Perry et al v. Schwarzenegger et al

Filing 314

NOTICE by Martin F. Gutierrez, Dennis Hollingsworth, Mark A. Jansson, Gail J. Knight, ProtectMarriage.com - Yes on 8, A Project of California Renewal, Hak-Shing William Tam of Filing of Privilege Log (Attachments: #1 Exhibit, #2 Exhibit, #3 Exhibit, #4 Exhibit, #5 Exhibit)(Cooper, Charles) (Filed on 12/21/2009)

Perry et al v. Schwarzenegger et al

Doc. 314 Att. 1

Case3:09-cv-02292-VRW Document314-2

Filed12/21/09 Page1 of 3

Exhibit 2

Dockets.Justia.com

Case3:09-cv-02292-VRW Document314-2
Hak-Shing William Tam

Filed12/21/09 Page2 of 3
December 1, 2009

San Francisco, CA Page 1

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UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA _________________________________________________ KRISTIN M. PERRY, SANDRA B. STIER, PAUL ) T. KATAMI, and JEFFREY J. ZARRILLO, ) Plaintiffs, ) Case No. vs. ) 09-CV-2292 ARNOLD SCHWARZENEGGER, in his official ) VRW capacity as Governor of California; ) EDMUND G. BROWN, JR., in his official ) capacity as Attorney General of ) California, MARK B. HORTON, in his ) official capacity as Director of the ) California Department of Public Health ) and State Registrar of Vital Statistics; ) LINETTE SCOTT, in her official capacity ) as Deputy Director of Health Information ) & Strategic Planning for the California ) Department of Public Health; PATRICK ) O'CONNELL, in his official capacity as ) Clerk-Recorder for the County of Alameda; ) and DEAN C. LOGAN, in his official ) capacity as Registrar-Recorder/County ) Clerk for the County of Los Angeles, ) Defendants. ) and ) PROPOSITION 8 OFFICIAL PROPONENTS DENNIS ) HOLLINGSWORTH, GAIL J. KNIGHT, MARTIN F. ) GUTIERREZ, HAKSHING WILLIAM TAM, and MARK ) A. JANSSON; and PROTECTMARRIAGE.COM - YES ) ON 8, A PROJECT OF CALIFORNIA RENEWAL, ) Defendant-Intervenors. ) _________________________________________________ DEPOSITION OF HAK-SHING WILLIAM TAM December 1, 2009 San Francisco, California Reported by: EMI ALBRIGHT RPR, CSR No. 13042

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Case3:09-cv-02292-VRW Document314-2 Hak-Shing William Tam

Filed12/21/09 Page3 of 3 December 1, 2009

San Francisco, CA
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day would not come.

The choice is yours.

Talk to

the leaders of your church.

Your actions would

change the history in either direction. Do you see that paragraph there? A Q Yes. Do you believe that to be true? MS. MOSS: not to answer. A No answer. I object and instruct you

BY MR. DETTMER: Q Okay. Was your goal in writing this

letter to encourage people to raise funds for passing Proposition 8? MS. MOSS: I am going to -- again I am

going to object to the extent that you are asking him about a document that he has specifically said was intended for private communication. going to instruct him not to answer. A No answer. And I am

BY MR. DETTMER: Q Was your goal in writing this letter to

encourage people to vote in favor of Proposition 8? MS. MOSS: instruction. Same objection. Same

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