Evenflow, Inc. v. Domains by Proxy, Inc.

Filing 450

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Evenflow, Inc. v. Domains by Proxy, Inc. Doc. 450 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 LAW OFFICE OF TERRY L. THOMPSON Terry L. Thompson (CA Bar No. 199870) tl_thompson@earthlink.net P.O. Box 1346, Alamo, CA 94507 Telephone: (925) 855-1507, Facsimile: (925) 820-6034 ATTORNEY FOR DEFENDANT-INTERVENOR HAK-SHING WILLIAM TAM UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA KRISTIN M. PERRY, SANDRA B. STIER, PAUL CASE NO. 09-CV-2292 VRW T. KATAMI, and JEFFREY J. ZARRILLO, Plaintiffs, CITY AND COUNTY OF SAN FRANCISCO, Plaintiff-Intervenor, v. 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, 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, DECLARATION OF TERRY L. THOMPSON IN SUPPORT OF REPLY BRIEF Courtroom: 6, 17th Floor Judge: Chief Judge Vaughn R. Walker Trial Date: January 11, 2010 Action Filed: May 22, 2009 DECLARATION OF TERRY L. THOMPSON IN SUPPORT OF REPLY BRIEF CASE NO. 09-CV-2292 VRW Dockets.Justia.com 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 I, Terry L. Thompson, hereby declare: 1. I am the attorney representing Hak-Shing William Tam (Dr. Tam), one of the Proposition 8 Official Proponent Defendant-Intervenors in the subject case. 2. I have personal knowledge of the matters set forth herein and, if called on to testify, I could and would competently testify thereto. 3. On January 13, 2010 I e-mailed Ethan Dettmer, counsel for Plaintiffs confirming that Dr. Tam would be in Court available to testify on Friday, January 15, 2010. Attached hereto as Exhibit A is a true and correct copy of that e-mail chain. 4. Dr. Tam received a subpoena from Plaintiffs on January 8, 2010, to appear in this case. Attached hereto as Exhibit B, is Dr. Tam's signed "Acknowledgement of Service of Civil Subpoena and Agreement to Appear", which was attached to the aforementioned subpoena. 5. On January 12, 2010 I e-mailed Ethan Dettmer, counsel for Plaintiffs confirming that Dr. Tam's supplemental production of documents ordered by the court on January 8, 2010 will be included in the Proponents' rolling production, which was started on January 10, 2010 and will be completed by January 17, 2010. Attached hereto as Exhibit C is a true and correct copy of that e-mail chain. I declare under penalty of perjury under the laws of the United States of America that the foregoing is true and correct. Executed on January 13, 2010, at Alamo, California. s/Terry L. Thompson Terry L. Thompson 1 DECLARATION OF TERRY L. THOMPSON IN SUPPORT OF REPLY BRIEF CASE NO. 09-CV-2292 VRW

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