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

Filing 186

REPLY by defendants in support of #171 Rule 56(f) Motion. (Attachments: #1 Declaration of Mollie M. Lee in support of Reply #2 Exhibit A #3 Exhibit B) (Lee, Mollie) Modified on 6/18/2009 (Marciel, M).

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DENNIS J. HERRERA, SB# 139669 City Attorney WAYNE SNODGRASS, SB# 148137 MOLLIE LEE, SB# 251404 Deputy City Attorneys One Dr. Carlton B. Goodlett Place City Hall, Room 234 San Francisco, California 94102-4682 Telephone: [phone] Facsimile: [phone] E-Mail: [e-mail] Attorneys for Defendants Department of Elections - City and County of San Francisco and Dennis J. Herrera, City Attorney for the City and County of San Francisco

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA SACRAMENTO DIVISION ProtectMarriage.com - Yes on 8, a Project of California Renewal; National Organization for Marriage California - Yes on 8, Sponsored by National Organization for Marriage, John Doe #1, an individual, and as a representative of the Class of Major Donors, Plaintiffs, vs. Case No. 2:09-CV-00058-MCE-DAD

DECLARATION OF MOLLIE M. LEE IN SUPPORT OF SAN FRANCISCO DEFENDANTS' REPLY IN SUPPORT OF DEFENDANTS' RULE 56(F) MOTION

Dated: June 18, 2009 10:00 a.m. Debra Bowen, Secretary of State for the State Time: of California, in her official capacity; Edmund Courtroom: 7, 14th Floor The Honorable Morrison C. England, Jr. G. Brown, Jr., Attorney General for the State of California, in his official capacity; Dean C. Logan, Registrar-Recorder of Los Angeles Trial Date: March 14, 2011 County, California, in his official capacity; Action Filed: January 7, 2009 Department of Elections - City and County of San Francisco; Jan Scully, District Attorney for Sacramento County, California, in her official capacity and as a representative of the Class of District Attorneys in the State of California; Dennis J. Herrera, City Attorney for the City and County of San Francisco, California, in his official capacity and as a representative of the Class of Elected City Attorneys in the State of California; Ross Johnson, Timothy Hodson, Eugene Huguenin, Jr., Robert Leidigh, and Ray
DECLARATION OF MOLLIE M. LEE CASE NO. 2:09-CV-00058-MCE-DAD
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Remy, members of the California Fair Political Practices Commission, in their official capacities, Defendants.

I, Mollie M. Lee, declare as follows: 1. I am an attorney at law licensed to practice in the State of California. I am an attorney

at the Office of the San Francisco City Attorney. I have personal knowledge of the facts set forth in this declaration, and if called as a witness, I can and would testify competently thereto. 2. A true and correct copy of a newspaper article, C. Miller, "9th Circuit Backs Church

on Disclosure of Donors to Campaign Against Gay Marriage," The Recorder, February 26, 2009, is attached hereto as Exhibit A. 3. A true and correct copy of a newspaper article, B. Egelko, "Justices seem to be leaning

in favor of Prop. 8," The San Francisco Chronicle, March 6, 2009, is attached hereto as Exhibit B. I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct.

Dated: June 17, 2009 By: MOLLIE LEE /s/

Attorneys for Defendants DEFENDANTS DEPARTMENT OF ELECTIONS ­ CITY AND COUNTY OF SAN FRANCISCO AND DENNIS J. HERRERA

DECLARATION OF MOLLIE M. LEE CASE NO. 2:09-CV-00058-MCE-DAD
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