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)
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.
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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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