1

IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF TEXAS

FORT WORTH DIVISION

JENNIFER VANDERSTOK, et al.,

Plaintiffs,

v.

MERRICK GARLAND, in his official

capacity as Attorney General of the United States;

et al.,

Defendants.

Civil Action No. 4:22-cv-00691-O

DECLARATION OF JENNIFER VANDERSTOK

I, Jennifer VanDerStok, declare under penalty of perjury, pursuant to 28 U.S.C. § 1746,

that the following statements are true and correct to the best of my knowledge:

1. I am over 18 years of age and am competent to testify to the matters contained

herein.

2. I reside in Mineral Wells, Texas within Palo Pinto County.

3. I am not prohibited from possessing firearms under federal or state law. I have

purchased at least one firearm through a Federal Firearms Licensee (FFL), undergoing and passing

the required federal background check.

4. I was a police officer in Dayton, Ohio, for 6 and a half years, and in Warner Robins,

Georgia, for 1 and a half years, where I qualified with, trained with, and carried a firearm for the

purpose of protecting the community, my fellow officers, and myself.

5. After leaving the police force, I became a high school teacher in Millsap, Texas,

where I also carried a firearm, pursuant to state law and school policy, in order to protect my

students, my fellow teachers, and myself should anyone attempt to threaten their lives on campus.

Case 4:22-cv-00691-O Document 16-2 Filed 08/17/22 Page 1 of 2 PageID 192
2

6. While I no longer teach, I still have my Texas License to Carry permit and I

regularly carry a firearm in order to protect myself, my loved ones, and my community.

7. I own one of the items at issue in this case, marketed as an “80% lower,” that I

intend to self-manufacture into a personal use firearm to own and use for lawful purposes, such as

self-defense. While I do not currently possess a firearm that I have personally manufactured using

the products at issue in this case, I wish to continue to acquire such products in the future and to

begin self-manufacturing them into personal use firearms to own and use for lawful purposes, such

as self-defense. I would do this but for Defendants’ rule that seeks to prohibit me from purchasing

these products directly from the company, without involvement of an FFL.

8. I wish to self-manufacture a personal use firearm for several reasons, including but

not limited to better learning about the function and construction of firearms. This knowledge will

help ensure I continue to safely operate firearms, which I have done for as long as I have owned

and used firearms. I also believe that I have the individual right to build my own self-defense tools

and to purchase the materials necessary to do so.

9. The Final Rule at issue in this case will prohibit me from engaging in an activity

that I wish to, have the right to, and have concrete plans to engage in and will detrimentally impact

me. The Final Rule also fundamentally alters the legal landscape that I have relied on to plan my

personal practices.

DATED this the ___th day of August, 2022.

Jennifer VanDerStok

Case 4:22-cv-00691-O Document 16-2 Filed 08/17/22 Page 2 of 2 PageID 193