American Freedom Defense Initiative et al v. Suburban Mobility Authority For Regional Transportation (SMART) et al

Filing 55

MOTION for Summary Judgment by Beth Gibbons, John Hertel, Suburban Mobility Authority For Regional Transportation (SMART). (Attachments: # 1 Index of Exhibits, # 2 Exhibit A, # 3 Exhibit B, # 4 Exhibit C, # 5 Exhibit D, # 6 Exhibit E, # 7 Exhibit F, # 8 Exhibit G, # 9 Exhibit H, # 10 Exhibit I, # 11 Exhibit J, # 12 Exhibit K, # 13 Exhibit L, # 14 Exhibit M, # 15 Exhibit N, # 16 Exhibit O, # 17 Exhibit P, # 18 Exhibit Q, # 19 Exhibit R, # 20 Exhibit S) (Hildebrandt, Christian)

UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF MICHIGAN
SOUTHERN DIVISION
AMERICAN FREEDOM DEFENSE
INITIATIVE, PAMELA GELLER, and
ROBERT SPENCER,
Plaintiffs,
Case 2:10-cv-12134
HON. DENISE PAGE HOOD

v.
SUBURBAN MOBILITY AUTHORITY
FOR REGIONAL TRANSPORTATION
(“SMART”); GARY L. HENDRICKSON,
Individually and in his official capacity as
Chief Executive of SMART, JOHN HERTEL,
Individually and in his official capacity as
General Manager of SMART and BETH
GIBBONS, individually and in her official
Capacity as Marketing Program Manager
Of SMART,

INDEX OF EXHIBITS DEFENDANTS’ MOTION FOR
SUMMARY JUDGMENT PURSUANT
TO Fed.R.Civ.P. 56

Defendants.
Robert J. Muise (P62849)
David Yerushalmi, Esq. (Arz. 009616; DC
978179, Cal. 132011; NY 4632568)
Counsel for Plaintiffs
3000 Green Rd., #131098
Ann Arbor, MI 48113
[phone]
[e-mail]
[e-mail]

Avery E. Gordon (P41194)
Anthony Chubb (P72608)
Co-Counsel for Defendants SMART, Hertel
and Gibbons
535 Griswold Street, Suite 600
Detroit, MI 48226
[phone]
[e-mail]
[e-mail]

Erin Elizabeth Mersino (P70886)
Co-Counsel for Plaintiffs
24 Frank Lloyd Wright Drive
P.O. Box 393
Ann Arbor, MI 48106
[phone] [e-mail]

John J. Lynch (P16887)
Christian E. Hildebrandt (P46989)
Co-Counsel for Defendants SMART, Hertel
and Gibbons
1450 W. Long Lake Road, Suite 100
Troy, MI 48098
[phone]
[e-mail]
[e-mail]

INDEX OF EXHIBITS

A

SMART’s Advertising Guidelines

B

Hurting after Abortion? Jesus, I Trust in You Ad

C

Red Dead Redemption Ad

D

Plaintiffs’ “Fatwa on your head? Is your family or community threatening you? LEAVING
ISLAM? Got Questions? Get Answers! RefugeFromIslam.com” Ad

E

Affidavit of Robert Hawkins

F

Affidavit of Beth Gibbons

G

Transcript of Deposition of Beth Gibbons taken June 25, 2013

H

RefugeFromIslam.com, post titled “THIS IS AMERICA, LAND OF THE FREE AND
HOME OF THE APOSTATES”

I

Complaint

J

District Court Order granting Plaintiffs’ Motion for Preliminary Injunction

K

US Court of Appeals for the Sixth Circuit AFDI v SMART Opinion

L

SMART web site page

M

DetroitCOR “Don’t believe in God?” Ad

N

Transcript of Deposition of Anthony Chubb (SMART 30(b)(6) witness taken May 21,
2013

O

Transcript of Deposition of Pamela Geller taken May 9, 2013

P

Articles of Agreement of American Freedom Defense Initiative

Q

Plaintiffs’ Shariah: Got Fatwa? Get Help! Ad

R

New York Times Newt Gingrich article referred to by Sixth Circuit

S

The Truth about Muhammad website