, ASTOR, : LENOX AND TILDEN FOUNDATIONS, : VERONICA WHITE, NEW YORK CITY : DEPARTMENT OF PARKS AND RECREATION, CITY OF NEW YORK, ROBERT SILMAN ASSOCIATES,: P.C., and JOSEPH TORTORELLA, Defendants. -andSTATE OF NEW YORK, NEW YORK STATE OFFICE OF PARKS, RECREATION & HISTORIC PRESERVATION (NEW YORK STATE DIVISION FOR HISTORIC PRESERVATION AND RECREATION), Nominal Defendants. : State of Connecticut ) :.ss: County of Litchfield ) EDMUND MORRIS, having been duly sworn, deposes and says: 1. My name is Edmund Morris. I am one of the plaintiffs in this action. I submit this
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AFFIDAVIT OF EDMUND MORRIS

Affidavit in Support of the Order the Show Cause for a Temporary Restraining Order and Preliminary Injunction. As shown below and in the accompanying papers, the Order to Show Cause, including the temporary relief pending the hearing, should be granted in all respects. AILBAgkgiouncl 2. I am a professional writer living in New York City and Kent, Connecticut. I was born

in Nairobi, Kenya in May 1940, immigrated to the United States in 1968, and became an American citizen 10 years later. In addition to writing numerous articles on literature, music, and the presidency for such periodicals as The New Yorker, Harper's, and The New York Times Book Review, I have published six books: The Rise of Theodore Roosevelt (1979), Dutch: A Memoir of Ronald Reagan (1999), Theodore Rex (2001), Beethoven: The Universal Composer (2004), Colonel Roosevelt (2010), and This Living Hand and Other Essays (2012). I am now writing a biography of Thomas Edison for Random House. I also lecture widely in such venues as the Metropolitan Museum of Art, the National Portrait Gallery, and Harvard University. 3. My professional awards include the Pulitzer Prize and National Book Award for

Biography. In 1985 President Ronald Reagan appointed me his official biographer. Four of my books have been national bestsellers, and the Theodore Roosevelt trilogy has over a million copies in print. My Use of the New York Public Library 4. From my first days as a penniless immigrant locking for work in New York City, I

have been an habitu of the research divisions of the New York Public Library, Initially I haunted the Music Division of the Library and Museum of the Performing Arts in Lincoln Center, where out of sheer curiosity, in 1972, I discovered a trove of information about the great Russian pianist Josef Lhevinne (1874-1944). I also listened to his rare recordings in the Library's Rodgers and

Hammerstein Archive of Recorded Sound. Helpful staff specialists taught me how to research deeper and further. Eventually I was able to write and record a 2 1/2-hour audio portrait of Lhevinne, which was broadcast by WNCN in 1972 and evoked the largest listener response in the station's history. The purpose of this anecdote is to show how the New York Public Library helped me in my efforts to become a biographer. 5. Since then I have researched large portions of my books in the Library's Main

Building on Fifth Avenue, using to the full, its prodigious wealth of print, manuscript, iconographic, periodical, and other resources. I would like to bring the Court's attention to a peculiarity of scholarly research, and that is the serendipity of "accidental" discovery. A chance reference, say, in a 1907 newspaper article to some book the President is reading, will send a scholar hastening from the microfilm room to the reading room to submit a request slip for that very edition. And when the book is delivered, perhaps in fragile condition wrapped and tied with string, an old photograph may tumble out, tucked inside a hundred years ago by an anonymous person, and inscribed verso with a few copperplate words that reveal something hitherto unknown about both author and President. (I am referring to an actual incident in my own work.) The weaving of the worldwide web has made serendipitous "browsing" easy for scholars interested primarily in digital knowledge which is to say, information accumulated from the 1980s onward. But for those of us who roam the full landscape of human history, a great research library full of interrelated materials of every conceivable type is an inexhaustible resource. That is, unless it is itself exhausted of its own precious contents.

The Irreparable Harm Threatened by Removal of the Stacks

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6. The so-called Central Library Plan is actually a decentralizing concept, in that much

of the Main Building's intellectual core its treasury of printed books and undigitalized periodicals will be dispersed, not only out of New York City, but out of New York State. Proponents of the Plan emphasize that items frequently called for will always be kept close at hand; only those rarely requisitioned will be deported. This is a quantitative, rather than qualitative rationale. It is precisely the books and periodicals least looked at that are most likely to contain gems of original information. What one finds in oft-consulted books is what other people have found already. 7. Those individuals who support the Plan are prone to boast that books relegated to off-

site storage are made available within two days of request. My experience is that requests for materials stored "off site" often takes much longer than the vaunted delivery time of 48 hours. And this does not include those situations in which the book requested cannot be found, ostensibly due to its having been transported back and forth. 8. Frustrating though this is for a researcher living in the New York area particularly

when one returns to the Library on the predicted delivery date, and finds the item still not available it is worse for scholars from out of town or overseas, who have to pay hotel and other bills while waiting and waiting and waiting. (It should be remembered that the New York Public Library, despite its name, is an international cultural resource.) Worse still is the likely probability that scholars from outside New York would leave rather than endlessly awaiting receipt of books or decide that the trip to New York is not worth taking in the first instance. I believe that the Library has proposed a system of advance email requests in an effort to alleviate this problem. Emailing ahead is all very well if you know what you are looking for, but for reasons of the serendipity explained above, some of the most rewarding research discoveries are unexpected or inspirational, and "on the spot." Indeed, it is exceptionally rare for a scholar to request and find in a single book all that is required for a project; more often than not, examination of a requested book leads the

researcher to request another book which, unfortunately, would require another 48 hours or longer before it can be reviewed. 9. As for the very notion of offsite delivery from far away, through heavy citybound

traffic -- I would point out the obvious danger of physical damage to old volumes (transferred from remote shelf to box to truck to central shelf to reader, then back to central shelf to box to truck to remote shelf, with all the climatic changes such shiftings imply), not to mention the even more fraught consequences of an accident on the New Jersey Turnpike. One overturned and burning van could do away with millions of irreplaceable words. 10. The Central Library Plan ignores such risks. Over the last few years, I have noticed

that more and more items have been listed as "off site" -- to such an extent that I recently complained to a reference clerk, "I thought a library was a place that stores books." The clerk replied, "It's only going to get worse, sir, and I can't tell you how much I hate working here now." Speaking as a scholar who has loved the Library all his professional life, I can only say that I, too, hate working there now. 11. In conclusion, I must state with deep regret that if the Central Plan is carried into

effect, I will visit the Library in future only when I have to. And I fully expect most such visits would be unrewarding, since the Plan's apparent intent is to focus on entertainment, exhibitions, and free interne access. My wife is also a professional writer (the author of a biography of Edith Kermit Roosevelt and a two-volume life of Clare Boothe Luce). We have always intended to leave our personal papers and book and picture collection to the New York Public Library, in gratitude for its services over 40 years. But if the current administration goes ahead with its announced intent to replace the solid stacks with the vacuousness of public space, we will sadly seek a depository with 5

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a greater sense of historical responsibility.

Edmund Morris

Sworn before me this day of July, 2013,

Notary Public,

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