AMERICAN EDUCATIONAL RESEARCH ASSOCIATION, INC. et al v. PUBLIC.RESOURCE.ORG, INC.
MOTION to Strike #60 the declaration of Kurt P. Geisinger by PUBLIC.RESOURCE.ORG, INC. (Attachments: #1 Memorandum in Support of Defendant-Counterclaimant Public.Resource.Orgs Motion to Strike [PUBLIC], #2 Declaration of Matthew Becker [PUBLIC], #3 Exhibit 1 (Filed Under Seal), #4 Exhibit 2 (Filed Under Seal), #5 Exhibit 3, #6 Exhibit 4, #7 Exhibit 5, #8 Exhibit 6 (Filed Under Seal), #9 Exhibit 7 (Filed Under Seal), #10 Exhibit 8, #11 Exhibit 9, #12 Exhibit 10, #13 Exhibit 11, #14 Exhibit 12, #15 Exhibit 13, #16 Exhibit 14, #17 Exhibit 15, #18 Exhibit 16, #19 Text of Proposed Order, #20 Certificate of Service)(Bridges, Andrew) Modified on 1/21/2016 linkage and text(td).
UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
AMERICAN EDUCATIONAL RESEARCH
ASSOCIATION, INC., AMERICAN
PSYCHOLOGICAL ASSOCIATION, INC., and
NATIONAL COUNCIL ON MEASUREMENT IN
Case No. 1:14-CV-00857-TSC-DAR
DECLARATION OF MATTHEW
BECKER IN SUPPORT OF
MOTION TO STRIKE ECF NO. 60-88,
THE DECLARATION OF KURT F.
GEISINGER IN SUPPORT OF
PLAINTIFFS’ MOTION FOR
SUMMARY JUDGMENT AND
Action Filed: May 23, 2014
I, Matthew Becker, declare pursuant to 28 U.S.C. § 1746 as follows:
I am an attorney admitted to practice in the District of Columbia and am an
associate with the law firm of Fenwick & West LLP, counsel of record for DefendantCounterclaimant Public.Resource.Org, Inc. (“Public Resource”). Except where otherwise
indicated, I have personal knowledge of the facts herein and could and would testify competently
Attached as Exhibit 1 is a true and correct copy of excerpts of the deposition of
Kurt F. Geisinger, dated September 10, 2015.
Attached as Exhibit 2 is a true and correct copy of excerpts of the deposition of
Felice Levine’s deposition, dated May 4, 2015.
Attached as Exhibit 3 is a true and correct copy of Kurt F. Geisinger’s Expert
Report in this matter, dated June 10, 2015.
Attached as Exhibit 9 is a true and correct copy of the website
ion)/tabid/15578/Default.aspx (last visited January 21, 2015).
Attached as Exhibit 10 is a true and correct copy of the website containing the
text of the 2012 State of the Union Address at https://www.whitehouse.gov/the-pressoffice/2012/01/24/remarks-president-state-union-address (last visited January 21, 2015).
Attached as Exhibit 11 is a true and correct copy of the website containing a
White House announcement concerning State waivers to the No Child Left Behind law at
https://www.whitehouse.gov/blog/2012/02/09/everything-you-need-know-waivers-flexibilityand-reforming-no-child-left-behind (last visited January 21, 2015).
Attached as Exhibit 12 is a true and correct copy of a Washington Post article
concerning criticism of high-stakes testing, at https://www.washingtonpost.com/blogs/answersheet/post/national-resolution-against-high-stakes-testsreleased/2012/04/23/gIQApRnNdT_blog.html (last visited January 21, 2015).
Attached as Exhibit 13 is a true and correct copy of an article from FairTest.org
concerning resistance to high-stakes testing, at http://www.fairtest.org/resistance-high-stakestesting-spreads (last visited January 21, 2015).
Attached as Exhibit 14 is a true and correct copy of an online order form of a
compilation of California Statutes sold by Lexis Nexis, at
ucts&prodId=10291 (last visited January 21, 2015).
Attached as Exhibit 15 is a true and correct copy of the amazon.com listing for
Code of Federal Regulations, Title 38, Pensions, Bonuses, and Veterans' Relief, Pt. 0-17,
Revised as of July 1, 2015 http://www.amazon.com/Federal-Regulations-Pensions-BonusesVeterans/dp/0160929229/ref=sr_1_15?s=books&ie=UTF8&qid=1453340653&sr=1-15 (last
visited January 21, 2015).
Attached as Exhibit 16 is a true and correct copy of a website listing prices for
books in Barnes & Noble Classics series, at http://www.barnesandnoble.com/b/barnes-nobleclassics/fiction-literature-classics/american-fiction-literature-classics/_/N-rqvZ11hj (last visited
January 21, 2015).
I declare under penalty of perjury under the laws of the United States that the foregoing is
true and correct.
Executed this 21st day of January, 2016 at San Francisco, California.
/s/ Matthew Becker
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