Quotes taken directly from a court filing on February 2:
"I am more than eighteen (18) years of age, under no legal disability, and I make this affidavit based upon my personal knowledge.
"As mentioned in more detail in my declaration of December 6, 2006, Hidden Lake Academy ("HLA") has suffered a sharp decrease in enrollment, primarily due to the decrease in referrals from educational consultants.
"My understanding of this decrease in referrals is that the educational consultants fear legal action against them, which fear arises from the allegations in plaintiffs' complaint implicating educational consultants.
"As set forth in more detail in my declaration of December 6, 2006, HLA has suffered significant loss of revenue due to decreased enrollment. Enrollment has dropped from over 150 students in September to 102 as of this date. Since September 1, 2006, 42 of the 120 employees of HLA have been terminated due to decreased revenues.
"Despite reductions in the number of staff and reductions in the salaries of those who remained employed by HLA, HLA's revenue is insufficient to cover its expenses (mortgage, payroll, utilities, etc.) each month.
"Due to the dire financial situation faced by HLA, further reductions in the number of staff employed by HLA or closure of the school is imminent.
"It is important to note that this situation affects not only the employees of the school, but also the 102 students currently enrolled at HLA who have completed approximately two-thirds of their academic year. Further staff reductions will result in a decreased quality of service to those students.
"Even more troublesome is the imminent threat of closure of HLA, which I reasonably believe will have devastating effects on the currently enrolled students, whose mental health will be jeopardized by such instability.
"HLA cannot afford a continued delay in the prosecution of this litigation and will not likely survive the two months that plaintiffs' counsel has requested to conduct discovery prior to a decision on class certification."
