AMERICAN EDUCATIONAL RESEARCH ASSOCIATION, INC. et al v. PUBLIC.RESOURCE.ORG, INC.

Filing 107

Memorandum in opposition to re #98 SEALED MOTION FOR LEAVE TO FILE DOCUMENT UNDER SEAL filed by PUBLIC.RESOURCE.ORG, INC. (This document is SEALED and only available to authorized persons.) filed by AMERICAN EDUCATIONAL RESEARCH ASSOCIATION, INC., AMERICAN PSYCHOLOGICAL ASSOCIATION, INC., NATIONAL COUNCIL ON MEASUREMENT IN EDUCATION, INC.. (Attachments: #1 Declaration of Jonathan Hudis, #2 Certificate of Service)(Hudis, Jonathan)

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UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA AMERICAN EDUCATIONAL RESEARCH ASSOCIATION, INC., AMERICAN PSYCHOLOGICAL ASSOCIATION, INC., and NATIONAL COUNCIL ON MEASUREMENT IN EDUCATION, INC., Plaintiffs, v. PUBLIC.RESOURCE.ORG, INC., Defendant. ) ) ) ) ) ) ) ) ) ) ) ) ) ) Civil Action No. 1:14-cv-00857-TSC-DAR DECLARATION OF JONATHAN HUDIS IN SUPPORT OF PLAINTIFFS’ OPPOSITION TO THE MOTIONS EMBEDDED WITHIN DEFENDANT-COUNTERCLAIMANT PUBLIC.RESOURCE.ORG’S OBJECTIONS TO PLAINTIFFS’ SUPPLEMENTAL EVIDENCE [ECF No. 98-3 (Sealed)] [ECF No. 99-4 (Redacted)] I, JONATHAN HUDIS, declare: 1. I am a partner with Quarles & Brady LLP, counsel for Plaintiffs, American Educational Research Association, Inc., American Psychological Association, Inc. and National Council on Measurement in Education, Inc. (collectively, “Plaintiffs”) in this action. 2. I make this Declaration, based upon my personal knowledge and review of relevant documents, in support of Plaintiffs’ Opposition to the Motions Embedded Within Defendant-Counterclaimant Public.Resource.Org Inc.’s Objections to Plaintiffs’ Supplemental Evidence. If called upon to do so, I would, and could, testify competently as to the information set forth herein. 3. On July 15, 2015, Plaintiffs served the rebuttal expert report of Dr. S.E. Phillips on Defendant. 4. On September 22, 2015, Defendant deposed Dr. S.E. Phillips. True and correct excerpts from the deposition transcript of Dr. S.E. Phillips are attached hereto as Exhibit 1. 5. Prior to Defendant filing the Motion to Strike the Declaration of Kurt Geisinger, counsel for Defendant, Matthew Becker, contacted me, via telephone, to meet and confer, as required by Local Civil Rule 7(m). 6. Prior to the filing of the motions embedded within Defendant’s Objections to Plaintiffs’ Supplemental Evidence on March 3, 2016, counsel for Defendant never contacted me or, to my knowledge, any of Plaintiffs’ counsel, to meet and confer, as required by Local Civil Rule 7.1(m), before the filing of those motions. I DECLARE, under the penalty of perjury, that the foregoing is true and correct. Executed on March 21, 2016, in Washington, D.C. /s/ Jonathan Hudis Jonathan Hudis 2 EXHIBIT 1 Case No. 1:14-cv-00857-TSC-DAR FILED UNDER SEAL

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