AFFIDAVIT OF STANLEY SACK


I, Stanley Sack, being first duly cautioned and sworn, hereby state as follows:

1.     The statements contained in this affidavit are based on my personal knowledge.

2.     I am a medical doctor. I graduated from Hahnemann University School of Medicine in 1985. I completed my residency in pediatrics at Tulane University Hospital in 1988. I maintained a practice in Massachusetts for 18 years. I currently reside in Key West, FL, and have maintained a practice there for 3 years.

3.     I have maintained licensure in Massachusetts, Louisiana and Florida and am Board Certified. Prior to my move to Florida, I held a faculty appointment at the University of Massachusetts School of Medicine.

4.     I go barefoot in my off hours. This includes shopping in various stores, art museums, using restrooms, nightclubs, restaurants, and theaters. In my primary care practice, I am familiar with the risks of injury when barefoot versus risks when shod.

5.     I have read Robert Neinast's essay, Exhibit 4 of his affidavit of September 28, 2009, regarding the issue of the safety of bare feet. It is my professional opinion that the essay is medically accurate.

6.     The conditions in restrooms, such as urine or feces on the floor, pose little risk to the barefooted. Intact human skin does not allow either to penetrate, and urine is generally sterile.

7.     Overall, in developed areas, in the overwhelming majority of cases, the benefits of bare feet appear to outweigh the risks.

Further affiant sayeth naught.

  ___________________________
Stanley Sack
State of Florida }
  }   ss:
County of Monroe }

Sworn to before me and subscribed in my presence this 13 day of November, 2009.

  ___________________________
Notary Public