Log Cabin Republicans v. United States of America et al

Filing 198

Opposition re: MOTION IN LIMINE to Exclude expert testimony #178 filed by Plaintiff Log Cabin Republicans. (Attachments: #1 Declaration of Rachel Feldman, #2 Declaration of Patrick Hagan and Exhs A & B)(Aenlle-Rocha, Fernando)

Log Cabin Republicans v. United States of America et al

Doc. 198 Att. 1

Case 2:04-cv-08425-VAP -E Document 198-1

Filed 06/22/10 Page 1 of 3

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DAN WOODS (SBN 78638) FERNANDO L. AENLLE-ROCHA (SBN 129515) RACHEL J. FELDMAN ((SBN 246394) PATRICK HAGAN (SBN 266237) WHITE & CASE LLP 633 W. Fifth Street, Suite 1900 Los Angeles, CA 90071-2007 Telephone: [phone] Facsimile: [phone] Email: [e-mail] Email: [e-mail] Email: [e-mail] Email: [e-mail] Attorneys for Plaintiff Log Cabin Republicans UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA LOG CABIN REPUBLICANS, a nonprofit corporation, Plaintiff, v. UNITED STATES OF AMERICA and ROBERT M. GATES, SECRETARY OF DEFENSE, in his official capacity, Defendants. Case No. ED CV 04-8425-VAP (Ex) DECLARATION OF RACHEL J. FELDMAN IN SUPPORT OF PLAINTIFF'S OPPOSITION TO DEFENDANTS' MOTION IN LIMINE REGARDING PLAINTIFF'S EXPERT WITNESSES Date: June 28, 2010 Time: 2:30 p.m. Judge: Hon. Virginia A. Phillips

LOSANGELES 870386 (2K)

DECLARATION OF RACHEL FELDMAN IN SUPPORT OF PLAINTIFF'S OPPOSITION TO DEFENDANTS' MOTION IN LIMINE REGARDING PLAINTIFF'S EXPERT WITNESSES
Dockets.Justia.com

Case 2:04-cv-08425-VAP -E Document 198-1

Filed 06/22/10 Page 2 of 3

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I, Rachel J. Feldman, hereby declare and state as follows: I am an attorney admitted to practice in the State of California. I am associated with White & Case LLP, counsel of record for plaintiff Log Cabin Republicans ("Log Cabin") in the action styled Log Cabin Republicans v. United States, No. CV 04-8425-VAP (Ex) (the "instant action"). I submit this declaration in support of Log Cabin's Opposition to Defendants' (the "government") Motion in Limine Regarding Plaintiff's Expert Witnesses. I have personal knowledge of the facts stated herein or know of such facts from my review of the file in this case, and, if called upon to do so, could competently testify as follows: 1. 2. On behalf of Log Cabin, I attended the government's deposition of At the deposition, the government's counsel extensively questioned Aaron Belkin, Ph.D., on March 5, 2010 (the "deposition"). Dr. Belkin on the subject of privacy in the context of homosexual and heterosexual servicemembers sharing living and working space in the armed forces. 3. 4. Dr. Belkin responded to the government's questions on that subject The government's counsel asked Dr. Belkin if he would be amending with detailed and extensive answers based on his research. his report to reflect his deposition testimony concerning the subject of privacy. Dr. Belkin stated that he would gladly do so. 5. In response to the government's request, Dr. Belkin provided me on March 24, 2010 with an amended expert report reflecting his expert opinions on the subject of privacy, which I then forwarded to the government.

-2LOSANGELES 870386 (2K)

DECLARATION OF RACHEL FELDMAN IN SUPPORT OF PLAINTIFF'S OPPOSITION TO DEFENDANTS' MOTION IN LIMINE REGARDING PLAINTIFF'S EXPERT WITNESSES

Case 2:04-cv-08425-VAP -E Document 198-1

Filed 06/22/10 Page 3 of 3

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I declare under penalty of perjury under the laws of the United States of America that the foregoing is true and correct. Executed this 22nd day of June 2010, at New York, New York.

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Rachel J. Feldman

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DEC LARA TION OF RACHEL FELDMAN IN SUPPORT OF PLAINTIFF' S OPPOSITION TO DEFENDANTS' MOTION IN LIMINE REGARDING PLAINTIFF' S EXPERT WITNESSES