SHERLEY et al v. SEBELIUS et al

Filing 3

MOTION for Preliminary Injunction by WILLIAM FLYNN, PATRICIA FLYNN, CHRISTIAN MEDICAL ASSOCIATION, JAMES L. SHERLEY, THERESA DEISHER, NIGHT-LIGHT CHRISTIAN ADOPTIONS, SHAYNE NELSON, TINA NELSON (Attachments: # 1 Memorandum in Support, # 2 Declaration Bradley J. Lingo, # 3 Bradley J. Lingo Exhibit A, # 4 Bradley J. Lingo Exhibit B, # 5 Bradley J. Lingo Exhibit C, # 6 Bradley J. Lingo Exhibit D, # 7 Declaration Dr. James Sherley, # 8 Declaration Dr. Theresa Deisher, # 9 Declaration Ronald L. Stoddart, # 10 Declaration Mrs. Tina Nelson, # 11 Declaration William T. Flynn)(rdj)

SHERLEY et al v. SEBELIUS et al

Doc. 3 Att. 2

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA DR. JAMES L. SHERLEY; DR. THERESA DEISHER; NIGHTLIGHT CHRISTIAN ADOPTIONS, individually and as next friend for PLAINTIFF EMBRYOS; SHAYNE AND TINA NELSON; WILLIAM AND PATRICIA FLYNN; CHRISTIAN MEDICAL ASSOCIATION, Plaintiffs, v. KATHLEEN SEBELIUS, in her official capacity as Secretary of the Department of Health and Human Services; DEPARTMENT OF HEALTH AND HUMAN SERVICES; DR. FRANCIS S. COLLINS, in his official capacity as Director of the National Institutes of Health; NATIONAL INSTITUTES OF HEALTH, Defendants. ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) )

Civil Action No. ____

DECLARATION OF BRADLEY J. LINGO I, Bradley J. Lingo, declare as follows: 1. I am an associate in the law firm of Gibson, Dunn & Crutcher LLP, counsel of

record for the plaintiffs in this case and a member of the bar of this Court. I am over the age of eighteen and am competent to testify. I am knowledgeable about the facts set forth herein and make this declaration in support of plaintiffs' Motion for Preliminary Injunction. 2. Attached as Exhibit A is a true and correct copy of the National Institutes of

Health Guidelines for Human Stem Cell Research, 74 Fed. Reg. 32,170 (July 7, 2009). 3. Attached as Exhibit B is a true and correct copy of the Comments of Do No

Harm: The Coalition of Americans for Research Ethics, molecular biologists and stem cell

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