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

Filing 135

DECLARATION of John Doe #32 in SUPPORT OF 110 MOTION for SUMMARY JUDGMENT. (Attachments: # 1 Exhibit A)(Bieniek, Scott) Modified on 6/4/2009 (Matson, R).

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ProtectMarriage.com - Yes on 8, a Project of California Renewal et al v. Bowen et al Doc. 135 John Doe #32 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 IN REDACTED SUPPORT OF PLAINTIFFS' MOTION FOR SUMMARY JUDGMENT Date: TBD Time: TBD. Judge England 1 Dockets.Justia.com John Doe #32 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 Ohio 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 made three donations, totaling $XXX , to the National Organization for Marriage California - Yes on 8, sponsored by National Organization for Marriage. 4. I have supported causes similar to Proposition 8 in the past, and I have never experienced any sort of retribution because of my support for these causes. 5. Because of my donations in support of Proposition 8, at least one website has singled me out as a "homophobe" and a "wingnut" because of my support for Proposition 8. A true and correct copy of this website as it appeared on February 6, 2008 is attached as Exhibit A. 5. I have a son in California who shares my name. My son is a practicing lawyer. 6. Because we share the same name, I feel that these attacks on me are an indirect attack on my son, even though he is not involved with supporting Proposition 8. I do not want my support of Proposition 8 to compromise his professional identity, yet I fear that the sort of harassment I experienced on the internet will do 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 #32 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 #32 in Support of Plaintiffs' Motion for Summary Judgment