AMERICAN SOCIETY FOR TESTING AND MATERIALS et al v. PUBLIC.RESOURCE.ORG, INC.

Filing 67

Memorandum in opposition to re #64 First MOTION to Compel Public Resource.Org, Inc. Discovery filed by PUBLIC.RESOURCE.ORG, INC.. (Attachments: #1 Declaration of Kathleen Lu In Support of Defendant-Counterclaimant Public.Resource.Org, Inc.'s Opposition to Plaintiff-Counterdefendant American Society for Testing and Materials d/b/a ASTM International Motion to Compel Discovery, #2 Declaration of John Doe In Support of Defendant-Counterclaimant Public.Resource.Org, Inc.'s Response to Plaintiffs' Motion to Compel Discovery, #3 Declaration of Carl Malamud In Support of Defendant-Counterclaimant Public.Resource.Org, Inc.'s Response to Plaintiffs' Motion to Compel Discovery)(Bridges, Andrew)

IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
AMERICAN SOCIETY FOR TESTING AND
MATERIALS d/b/a ASTM INTERNATIONAL;
NATIONAL FIRE PROTECTION
ASSOCIATION, INC.; and
AMERICAN SOCIETY OF HEATING,
REFRIGERATING, AND AIR CONDITIONING
ENGINEERS,
Plaintiffs-Counterdefendants,

Case No. 1:13-cv-01215-TSC-DAR
DECLARATION OF JOHN DOE IN
SUPPORT OF DEFENDANTCOUNTERCLAIMANT
PUBLIC.RESOURCE.ORG, INC.’S
RESPONSE TO PLAINTIFFS’
MOTION TO COMPEL DISCOVERY
Filed:

August 6, 2013

v.
PUBLIC.RESOURCE.ORG, INC.,
Defendant-Counterclaimant.
Using the pseudonym John Doe, instead of my actual name, in order to protect my
identity pursuant to my rights under the First Amendment, I declare as follows:
1. I have personal knowledge of all matters set forth in this declaration.
2. I am providing this declaration under a pseudonym because I wish to protect my
rights to free speech and participation in associational activities. A true and
correct copy of my actual signature for this document resides with my attorneys.
3. Through a charitable foundation, I have donated substantial funds to Public
Resource to support its activities. I gave these funds with the wish and expectation
that my contribution would remain anonymous.
4. I have expressed to Carl Malamud, Public Resource’s president, my wish that my
contributions remain anonymous.

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