Natural Resources Defense Council, Inc. et al v. United States Consumer Product Safety Commission

Filing 26

DECLARATION of Linda Lopez in Support re: 13 MOTION for Summary Judgment.. Document filed by Natural Resources Defense Council, Inc., Public Citizen, Inc.. (Colangelo, Aaron)

Natural Resources Defense Council, Inc. et al v. United States Consumer Product Safety Commission

Doc. 26

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK ____________________________________ NATURAL RESOURCES DEFENSE ) COUNCIL, INC., and PUBLIC CITIZEN, ) INC., ) ) Plaintiffs, ) v. ) ) U.S. CONSUMER PRODUCT ) SAFETY COMMISSION, ) ) Defendant. ) ____________________________________)

08 Civ. 10507 (PGG)

DECLARATION OF LINDA LOPEZ I, Linda Lopez, declare as follows: 1. I am the director of membership at the Natural Resources Defense Council, Inc.

("NRDC"). I have been the director of membership for twenty years. 2. My duties include supervising the preparation of materials that NRDC distributes

to members and prospective members. Those materials describe NRDC and identify its mission. 3. NRDC is a membership organization incorporated under the laws of the State of

New York. It is recognized as a not-for-profit corporation under section 501(c)(3) of the United States Internal Revenue Code. 4. NRDC currently has approximately 429,367 members. There are NRDC

members residing in each of the fifty United States and in the District of Columbia, including 37,317 in New York. 5. NRDC's mission statement declares that "The Natural Resources Defense

Council's purpose is to safeguard the Earth: its people, its plants and animals, and the natural

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