Perry et al v. Schwarzenegger et al

Filing 340

Declaration of Ethan D. Dettmer in Support of #339 First MOTION to Compel filed byPaul T. Katami, Kristin M. Perry, Sandra B. Stier, Jeffrey J. Zarrillo. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C, #4 Exhibit D, #5 Exhibit E, #6 Exhibit F, #7 Exhibit G, #8 Exhibit H, #9 Exhibit I, #10 Exhibit J, #11 Exhibit K)(Related document(s) #339 ) (Boutrous, Theodore) (Filed on 1/4/2010)

Perry et al v. Schwarzenegger et al

Doc. 340 Att. 8

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Exhibit I

Dockets.Justia.com

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vs.

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA

KRISTIN M. PERRY, SANDRA B. STIER, PAUL T. KATAMI, JEFFREY J. ZARRILLO, Plaintiffs,

ARNOLD SCHWARZENEGGER, in his official 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,

) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) )

No. 09-CV-2292 VRW

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and PROPOSITION & 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 MARK A. JANSSON Folsom, California Thursday, December 3, 2009

REPORTED BY: YVONNE FENNELLY, CSR NO. 5495 California Certified Realtime Reporter FILE NO.: Pages 1 - 304 35818

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Q.

And who were the four members of the

executive committee for ProtectMarriage.com - Yes on 8 during 2008? MS. MOSS: To the extent that the response

to that question would require you to reveal the identity of any anonymous members of the executive committee, I would instruct you not to provide that information, but you can provide any publically-available information. THE WITNESS: myself, and John Doe. BY MR. UNO: Q. Was Mr. Pugno a member of the Ron Prentice, Ned Dolejsi,

ProtectMarriage.com - Yes on 8 executive committee in 2008? A. Q. He was our legal counsel. He was legal counsel to the executive

committee -- sorry. Was Mr. Pugno legal counsel to the executive committee of ProtectMarriage.com - Yes on 8 during 2008? A. Q. Yes. Is there a distinction between Mr. Pugno

being legal counsel to the executive committee of ProtectMarriage.com - Yes on 8 during 2008 and his

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STATE OF CALIFORNIA COUNTY OF CONTRA COSTA

I, YVONNE FENNELLY, hereby certify that the witness in the foregoing deposition was by me duly affirmed to testify to the truth, the whole truth and nothing but the truth, in the within-entitled cause; that said deposition was taken at the time and place herein named; that the deposition is a true record of the witness's testimony as reported to the best of my ability, by me, a duly Certified Shorthand Reporter and disinterested person, and was thereafter transcribed under my direction into typewriting by computer; that the witness was given an opportunity to read, correct and sign the deposition. I further certify that I am not interested in the outcome of said action nor connected with nor related to any of the parties in said action nor to their respective counsel.

YVONNE FENNELLY, CCRR, CSR No. 5495