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

Filing 91

RESPONSE re #67 MOTION to Strike #66 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.) (Plaintiffs' Opposition to Defendant's Motion to Strike the Declaration of Kurt F. Geisinger) 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 Exhibit 1, #3 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
DEFENDANT’S MOTION TO STRIKE
THE DECLARATION OF KURT F.
GEISINGER

I, JONATHAN HUDIS, declare:
1.

I am an attorney with Quarles & Brady LLP, attorneys for Plaintiffs, American

Educational Research Association, Inc., American Psychological Association, Inc. and National
Council on Measurement in Education, Inc. Unless otherwise stated, I have knowledge of all
facts set forth in this declaration, and I would, and could, testify competently thereto if called
upon to do so.
2.

I submit this Declaration in support of Plaintiffs’ Opposition to Defendant’s

Motion to Strike the Declaration of Kurt F. Geisinger.
3.

Attached as Exhibit 1 is a true and correct copy of the deposition transcript of

Kurt F. Geisinger, taken on September 10, 2015.
I declare under the penalty of perjury that the foregoing is true and correct.
Executed on February 18, 2016, in Washington, D.C.
/s/ Jonathan Hudis
Jonathan Hudis