edmund morris affidavit supporting cdl v. nypl lawsuit

7/28/2019 Edmund Morris Affidavit supporting CDL v. NYPL lawsuit

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SUPREME COURT OF THE STATE OF NEW YORKCOUNTY OF NEW YORKCITIZENS DEFENDING LIBRARIES, :EDMUND MORRIS, ANNALYN SWAN, :STANLEY N. KATZ, THOMAS BENDER,:DAVID NASAW, JOAN W. SCOTT, CYNTHIA M . PYLE, CHRISTABELGOUGH, and BLANCHE WEISENCOOK,

Plaintiffs,

Index No.: 65242712013

- against -FFIDAVIT OFEDMUND MORRISDR. ANTHONY MARKS, NEIL L.RUDENSTINE, BOARD OF TRUSTEES :OF THE NEW YORK PUBLIC LIBRARY, :NEW YO RK PUBLIC LIBRARY , ASTOR, :LENOX AND TILDEN FOUNDATIONS, :VERONICA WHITE, NEW YORK CITY :DEPARTMENT OF PARKS ANDRECREATION, CITY OF N EWYORK , ROBERT SILMAN ASSOCIATES,:P.C., and JOSEPH TORTORELLA ,

Defendants.-and-

STATE OF NEW YO RK, NEW YORKSTATE OFFICE OF PARKS,RECREATION & HISTORICPRESERVATION (NEW YORKSTATE DIVISION FOR H ISTORICPRESERVATION AND RECREATION),Nominal Defendants. :

State of Connecticut ):.ss:

County of Litchfield )EDMUND MORRIS, having been duly sworn, deposes and says:1.y name is Edmund Morris. I am one of the plaintiffs in this action. I submit this


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Affidavit in Support of the Order the Show Cause for a Temporary Restraining Order andPreliminary Injunction. As shown below and in the accompany ing papers, the Order to Show Cause,including the temporary relief pending the h earing, should be granted in all respects.AILBAgkgiouncl

2. I am a professional writer living in New York C ity and Kent, Con necticut. I was bornin Nairobi, Kenya in May 1940, immigrated to the United States in 1968, and became an Am ericancitizen 10 years later. In addition to writing numerous articles on literature, music, and thepresidency for such periodicals as The New Yorker, Harper's, and The New York Times BookReview, I have published six books: The Rise of Theodore Roosevelt (1979), Dutch: A Mem oir ofRonald Reagan (1999), Theodore Rex (2001), Beethoven: The Universal Com poser (2004), ColonelRoosevelt (2010), and This Living Hand and Other Essays (2012). I am now writing a biographyof Thomas Edison for Random House. I also lecture widely in such venues as the MetropolitanMuseum 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 mybooks have been national bestsellers, and the Theodore Roosevelt trilogy has over a million copiesin print.My U se of the New York Public Library

4. From m y first days as a pen niless immigrant locking for work in New Yo rk City, Ihave been an habitu of the research divisions of the N ew Y ork Public Library, Initially I hauntedthe Music Division of the Library and Museum of the Performing A rts in Lincoln Center, where outof sheer curiosity, in 1972, I discovered a trove of inform ation about the great R ussian pianist JosefLhevinne (1874-1944). I also listened to his rare recordings in the Library's Rodgers and

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Hamm erstein A rchive of Recorded Sound. H elpful staff specialists taught me how to research deeperand further. Eventually I was able to write and record a 2 1/2-hour audio portrait of Lhevinne, whichwas broad cast by W NCN in 1972 and evoked the largest listener response in the station's history.The purpose of this anecdote is to show how the Ne w York Public Library helped me in my effortsto become a biographer.

5. Since then I have researched large portions of my books in the Library's MainBuilding 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 ofscholarly research, and that is the serendipity of "accidental" discovery. A chance reference, say, ina 1907 newspape r article to some boo k the President is reading, will send a scholar hastening fromthe microfilm room to the rea ding room to subm it a request slip for that very edition. And w hen thebook is delivered, perhaps in fragile condition wrapped and tied with string, an old photograph m aytumb le out, tucked inside a hundred years ago by a n anonym ous person, and inscribed verso witha few copperplate words that reveal something hitherto unknown about both author and President.

(I am referring to an actual incident in my ow n work.) The weaving of the w orldwide web has mad eserendipitous "browsing" easy for scholars interested primarily in digital knowledge which is tosay, information accumulated from the 1980s onward. But for those of us who roam the fulllandscape of human history, a great research library full of interrelated materials of everyconceivab le type is an inexhaustible resource. That is, unless it is itself exhausted of its own p reciouscontents.

The Irreparable Harm T hreatened by Rem oval of the StacksmihsDspagsugattr1_,UhEary6. The so-called Central Library Plan is actually a decentralizing con cept, in that much3


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of the M ain Building's intellectual core its treasury of printed books and und igitalized periodicals will be dispersed, not only out of N ew Y ork City, but out of New York State. Proponents of thePlan emp hasize that items frequen tly 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 preciselythe books a nd periodicals least looked at that are m ost likely to contain gems of original information.What one finds in oft-consulted books is what other p eople have found already.

7. Those individuals who support the Plan are prone to bo ast that books relegated to off-site storage are made available within two days of request. My experience is that requests formaterials stored "off site" often takes much longer than the vaunted delivery time of 48 hours. Andthis does not include those situations in which the book requested cannot be found, ostensibly dueto its having been transported back and forth.

8. Frustrating though this is for a researcher living in the New York are a p articularlywhen o ne 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 whilewaiting 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 thatscholars from outside New York would leave rather than endlessly awaiting receipt of books ordecide that the trip to New York is not w orth taking in the first instance. I believe that the Libraryhas proposed a system of advance email requests in an effort to alleviate this problem. Emailingahead is all very well if you know what you are looking for, but for reasons of the serendipityexplained above, some of the most rew arding 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 bookall that is required for a project; more often than not, examination of a requested book leads the

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researcher to request another book w hich, unfortunately, would require another 48 ho urs or longerbefore it can be reviewed.

9. As for the very notion of offsite delivery from far away, through heavy cityboundtraffic -- I would point out the obv ious danger of phy sical damage to old vo lumes (transferred fromremo te shelf to box to truck to central shelf to reader, then back to central shelf to box to truck toremote shelf, with all the climatic changes such shiftings imply), not to mention the even morefraught consequence s of an accident on the New Jersey Turnpike. One overturned and burning vancould do away with millions of irreplaceable words.

10. The C entral Library Plan ignores such risks. Over the last few years, I have noticedthat more and m ore items have be en listed as "off site" -- to such an extent that I recently complainedto a reference clerk, "I thought a library was a place that stores books." Th e clerk replied, "It's onlygoing to get worse, sir, and I can't tell you how much I hate working here now." Speaking as ascholar who ha s loved the Library all his professional life, I can only say that I, too, hate workingthere now.

11. In conclusion, I must state with deep regret that if the Central Plan is carried intoeffect, I will visit the Library in future only when I have to. An d I fully expect most such visits wouldbe unrew arding, since the Plan's apparent intent is to focus on entertainment, exhibitions, and freeinterne access. My wife is also a professional writer (the author of a biography of Edith KermitRoosevelt and a two-volume life of Clare Boothe Luce). We have always intended to leave ourpersonal papers and book and picture collection to the New York Public Library, in gratitude for itsservices over 40 years. But if the current administration goes ahead with its announced intent toreplace the solid stacks with the vacuousness of public space, we w ill sadly seek a dep ository with

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JUL-10-2013 07:18 PM MORRIS60 927 5087.01a greater sen se of histor ical responsibil i ty .Edmund Mor r i s

Sw orn before me thisday of July, 2013,

Notary P ubl ic,S i i A N N O N E - M C C 1 1 , j

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edmund morris affidavit supporting cdl v. nypl lawsuit

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