ProtectMarriage.com - Yes on 8, a Project of California Renewal et al v. Bowen et al

Filing 117

DECLARATION of John Doe #14 in SUPPORT OF 110 MOTION for SUMMARY JUDGMENT. (Bieniek, Scott)

ProtectMarriage.com - Yes on 8, a Project of California Renewal et al v. Bowen et al Doc. 117 John Doe #14 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Declaration of REDACTED in Support of Plaintiffs' Motion for Summary Judgment James Bopp, Jr. (Ind. State Bar No. 2838-84)* Richard E. Coleson (Ind. State Bar No. 11527-70)* Barry A. Bostrom (Ind. State Bar No.11912-84)* Sarah E. Troupis (Wis. State Bar No. 1061515)* Scott F. Bieniek (Ill. State Bar No. 6295901)* BOPP, COLESON & BOSTROM 1 South Sixth Street Terre Haute, IN 47807-3510 Telephone: (812) 232-2434 Facsimile: (812) 235-3685 Counsel for All Plaintiffs Benjamin W. Bull (AZ Bar No. 009940)* ALLIANCE DEFENSE FUND 15100 North 90th Street Scottsdale, Arizona 85260 Telephone: (480) 444-0020 Facsimile: (480) 444-0028 Counsel for All Plaintiffs Timothy D. Chandler (Cal. State Bar No. 234325)** ALLIANCE DEFENSE FUND 101 Parkshore Drive, Suite 100 Folsom, CA 95630 Telephone: (916) 932-2850 Facsimile: (916) 932-2851 Counsel for All Plaintiffs * Admitted Pro Hac Vice ** Designated Counsel for Service United States District Court Eastern District of California Sacramento Division ProtectMarriage.com, et al., Plaintiffs, v. Debra Bowen, et al., Defendants. Case No. 2:09-CV-00058-MCE-DAD DECLARATION OF REDACTED IN SUPPORT OF PLAINTIFFS' MOTION FOR SUMMARY JUDGMENT Date: TBD Time: TBD. Judge England 1 Dockets.Justia.com John Doe #14 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Declaration of REDACTED in Support of Plaintiffs' Motion for Summary Judgment I, REDACTED , make the following declaration pursuant to 28 U.S.C. 1746: 1. I am a resident of the state of California over 18 years of age, and my statements herein are based on personal knowledge. 2. I supported the passage of Proposition 8. 3. In support of Proposition 8, I donated $XXX to my church. 4. In support of Proposition 8, I placed Yes on 8 signs in my yard and on a balcony of my house. 5. The Yes on 8 signs were ripped out of my yard and off of my balcony at least once a week after I put them up. 6. On September 23, 2008, someone egged and floured my home during the night. 7. In October, my home was once again egged and floured. 8. On the day before the November 2008 election, my home was egged and floured for a third time. 9. On November 1, 2008, my cars were egged and floured. Additionally, someone poured honey on my cars. This destroys the finish on the cars. 10. On November 3, 2008, my cars were once again egged, floured, and had honey poured on them. 11. In support of Proposition 8, I also placed bumper stickers on my cars and on my motorbike. 12. In August and September, the bumper stickers on my cars were scraped off the back glass windows of the cars. This happened during the day, while the cars were parked on the street. 13. At work, I park in a parking lot. One day while I was at work, someone scraped the bumper sticker off of my motorbike. 14. On November 5, 2008, my motorbike was pushed over. 15. Someone vandalized my church's temple. The next day, I assisted in the clean up of 2 John Doe #14 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Declaration of REDACTED in Support of Plaintiffs' Motion for Summary Judgment the graffiti that had been spray painted at the Temple. I DECLARE UNDER PENALTY OF PERJURY THAT THE FOREGOING IS TRUE AND CORRECT. Executed on: REDACTED REDACTED REDACTED 3 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 CERTIFICATE OF SERVICE I, Scott F. Bieniek, am over the age of 18 years and not a party to the within action. My business address is 1 South Sixth Street, Terre Haute, Indiana 47807. On June 3, 2009, I electronically filed the foregoing document described as Declaration of John Doe #14 in Support of Plaintiffs' Motion for Summary Judgment, with the Clerk of Court using the CM/ECF system which will send notification of such filing to: Zackery P. Morazzini zackery.morazzini@doj.ca.gov Attorney for Defendants Debra Bowen and Edmund G. Brown, Jr. Judy W. Whitehurst jwhitehurst@counsel.lacounty.gov Attorney for Defendant Dean C. Logan Terence J. Cassidy tcassidy@porterscott.com Attorney for Defendant Jan Scully Mollie M. Lee mollie.lee@sfgov.org Attorney for Defendants Dennis J. Herrera and Department of Elections - City and Count of San Francisco Lawrence T. Woodlock lwoodlock@fppc.ca.gov Attorney for Defendant Members of the Fair Political Practices Commission I declare under the penalty of perjury under the laws of the State of Indiana that the above is true and correct. Executed this 3rd day of June, 2009. /s/ Scott F. Bieniek Scott F. Bieniek (Ill. State Bar No. 6295901) Counsel for All Plaintiffs 1 Declaration of John Doe #14 in Support of Plaintiffs' Motion for Summary Judgment