Righthaven LLC v. Democratic Underground, LLC et al

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DECLARATION of KURT OPSAHL re 44 Response to Motion, 46 Response to Motion, 45 Brief, ; IN SUPPORT OF OPPOSITION TO PLAINTIFF'S MOTION FOR VOLUNTARY DISMISSAL, MOTION FOR SUMMARY JUDGMENT, AND OPPOSITION TO MOTION TO DISMISS AND JOINDER by Defendants David Allen, Democratic Underground, LLC, Counter Claimant Democratic Underground, LLC. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E, # 6 Exhibit F, # 7 Exhibit G, # 8 Exhibit H, # 9 Exhibit I, # 10 Exhibit J, # 11 Exhibit K, # 12 Exhibit L)(Pulgram, Laurence)

Righthaven LLC v. Democratic Underground, LLC et al

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U.S. SENATE RACE: Tea Party power fuels Angle - News - ReviewJournal.com

12/6/10 12:13 PM

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May. 13, 2010 Copyright © Las Vegas Review-Journal

U.S. SENATE RACE: Tea Party power fuels Angle
Ex-Reno assemblywoman moves up in crowded GOP primary field
By LAURA MYERS LAS VEGAS REVIEW-JOURNAL

Tea Party Elections Opinion Polls

Fueled by a burst of support from the Tea Party, Sharron Angle has rocketed into a near dead heat with Sue Lowden in the white-hot U.S. Senate Republican primary, according to a new poll commissioned by the Las Vegas Review-Journal. Lowden, who had been the Republican front-runner since February, lost support to Angle, the former Reno assemblywoman seen by likely Republican voters as the most conservative candidate in a contest in which three-quarters of Republican voters say they're somewhat or very conservative, the poll showed. Danny Tarkanian lost ground to Angle, too. She passed him after gaining a bit of political star power and a bunch of financial support from an endorsement by the Tea Party Express, which launched radio and TV ads to help her win the GOP nomination to face U.S. Sen. Harry Reid in the fall. All three top GOP candidates are capable of beating Reid, according to previous polls that have shown the Democratic Party incumbent in an uphill battle Sponsored Links to win a fifth Senate term on BREAKING: $700 Apple iPad sold for $25? Nov. 2.
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Republican candidate for U.S. Senate Sue Lowden speaks out Wednesday on behalf of local subcontractors. Lowden, a front-runner for the GOP nomination to challenge Democrat Sen. Harry Reid, is losing ground to Republican candidate Sharron Angle, a former assemblywoman. JASON BEAN/LAS VEGAS REVIEW-JOURNAL

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U.S. SENATE RACE: Tea Party power fuels Angle - News - ReviewJournal.com
primary and Cambridge Researchers have developed an also to defeat all natural sleep aid just for you. Harry Reid," Angle said Wednesday I Had High Blood Pressure from rural Now it's down to 120/75. Find out how I did it Fallon, where without drugs she campaigned Buy a link here door to door, spoke to a group at the convention center and attended a gun supporters event. "These numbers really confirm what we've been fairly certain of all along: that if people heard my conservative message, they would respond."

12/6/10 12:13 PM

U.S. Senate candidate Sharron Angle, who seeks the Republican nomination to run against Democratic incumbent Harry Reid, speaks at a November GOP candidates forum. A new poll shows Angle in a near dead heat with GOP candidate Sue Lowden. LAS VEGAS REVIEWJOURNAL FILE

Angle said voters can look at her eight-year record in the Assembly that shows a consistent pattern of opposing taxes and supporting smaller government. Those are two tenets of the Tea Party movement and conservative values in opposition to the Democratic Party's hold on Congress and the White House, government bailouts of industry, and Reid's and President Barack Obama's signature health insurance overhaul. Lowden said she wasn't worried about the tightening primary race nine days before early voting starts May 22 and three weeks before the June 8 vote. "We're confident that our lead will hold," Lowden said in an interview in Las Vegas. "We'll have a strong get-out-the-vote effort. You only need one more vote to win, but we'll win by more than that." According to the Mason-Dixon poll, if the Republican primary were held today: Lowden would win 30 percent of the vote; Angle 25 percent; Tarkanian 22 percent; John Chachas 3 percent; and Chad Christensen 2 percent. The telephone survey of 500 likely Republican voters in Nevada was taken on Monday and Tuesday and has a margin of error of plus or minus 4.5 percentage points. In a similar Mason-Dixon survey taken April 5 to 7, Lowden led the crowded field of 12 Republicans with 45 percent support compared with 27 percent for Tarkanian, 5 percent for Angle, 4 percent for Las Vegas Assemblyman Christensen and 3 percent for Chachas, an Ely native and Wall Street investment banker. "Lowden's loss has been Angle's gain," said Mason-Dixon pollster Brad Coker. "Lowden has been the anointed front-runner for a couple of months, which made her a target for everybody. And Angle got the Tea Party endorsement, and she's the most conservative candidate running." Angle also has a history "of running strong down the stretch" in close elections, Coker added. In 2006, Angle was all but counted out in a congressional GOP primary until the last few weeks, and then she narrowly lost to Rep. Dean Heller by fewer than 500 votes. Two years ago, she almost beat state Senate Minority Leader Bill Raggio, R-Reno, one of Nevada's most powerful lawmakers. "Obviously, Angle still has her homestretch legs," Coker said, although he added that anything can happen in such a competitive race. "I think you have to be conservative and say it's a three-way race. But trend-wise, Angle has jumped out quickly and has the momentum." The Tea Party Express, the national group that held an anti-Reid protest in the senator's hometown of Searchlight in late March, shook up the race April 15 when it endorsed Angle at a Tax Day news conference in Washington, D.C. The group's political action committee has been raising money for Angle with a goal of $500,000. It already has spent $200,000 for her, including on radio and TV ads. Meantime, Angle has been stacking up endorsements from more than two dozen conservative groups and people, from Gun Owners of America to "Joe the Plumber." Angle's name recognition has jumped to 85 percent compared with 67 percent about a month ago. Only 4 percent of GOP primary voters do not know Lowden's name, and only 3 percent do not know Tarkanian, a real estate developer and former basketball star for the University of Nevada, Las Vegas, whose dad is well-known ex-basketball coach Jerry Tarkanian. The Tarkanian campaign expressed skepticism that Angle had risen so high so fast. Jamie Fisfis, consultant to the campaign, said his tracking polls show Angle moving up to 16 percent support, Lowden dropping to 30 percent and Tarkanian gaining to tie the GOP front-runner in his best showing so far. "In my mind it's still a two-way race because Angle does not have the name recognition to be ahead of either of the two candidates in contention," Fisfis said. Lowden blamed part of her recent drop in the polls to attacks from both her GOP foes -especially Tarkanian -- and Reid, whose campaign has focused on her, criticizing her record as a casino executive who with her husband, Paul Lowden, has owned and managed four hotel-casinos. The Reid campaign has released records that show problems with health and safety violations at the Lowden properties over the years that resulted in heavy fines and offered

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U.S. SENATE RACE: Tea Party power fuels Angle - News - ReviewJournal.com
violations at the Lowden properties over the years that resulted in heavy fines and offered details of angry disputes with the unions over medical benefits for their workers. Tarkanian has criticized Lowden for voting for fees as a lawmaker in the early 1990s and for telling a reporter recently that she understood why some members of Congress voted for the first government bailout during the Bush administration when lawmakers said it was needed to avoid massive business failures and a depression. She since has said she wouldn't have voted for bailouts then or now. "It's not unexpected that the race would tighten after Harry Reid has spent $8 million going after me," Lowden said Wednesday, referring to how much his campaign has spent. "The Reid campaign and Harry Reid do not want me to come out of this primary, and so they have targeted me." In the past month, Lowden has been dogged by near daily attacks by the Democratic Party for suggesting people could barter with their doctors for cheaper health care. She defended her remarks made at a town hall meeting in Mesquite by saying that in the old days, people even used chickens to barter, a comment that prompted video spoofs and late-night talk show jokes about her. The gaffe hasn't had much effect on Republican primary voters, however, according to the new Mason-Dixon poll, which asked what effect her remarks would have on support for her. Some 70 percent of those polled said Lowden's bartering remarks would have "no effect" on their voting decision, 15 percent said they would be "less likely" to vote for her, and 12 percent said they would be "more likely" to vote for her. Another 3 percent said they weren't sure. Lowden said that during her campaign stops in rural Nevada, voters have told her that they're still bartering with doctors to get cheaper medical care in some cases. "I never said this was my health care policy, but bartering is still happening out there in rural Nevada," Lowden said Wednesday. "Harry Reid is the one who's out of touch if he doesn't know that." Lowden has been running a primary and general campaign at the same time, which has cost her support among staunch conservatives and Tea Party movement supporters. According to the new poll, 58 percent said they consider themselves "a supporter of the Tea Party movement." Another 27 percent do not, and 15 percent said they don't know or refused to answer. "I am a member of the Tea Party movement, as well, and many of my supporters and volunteers are members," said Lowden, who spoke at the Tea Party Express event in Searchlight and has attended many local Tea Party group events as candidates compete for that key slice of the 2010 vote. "It's not unexpected that Sharron would get their support, but they know I'm one of them, too." Contact Laura Myers at [e-mail] or 702-387-2919.
RELATED TOPICS Chad Christensen Danny Tarkanian Harry Reid John Chachas Laura Myers Mason-Dixon poll primary Republican Sharron Angle Sue Lowden voters

12/6/10 12:13 PM

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Comments (115)
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U.S. SENATE RACE: Tea Party power fuels Angle - News - ReviewJournal.com

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Submit Some comments may not display immediately due to an automatic filter. These comments will be reviewed within 24 hours. Please do not submit a comment more than once. Note: Comments made by reporters and editors of the Las Vegas Review-Journal are presented with a yellow background.

Report abuse Bob Dobolina wrote on May 20, 2010 08:59 PM:

I think Lowden is out of this. Her poll numbers are down 20 points since she suggested that people should pay their doctors with chickens, then denied that she had ever said it. Saying something dumb is one thing. But lying about it later (especially when you said it on camera) is really stupid.

Report abuse Just_Me wrote on May 17, 2010 02:30 PM:

What to do - what do do Lowden blew the GOP convention - NO Tarkanian - nothing but daddy's name -NO Angle - Nice , but dingy -Enough with the California-style property taxes -NO That leaves ChaChas & Christensen. Chachas' family lives in New York - NO Chad Christensen gets my vote!

Report abuse Brigham wrote on May 16, 2010 12:08 PM:

Reid is the most corrupt of all of them. We don't need anymore of his back door deals, bribes and name calling. He got more money from Wall St. than any of the republicans yet he pointing a finger just like Obama. Reid wants to make the illegals legal for the votes. Then they can take more of our jobs and services. Reid is nothing but a disgusting despicable crook. Vote for anyone but Reid!

Report abuse Dan Fitzgerald wrote on May 14, 2010 06:54 PM:

Sue Lowden was the GOP chair who delayed, then adjourned the state convention when it became apparent that Ron Paul was going to win delegates to the National Convention. She put John McCain above Nevadans, and ignored the rules when they led to a result she didn't like.

Report abuse Wallbanger wrote on May 14, 2010 07:10 AM:

Tea Party Express is made up of RINO's...Republican Party thinks they can co-opt the Tea Party movement to help them elect the same status-quo Oath-Breaking politicians they always have!! Our military, law enforcement, and ELECTED OFFICIALS need to HONOR THEIR OATH TO THE U.S. CONSTITUTION!!! oathkeepers.org

Report abuse Brigham Young wrote on May 14, 2010 07:04 AM:

Reid, Tark and Lowden have corruption in common, Reid being public enemy #1

Report abuse

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U.S. SENATE RACE: Tea Party power fuels Angle - News - ReviewJournal.com

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Peter.K wrote on May 14, 2010 06:42 AM:

There are a great number of 48-year-old men that have a lot better resume than Mr. Tarkanian. The problem they have is that they don't have a famous father and, ergo, a recognizable name. Other than his name, Mr. Tarkanian is an unremarkable person. He offers no qualifications for the office which he seeks other than his name. He has pointed-out Sue Lowden's shortcomings and flip-flops and for that Republicans should be grateful but he has really advanced no reason why he is qualified to represent us and no record by which we can measure his steadfastness to the principles he preaches. Accordingly, it appears that Angle is the candidate who measures up to the job as she has a solid record of upholding the constitutions of Nevada and the USA.

Report abuse Tark is a Gun Hater wrote on May 14, 2010 02:09 AM:

Danny Tarkanian will take your gun rights. http://media.washingtontimes.com/media/docs/2009/Dec/16/Nevada_Tarkanian.pdf http://media.washingtontimes.com/media/audio/2009/12/17/brady.mp3

Report abuse Hairy Weed wrote on May 13, 2010 08:45 PM:

Great News, now people need to wake up and support Montandon for Governor as well. NO MORE RINOs. Kenny Guinn was a disaster for Nevada, now his right hand guy Sandoval is running? - No f-ing way.

Report abuse Sue is a JOKE! wrote on May 13, 2010 08:22 PM:

Sue LOWden's version of capitalism: Marry a Rich Man!

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