ProtectMarriage.com - Yes on 8, a Project of California Renewal et al v. Bowen et al
DECLARATION of John Doe #30 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. 133 John Doe #30 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 #30 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 $XX in support of Proposition 8, and my name was disclosed as a donor to Proposition 8. 4. I also supported Proposition 8 by walking the precincts in San Mateo and San Francisco. I also worked phone banks. 5. Because of my support for Proposition 8, I have received numerous harassing and threatening emails and inquiries at my website. True and correct copies of some of these emails and inquiries are attached as Exhibit A. One email states: "I tolerate you because I don't come to where you are and slaughter you. . . . I will actively pursue your financial ruin through legal means." Another email states: "Your company is now on a list I am producing of those that will be boycotted and shut down soon." 6. These incidents with the emails make me want to fight harder for causes similar to Proposition 8. However, from this point forward, I will be very careful about what I do in support of similar causes. I will try to donate anonymously, and I will not speak out publicly on similar causes, because I would fear for the safety of my children if I did so. 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 #30 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 email@example.com Attorney for Defendants Debra Bowen and Edmund G. Brown, Jr. Judy W. Whitehurst firstname.lastname@example.org Attorney for Defendant Dean C. Logan Terence J. Cassidy email@example.com Attorney for Defendant Jan Scully Mollie M. Lee firstname.lastname@example.org Attorney for Defendants Dennis J. Herrera and Department of Elections - City and Count of San Francisco Lawrence T. Woodlock email@example.com 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 #30 in Support of Plaintiffs' Motion for Summary Judgment