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

Filing 122

DECLARATION of John Doe #19 in SUPPORT OF #110 MOTION for SUMMARY JUDGMENT. (Bieniek, Scott)

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

Doc. 122

John Doe #19
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: [phone] Facsimile: [phone] Counsel for All Plaintiffs Benjamin W. Bull (Ariz. State Bar No. 009940)* ALLIANCE DEFENSE FUND 15100 North 90th Street Scottsdale, Arizona 85260 Telephone: [phone] Facsimile: [phone] Counsel for All Plaintiffs Timothy D. Chandler (Cal. State Bar No. 234325)** ALLIANCE DEFENSE FUND 101 Parkshore Drive, Suite 100 Folsom, CA 95630 Telephone: [phone] Facsimile: [phone] 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 #19
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 Louisiana 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 gave $X,XXX to National Organization for Marriage California - Yes on 8, sponsored by National Organization for Marriage. 4. Shortly after the passage of Proposition 8 in November 2008, a few of my colleagues informed me that an email had been sent to the
REDACTED

, my colleagues, and the alumni

director from an alumna living in Georgia. The alumna stated that he would no longer contribute to the 8. 5. If I was still employed as an untenured professor, this email may well have intimidated me. However, even though I retired as a chaired full professor, I still find this email irritating. 6. I have had political opponents in other causes, but I have never seen political opponents act so out of bounds as the opponents of Proposition 8 have acted. 7. In the future, I will think twice about supporting a cause similar to Proposition 8, because my son lives and works in San Francisco, California with my two granddaughters, and I worry that someone could go after them. I DECLARE UNDER PENALTY OF PERJURY THAT THE FOREGOING IS TRUE AND CORRECT.
REDACTED

, because he had read my name on a list of donors to Proposition

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 #19 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 [e-mail] Attorney for Defendants Debra Bowen and Edmund G. Brown, Jr. Judy W. Whitehurst [e-mail] Attorney for Defendant Dean C. Logan Terence J. Cassidy [e-mail] Attorney for Defendant Jan Scully Mollie M. Lee [e-mail] Attorney for Defendants Dennis J. Herrera and Department of Elections - City and Count of San Francisco Lawrence T. Woodlock [e-mail] 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 #19 in Support of Plaintiffs' Motion for Summary Judgment