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

Filing 126

DECLARATION of John Doe #23 in SUPPORT OF 110 MOTION for SUMMARY JUDGMENT. (Bieniek, Scott)

Download PDF
ProtectMarriage.com - Yes on 8, a Project of California Renewal et al v. Bowen et al Doc. 126 John Doe #23 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 (Ariz. State 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 #23 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 over $X,XXX to ProtectMarriage.com - Yes on 8, a Project of California Renewal. 4. In support of Proposition 8, I also placed a bumper sticker on my car. 5. Because of my support of Proposition 8, my name was published on a "blacklist" of donors to Proposition 8. This made me concerned for the safety of my boys, and I instructed the principal at their school to alert the teachers that only my wife or I was to pick them up from school. Although most of the websites with blacklists have since been taken down, the San Francisco Chronicle now has a site where donors to Proposition 8 can be looked up. Additionally, I am very concerned about www.eightmaps.com, where people can obtain maps directing them to the homes of people who supported Proposition 8. 6. About a week after the November 2008 election, someone ordered a book containing the greatest homosexual love stories of all time and sent it to me. Amazon would not tell me who sent this book. 7. On the night of the election, when Proposition 8 passed, someone painted the face of the statute of Mary, the Mother of Jesus, outside of my church orange. 8. Because of these incidents, if I donate to a cause similar to Proposition 8 in the future, I may donate a lesser amount under the disclosure threshold, or donate to an organization in a way that will not require the disclosure of my name. I DECLARE UNDER PENALTY OF PERJURY THAT THE FOREGOING IS TRUE AND CORRECT. Executed on: REDACTED REDACTED REDACTED 2 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 #23 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 #23 in Support of Plaintiffs' Motion for Summary Judgment