Log Cabin Republicans v. United States of America et al

Filing 205

REPLY in support of MOTION IN LIMINE to Exclude Certain of Plaintiff's Proposed Exhibits #179 filed by Defendants Donald H Rumsfeld, United States of America. (Attachments: #1 Exhibit, #2 Exhibit)(Parker, Ryan)

Log Cabin Republicans v. United States of America et al

Doc. 205 Att. 2

Case 2:04-cv-08425-VAP -E Document 205-2

Filed 06/24/10 Page 1 of 5

EXHIBIT 2

Dockets.Justia.com

Case 2:04-cv-08425-VAP -E Document 205-2

Filed 06/24/10 Page 2 of 5
1

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

UNITED STATES DISTRICT COURT FOR THE CENTRAL DISTRICT OF CALIFORNIA EASTERN DIVISION _________________________________________________ LOG CABIN REPUBLICANS, ) ) Plaintiff, ) ) Case No. vs. ) ) CV04-8425 UNITED STATES OF AMERICA AND ROBERT GATES, Secretary of Defense, ) (VAP)(Ex) ) ) Defendants. ) ) __________________________________________________

DEPOSITION OF AARON BELKIN, Ph.D. March 5, 2010 San Francisco, California

Reported by: EMI ALBRIGHT RPR, CSR No. 13042 Job No. 19676

Case 2:04-cv-08425-VAP -E Document 205-2

Filed 06/24/10 Page 3 of 5
117

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

Q position? A Q A Q A

Have you ever been fired from a

No. You ever served in the military? No. Who funds the Palm Center? We get probably 97, 98 percent of our

money from ten, plus or minus, sources that are basically stable from year to year. These include

gay rights foundations and private donors, most of whom are wealthy gay men. Q A Who funds your particular research? So my research doesn't really cost Are you

anything because it's just at a desk.

talking about the Palm Center research or the book on -Q You, Professor Belkin, if anybody

specifically funds your research -A Q A research. Sorry. -- at the Palm Center? Sorry. So I have two lines of

One is the work for the Palm Center and

the other is the book on military masculinity. The work for the Palm Center is funded through the Palm Center. And the work on military masculinity

Case 2:04-cv-08425-VAP -E Document 205-2

Filed 06/24/10 Page 4 of 5
140

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

it to the table? Q Was that your expertise on that

particular issue? A Q Reading the study. And then I believe you said

commissioning it? A No, because I helped -- I mean, I And I also

helped frame the research question. commissioned the Zogby report.

And I did not

write the questions in Zogby but I helped embed the experiment of the Miller Moradi paper in the Zogby study so that that analysis -- so that that question could be tested. Q A Q A Q Who carried out the actual testing? Miller and Moradi. Not you? Right. When you say you framed the research

question, what does that mean? A Well, because we have had all these

polls that ask service members, should Don't Ask, Don't Tell be repealed. But we have never had a

statistical study of the plausibility of the unit cohesion rationale. I thought that we could use

the Zogby poll as a way to test the plausibility

Case 2:04-cv-08425-VAP -E Document 205-2

Filed 06/24/10 Page 5 of 5
141

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

of the unit cohesion rationale.

And so in order

to set the poll up to be able to sustain that test, you had to include the right questions. had to include questions about whether someone knew a gay in their unit so you could get a measure of outness for that unit, and you had to include questions about the quality of the unit so that they could then be correlated. Q A That's what you did? I did not write the questions but it You

was my idea to have questions asking those things on the survey. Q Okay. But the actual formulation of

the questions, that was done by somebody else? A I cannot remember. I may have written

a draft of some of the questions, but the final version of the survey instrument was produced by another scholar. Q A Q Who was that? Dr. Laura Miller. And then the actual execution of the

study, that was done by Miller and Moradi? A Q A Moradi. Moradi? Yes.