Public.Resource.org v. United States Internal Revenue Service
Filing
50
Declaration of Scott Klein in Support of 47 MOTION for Summary Judgment Plaintiff Public.Resource.Org's Consolidated Cross-Motion for Summary Judgment and Opposition to Defendant's Motion for Summary Judgment filed byPublic.Resource.org. (Related document(s) 47 ) (Burke, Thomas) (Filed on 9/29/2014)
1
2
3
4
5
6
7
8
9
DAVIS WRIGHT TREMAINE LLP
10
11
12
13
14
15
THOMAS R. BURKE (CA State Bar No. 141930)
DAVIS WRIGHT TREMAINE LLP
505 Montgomery Street, Suite 800
San Francisco, California 94111
Telephone:
(415) 276-6500
Facsimile:
(415) 276-6599
Email:
thomasburke@dwt.com
RONALD G. LONDON (Pro Hac Vice)
DAVIS WRIGHT TREMAINE LLP
1919 Pennsylvania Ave., N.W., Suite 800
Washington, DC 20006
Telephone:
(202) 973-4200
Email:
ronnielondon@dwt.com
DAVID HALPERIN (Pro Hac Vice)
1530 P Street NW
Washington, DC 20005
Telephone:
(202) 905-3434
Email:
davidhalperindc@gmail.com
DAN LAIDMAN (State Bar No. 274482)
DAVIS WRIGHT TREMAINE LLP
865 South Figueroa Street, Suite 2400
Los Angeles, CA 90017-2566
Telephone:
(213) 633-6800
Facsimile:
(213) 633-6899
Email:
danlaidman@dwt.com
Attorneys for Plaintiff Public.Resource.Org
16
17
IN THE UNITED STATES DISTRICT COURT
18
THE NORTHERN DISTRICT OF CALIFORNIA
19
SAN FRANCISCO DIVISION
20
21
22
23
24
25
26
PUBLIC.RESOURCE.ORG., a California non- ) Case No. 3:13-CV-02789-WHO
profit organization,
)
)
Plaintiff,
) DECLARATION OF SCOTT KLEIN
)
v.
)
)
UNITED STATES INTERNAL REVENUE
)
SERVICE,
)
)
Defendant.
)
27
28
1
Declaration of Scott Klein
DWT 24875494v1 0200593-000001
1
I, Scott Klein, declare as follows:
2
1.
Since 2008, I have worked for ProPublica, where I am an Assistant Managing
3
Editor. From 1998 to 2008, I worked in several capacities at The Nation. I have personal
4
knowledge of the matters stated in this declaration and could competently testify to them if called
5
as a witness.
6
2.
ProPublica is a nonprofit news organization that produces investigative journalism
7
in the public interest. ProPublica was awarded the 2011 Pulitzer Prize for National Reporting, a
8
2010 Pulitzer Prize for Investigative Reporting and a Peabody Award (the highest honor in
9
broadcast journalism) in 2013. ProPublica can be found at http://www.propublica.org/.
DAVIS WRIGHT TREMAINE LLP
10
3.
From 2009 through 2011, I also served as President and Co-founder of
11
DocumentCloud. DocumentCloud is an online service that helps journalists work with primary
12
source documents. DocumentCloud is now used by more than 900 newsrooms around the world
13
and contains 17 million pages of documents, including many instances of the Form 990.
14
DocumentCloud may be found at http://www.documentcloud.org/home.
15
4.
We were able to create DocumentCloud after being awarded a grant from the John
16
S. and James L. Knight Foundation, as a winner of a competition called the Knight News
17
Challenge, which is designed to accelerate media innovation by funding breakthrough ideas. The
18
Knight News Challenge can be found at https://www.newschallenge.org/.
19
5.
At ProPublica, we make extensive use of the Form 990 in researching stories. We
20
have also created an interactive database called “Nonprofit Explorer,” which allows individuals to
21
quickly search over 1.1 million Form 990s. The Nonprofit Explorer can be found at
22
http://projects.propublica.org/nonprofits/.
23
6.
Lack of availability of the Form 990 in machine-processable formats, that is in
24
Modernized e-File (MeF) format instead of a scanned document or other bitmap format, is a
25
substantial impediment in our work. With scanned and bitmap images, reporters must leaf
26
through the Form 990s by hand and then re-enter data into analysis tools such as a database
27
management system or a spreadsheet program.
28
2
Declaration of Scott Klein
DWT 24875494v1 0200593-000001
1
7.
While Optical Character Recognition (OCR) is used in systems such as
2
DocumentCloud to recognize text in documents, OCR is a slow and cumbersome process and is
3
subject to errors. This is particularly true with low-resolution bitmap images, such as those
4
released for the Form 990.
5
8.
Availability of returns in MeF format would permit our programmers and
6
journalists to easily, accurately, and systematically put information from the Form 990 into
7
analysis tools. Availability of returns in MeF format would make it much easier for ProPublica
8
and all journalists to report on a single nonprofit as well as to write stories that systematically
9
examine a large number of returns.
DAVIS WRIGHT TREMAINE LLP
10
11
12
13
I declare under penalty of perjury under the laws of the United States that the foregoing is
true and correct and that this declaration was executed this 23rd day of September, 2014 at New
York, N.Y.
/s/ Scott Klein
SCOTT KLEIN
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
3
Declaration of Scott Klein
DWT 24875494v1 0200593-000001
Disclaimer: Justia Dockets & Filings provides public litigation records from the federal appellate and district courts. These filings and docket sheets should not be considered findings of fact or liability, nor do they necessarily reflect the view of Justia.
Why Is My Information Online?