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

Filing 131

DECLARATION of John Doe #28 in SUPPORT OF 110 MOTION for SUMMARY JUDGMENT. (Attachments: # 1 Exhibit B)(Bieniek, Scott) Modified on 6/4/2009 (Matson, R).

Download PDF
ProtectMarriage.com - Yes on 8, a Project of California Renewal et al v. Bowen et al Doc. 131 John Doe #28 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 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 Case No. 2:09-CV-00058-MCE-DAD ProtectMarriage.com, et al., Plaintiffs, v. Debra Bowen, et al., Defendants. Date: TBD Time: TBD Judge England DECLARATION OF REDACTED IN SUPPORT OF PLAINTIFFS' MOTION FOR SUMMARY JUDGMENT Decl. of REDACTED in Support of Plaintiffs' Motion for Summary Judgment 1 Dockets.Justia.com John Doe #28 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 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 the passage of Proposition 8, I made two separate donations to ProtectMarriage.com Yes on 8, each in the amount of $X,XXX.XX . 4. I did not engage in any other public support of Proposition 8, such as putting up a yard-sign or placing a bumper-sticker on my vehicle. 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 ProtectMarriage.com Yes on 8. 5. On November 11, 2008, at 11:55 a.m., I received a voice mail from an unknown male at my workplace that said: "Hey, it's really disheartening to know that one of my neighbors supported Proposition 8 so heavily. What a scum-fuck!" A true and correct recording of this voice mail is attached as Exhibit A. 6. The phone number the unknown male called from was blocked, so I was unable to obtain the number from my caller-identification system. 7. I filed a report of this harassing phone call with the REDACTED Police Department. A true and correct copy of that report is attached as Exhibit B. I DECLARE UNDER PENALTY OF PERJURY THAT THE FOREGOING IS TRUE AND CORRECT. Executed on: REDACTED REDACTED REDACTED Decl. of REDACTED in Support of Plaintiffs' Motion for Summary Judgment 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 #28 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 #28 in Support of Plaintiffs' Motion for Summary Judgment

Disclaimer: Justia Dockets & Filings provides public litigation records from the federal appellate and district courts. These filings and docket sheets were retrieved from PACER, and should not be considered findings of fact or liability, nor do they necessarily reflect the view of Justia.