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

Filing 29

DECLARATION of Joseph Stoshak 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. 29

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 JOSEPH STOSHAK I, Joseph Stoshak, declare as follows: 1. 2. I am the Chief Financial Officer of Public Citizen, Inc. (Public Citizen). Public Citizen is a membership organization incorporated under the laws of the

District of Columbia. It is recognized as a not-for-profit corporation under section 501(c)(4) of the United States Internal Revenue Code. Currently, it has approximately 80,000 members. 3. In my duties as Chief Financial Officer, I regularly view materials that Public

Citizen distributes to members and prospective members. Those materials describe Public Citizen and describe its mission. 4. Our mission statement declares that Public Citizen fights in the Congress, the

courts, and before the regulatory agencies for, among other things, "strong health, safety and environmental protections." Over the years, we have fought for bans and exposure-level reductions regarding a large number of environmental and workplace toxins, such as cadmium, hexavalent chromium, vinyl chloride, and lead, to name just a few.

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