ProtectMarriage.com - Yes on 8, a Project of California Renewal et al v. Bowen et al
DECLARATION of John Doe #27 in SUPPORT OF 110 MOTION for SUMMARY JUDGMENT. (Attachments: # 1 Exhibit A)(Bieniek, Scott) Modified on 6/4/2009 (Matson, R).
ProtectMarriage.com - Yes on 8, a Project of California Renewal et al v. Bowen et al Doc. 130 John Doe #27 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 #27 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 Michigan 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 the passage of Proposition 8, I donated approximately $XXX to National Organization for Marriage. 4. Although I have supported causes similar to Proposition 8 in the past, my only public support of Proposition 8 was the donation I made to the National Organization for Marriage California - Yes on 8, Sponsored by National Organization for Marriage ("National Organization for Marriage"). The only way I could be publicly identified as supporting Proposition 8 was through the public disclosure of my personal information as a result of my donations to the National Organization for Marriage. 5. When I made my donation, I had no idea that my name would be made public. It had been my intention to remain anonymous. Had I known that my name would be posted online, I probably would not have donated. 6. I am an author of three books under the pseudonym of REDACTED . I regularly check the internet to see what sort of information is being published about me. 7. In December, I performed one of my regular checks of the internet and discovered that my name had been posted on a "BoycottH8ers List" and listed as an intolerant "H8er" for supporting Proposition 8 in California. I support Proposition 8 because I believe that Natural Law is the basis of the U.S. Constitution and all laws. I am not a "H8er." 8. After being listed as a "H8er" on the internet, I sent an email to the Christian Legal Crew, and told them that I wished I would have known that my name would be posted on the internet if I made a donation. A true and correct copy of the text of that email is attached as Exhibit A. 2 John Doe #27 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 9. In the future, I would be much less likely to get involved in a cause similar to Proposition 8 that does not assure my confidentiality. 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 #27 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 firstname.lastname@example.org Attorney for Defendants Debra Bowen and Edmund G. Brown, Jr. Judy W. Whitehurst email@example.com Attorney for Defendant Dean C. Logan Terence J. Cassidy firstname.lastname@example.org Attorney for Defendant Jan Scully Mollie M. Lee email@example.com Attorney for Defendants Dennis J. Herrera and Department of Elections - City and Count of San Francisco Lawrence T. Woodlock firstname.lastname@example.org 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 #27 in Support of Plaintiffs' Motion for Summary Judgment