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

Filing 33

DECLARATION of John Doe #2 in SUPPORT OF #16 MOTION for PRELIMINARY INJUNCTION. (Attachments: #1 Exhibit A)(Chandler, Timothy)

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

Doc. 33

John Doe #2
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James Bopp, Jr. (Ind. State Bar No. 2838-84)* 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, Indiana 47807-3510 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, California 95630 Telephone: [phone] Facsimile: [phone] Counsel for All Plaintiffs * Pro Hac Vice Application Pending ** Designated Counsel for Service

United States District Court Eastern District of California

Case No. 2:09-CV-00058-MCE-DAD ProtectMarriage.com, et al., Plaintiffs, v. Debra Bowen, et al., Defendants. DECLARATION OF REDACTED REDACTED IN SUPPORT OF PLAINTIFFS' MOTION FOR PRELIMINARY INJUNCTION Date: TBD Time: TBD Judge England

Decl. of

REDACTED

in Support of Plaintiffs' Motion for Preliminary Injunction 1
Dockets.Justia.com

John Doe #2
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I,

REDACTED

, make the following declaration pursuant to 28 U.S.C. § 1746:

1. I am a resident of the state of California 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 the passage of Proposition 8, I made two donations totaling $X,XXX to ProtectMarriage.com ­ Yes on 8. 4. In support of the passage of Proposition 8, I also placed a "Yes on 8" bumper-sticker on my car. 5. On Saturday, November XX , 2008, a flyer was distributed in the town of
REDACTED

, California,

where I reside. Under a large headline reading, "Bigot," the flyer had a picture of me, as well as listing my name, the fact that I am a
REDACTED

at

REDACTED

Catholic Church, and that I contributed $X,XXX in

support of Proposition 8. A true and correct copy of this flyer is attached as Exhibit A. 6. To my knowledge, no one outside of my family was aware of my financial contribution to ProtectMarriage.com ­ Yes on 8, so the only way that the person who made this flyer could have known about it is through the state's public disclosure of such donations. 7. Because of this incident, which I believe occurred because of my support of Proposition 8, I would be less likely to donate to a similar cause in the future. I DECLARE UNDER PENALTY OF PERJURY THAT THE FOREGOING IS TRUE AND CORRECT. Executed on

REDACTED

Signature Redacted
REDACTED

Decl. of

REDACTED

in Support of Plaintiffs' Motion for Preliminary Injunction 2

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PROOF OF SERVICE I, Timothy D. Chandler, am over the age of 18 years and not a party to the within action. My business address is 101 Parkshore Drive, Suite 100; Folsom, California 95630. On January 15, 2009, I electronically filed the foregoing document described as Declaration of John Doe #2 in Support of Plaintiffs' Motion for Preliminary Injunction, with the Clerk of Court using the CM/ECF system which will send notification of such filing to: Zackery Paul Morazzini [e-mail] Attorney for Defendants Debra Bowen and Edmund C. Brown, Jr. And, pursuant to Rule 5-135(f), on January 15, 2009, I served the foregoing document described as Declaration of John Doe #2 in Support of Plaintiffs' Motion for Preliminary Injunction by placing true and correct copies of the documents in sealed envelopes with postage thereon fully prepaid, in the United States mail at Folsom, California, addressed to the following non-CM/ECF participants: Dean C. Logan Office of the Registrar-Recorder 12400 Imperial Highway Norwalk, California 90650 Department of Elections, City and County of San Francisco c/o Office of the Mayor Gavin Newsom 1 Dr. Carlton B. Goodlett Place San Francisco, California 94102 Jan Scully Office of the District Attorney 901 G Street Sacramento, California 95814 Eileen Teichert Office of the City Attorney New City Hall Building 915 I Street, 4th Floor Sacramento, California 95814 Ross Johnson California Fair Political Practices Commission 428 J. Street, Suite 620 Sacramento, California 95814

Decl. of John Doe #2 in Support of Plaintiffs' Motion for Preliminary Injunction 3

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Timothy Hodson California Fair Political Practices Commission 428 J. Street, Suite 620 Sacramento, California 95814 Eugene Huguenin, Jr. California Fair Political Practices Commission 428 J. Street, Suite 620 Sacramento, California 95814 Robert Leidigh California Fair Political Practices Commission 428 J. Street, Suite 620 Sacramento, California 95814 and Ray Remy California Fair Political Practices Commission 428 J. Street, Suite 620 Sacramento, California 95814 Defendants

I declare under penalty of perjury under the laws of the State of California that the above is true and correct. Executed on January 15, 2009 at Folsom, California. s/Timothy D. Chandler Timothy D. Chandler (CA Bar No. 234325) Attorney for Plaintiff

Decl. of John Doe #2 in Support of Plaintiffs' Motion for Preliminary Injunction 4