Windsor v. The United States Of America
Filing
82
DECLARATION of Roberta A. Kaplan in Support re: 28 MOTION for Summary Judgment.. Document filed by Edith Schlain Windsor. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E)(Kaplan, Roberta)
EXHIBIT C
Gary M. Segura, Ph. D.
July 8, 2011
Page 1
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
-------------------------------------EDITH SCHLAIN WINDSOR, in her
capacity as Executor of the Estate
of CLARA SPYER,
Plaintiff,
-against-
10-CV-8435
THE UNITED STATES OF AMERICA,
Defendant.
-------------------------------------(Caption continued on next page.)
DEPOSITION OF GARY MICHAEL SEGURA, Ph.D.
Gary M. Segura, Ph. D.
July 8, 2011
Page 28
1
G. Segura
2
3
MS. HENRY:
A.
Objection to form.
The term significant is a very
4
squishy term.
Do they have resources?
Yes.
5
Do they expend those resources?
6
Are their resources sufficient to the needs of
7
the group to defend their basic interests?
8
That's a different question.
9
resources -- let's see what am I looking
Certainly.
Are those
10
for -- comparable to the resources that are
11
arrayed against them?
12
question.
13
That's a different
So taking a more narrow response to
14
your question, gays and lesbians do expend
15
financial resources in their own defense.
16
Those resources have repeatedly proven
17
insufficient to protect their basic interests
18
because the resources arrayed against them are
19
far superior.
20
Q.
Have you studied how much money gay
21
and lesbian advocacy groups have spent on
22
political lobbying?
23
24
25
A.
Not specifically.
I have not summed
up their annual budgets.
Q.
If you could turn to paragraph 13,
Gary M. Segura, Ph. D.
July 8, 2011
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page 5, you write "Political power refers to a
3
person's or group's demonstrated ability to
4
extract favorable or prevent unfavorable
5
policy outcomes from the political system."
6
7
8
9
What do you mean by the use of
extract in that sentence?
A.
We want to look at two aspects of a
policy outcome.
The first aspect is whether
10
or not that policy outcome is consistent with
11
the preferences of the group.
12
whether or not the group themselves are in the
13
position to make that policy outcome happen or
14
if the policy outcome was simply the
15
happenstance of political conditions or a
16
meeting of the minds or an agreement of others
17
who agree with their position.
18
Q.
The second is
What is the difference between, I
19
think political happenstance is the term you
20
used, and actual extraction of political
21
benefit?
22
A.
I think the difference is best
23
illustrated in the following way:
If the
24
desirable outcome is not achieved, are gays
25
and lesbians in the political position to
Gary M. Segura, Ph. D.
July 8, 2011
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2
more access to the Republican party than the
3
Democratic party.
4
5
Would you say that they have limited
access to the political process?
6
7
MS. HENRY:
A.
Objection.
So I do not present myself as an
8
expert on pro-life politics.
9
notwithstanding, I would actually take issue
10
That
with the supposition.
11
There is a sizable contingent of
12
quote-unquote pro-life Democrats in the United
13
States Congress.
14
Stupak actually held up passage of the
15
comprehensive healthcare reform legislation
16
precisely over the issue of abortion.
17
is, a Democratic legislator held the
18
President's signature policy goal hostage for
19
months over the issue of abortion.
20
One former Congressman, Bart
That
So the idea that pro-lifers only have
21
sympathy in one party I think is actually
22
misrepresenting the facts.
23
Q.
How is what you write there in
24
paragraph 32 in that final sentence different
25
from the normal give and take of politics?
Gary M. Segura, Ph. D.
July 8, 2011
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3
MS. KAPLAN:
A.
Objection to form.
Let's think about a variety of groups
4
who contest for power in the political system.
5
When we think about businesses and the
6
financial sector, both parties seek the
7
support of businesses.
8
we normally think of as associated with the
9
Republicans but not exclusively, and certainly
10
the President has made no secret of his effort
11
to keep Wall Street financial folks on board
12
with the Democratic party agenda.
13
Democratic party would describe itself as
14
probusiness, even though obviously the
15
Republicans disagree.
16
sides trying to lure a group.
17
This is a group that
The
There is a case of both
The same might be true for
18
Evangelical Christians, even though
19
Evangelical Christians are overwhelming
20
identified with the Republican party,
21
President Obama appeared at Saddleback Church
22
during the campaign, had Rick Warren give the
23
invocation at his inauguration, has made
24
frequent and repeated overtures to try to
25
bring some number of Evangelical Christians
Gary M. Segura, Ph. D.
July 8, 2011
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2
whose policy preferences might not be quite as
3
conservative as others into the Democratic
4
fold.
5
Both sides seek their votes.
Another example might be police
6
unions or all sorts of peace officer
7
associations.
8
law and order sorts of policies from
9
Republicans, but they tend to prefer the
Police unions tend to prefer
10
fiscal policies and public expenditure
11
policies of Democrats, and also, by the way,
12
the gun control policies of Democrats.
13
both Democrats and Republicans seek the
14
support of police unions.
15
So
That is the rough and tumble of
16
politics, where one group has their support
17
sought from one political party and the other
18
tries to go in there and peel some away or
19
create an alternative narrative to get the
20
group to switch sides.
21
as the rough and tumble of politics.
22
That's what I think of
In the case of gay men and lesbians,
23
there is a political party who, by practice
24
and by platform, is affirmatively
25
disinterested in their issues.
That literally
Gary M. Segura, Ph. D.
July 8, 2011
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2
opposes employment nondiscrimination, opposes
3
adoption rights, opposes same-sex marriage
4
equality, opposes service in the military.
5
Opposes essentially every element of equality
6
that gays and lesbians seek.
7
So when gays and lesbian are seeking
8
legislative redress, there is the occasional
9
Republican that they might wish to go to.
But
10
by and large, they really only have one party.
11
That sort of party capture is really
12
debilitating to the political power of a
13
group.
14
outside of gays and lesbians which I think
15
illustrates my point.
16
years, though certainly not in the last year,
17
but in recent years, I think Latinos have been
18
advantaged vis-a-vis African-Americans because
19
African-Americans split 95 to 5 for the
20
Democratic party; whereas, Latinos are about a
21
two-thirds, one-third.
22
believe that if they can get up to about 40
23
percent of the Latino vote, then that would
24
make them more competitive and they can win
25
elections.
And I would give you an example
I think that in recent
And Republicans
What this means is that at least
Gary M. Segura, Ph. D.
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2
I can't think of a group that has to
3
regularly face legislative and electoral
4
challenges to even the simplest effort at
5
securing protection from social hostility,
6
whether that be valid initiatives to overturn
7
gay rights ordinances that protect employment
8
discrimination, or whether that be the
9
same-sex marriage fight or other issues.
So,
10
as I have testified earlier, there is no group
11
that has faced these ballot initiatives or
12
public referendum more frequently than gay men
13
and lesbians.
14
constitute a pretty extreme disadvantage.
15
16
Q.
Those things together I think
Earlier you talked about the
continuum of political power.
17
Is there a way to determine the
18
dividing line between politically powerful and
19
politically powerless?
20
A.
The shorts answer is that the
21
dividing line would be contingent, and I
22
believe this was like one of your first
23
questions when you asked me what is the 50
24
percent mark or what is the threshold or
25
whatever.
Gary M. Segura, Ph. D.
July 8, 2011
Page 166
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2
question.
3
I may have to read the section.
4
Q.
If you ask me a specific question,
Let me stipulate that this is a
5
letter that was written to President Barack
6
Obama lamenting the fact that his
7
administration was defending DOMA.
8
9
MS. KAPLAN:
website?
10
How did you get this?
MR. DUGAN:
11
Bartolmucci.
12
website.
13
14
I got it from Chris
I presume he got it from a
I can fill in that gap.
MS. KAPLAN:
If you can just let me
know.
15
16
Did you get this off a
MR. DUGAN:
Q.
Sure.
This letter was written to President
17
Obama June 2009.
18
President and the Attorney General determined
19
that they believe DOMA to be unconstitutional.
20
21
Sometime thereafter, the
Could this be evidence of politically
effective power?
22
MS. KAPLAN:
23
You can answer.
24
25
A.
Objection to form.
It could, but I am not buying it.
First of all, this letter was written
Gary M. Segura, Ph. D.
July 8, 2011
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2
almost two years before the administration
3
changed its policy on DOMA, so maybe in the
4
neighborhood of 21 months.
5
Second, the President of the United
6
States receives literally tens of thousands of
7
letters a day.
8
of letters a day from leaders of large
9
organizations.
He probably receives hundreds
So that a letter precedes a
10
policy change would require me to assume that
11
the order of, the temporal order of the events
12
is causal, and I have no reason to believe
13
that.
14
Q.
I need a little bit more than a letter.
Fair enough.
15
MR. DUGAN:
16
I will represent that this was taken
17
Mark this as Exhibit 6.
from the White House website.
18
(Defendant's Exhibit 6, excerpt
19
from White House website,
20
marked for identification.)
21
Q.
22
23
MS. KAPLAN:
Objection to the form
and foundation.
24
25
What is this Exhibit 6, Dr. Segura?
If you know.
A.
Based on my observation it appears to
Name of Cases:
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
EDITH SCHLAIN WINDSOR,
in her capacity as Executor of the Estate of THEA CLARA SPYER,
Plaintiff,
v.
THE UNITED STATES OF AMERICA,
Defendant.
(10 Civ. 8435) (BSJ) (JCF)
UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
JOANNE PEDERSEN & ANN MEITZEN, GERALD V. PASSARO II, LYNDA
DEFORGE & RAQUEL ARDIN, JANET GELLER & JOANNE MARQUIS,
SUZANNE & GERALDINE ARTIS, BRADLEY KLEINERMAN & JAMES GEHRE,
and DAMON SAVOY & JOHN WEISS,
Plaintiffs,
v.
OFFICE OF PERSONNEL MANAGEMENT, TIMOTHY F. GEITHNER, in his official
capacity as the Secretary of the Treasury, and HILDA L. SOLIS, in her official capacity
as the Secretary of Labor, MICHAEL J. ASTRUE, in his official capacity as the
Commissioner of the Social Security Administration, UNITED STATES POSTAL
SERVICE, JOHN E. POTTER, in his official capacity as The Postmaster General of the
United States of America, DOUGLAS H. SHULMAN, in his official capacity as the
Commissioner of Internal Revenue, ERIC H. HOLDER, JR., in his official capacity as
United States Attorney General, JOHN WALSH, in his official capacity as Acting
Comptroller of the Currency, and THE UNITED STATES OF AMERICA,
Defendants.
(310-CV-1750) (VLB)
Date of Deposition:
Friday, July 8, 2011
Name of Witness:
Gary Michael Segura, Ph.D.
Gary Michael Segura Errata Sheet for July 8, 2011 Deposition
I wish to make the following changes, for the following reasons:
PAGE LINE:
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“individuals”
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“individuals’”
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“Pedersen”
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“Golinski”
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“primarily the same sex sexual attraction”
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“primarily same-sex sexual attraction”
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“to prior to”
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“prior to”
2
Gary Michael Segura Errata Sheet for July 8, 2011 Deposition
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“and in least in one instance”
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“and at least in one instance”
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“so I guess that would yes”
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“so I guess that would mean yes”
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“at as well”
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“as well”
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“is”
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“are”
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“do not possess meaningful degree”
CHANGE TO:
“do not possess a meaningful degree”
3
Gary Michael Segura Errata Sheet for July 8, 2011 Deposition
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“would like a break it down”
CHANGE TO:
“would like to break it down”
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“press government for return, et cetera.”
CHANGE TO:
“press the government for a return, et cetera.”
REASON:
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“excluded from basics civil equality”
CHANGE TO:
“excluded from basic civil equality”
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CHANGE FROM:
“firefighters”
CHANGE TO:
“firefighters’”
REASON:
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“achieve its end”
CHANGE TO:
“achieve its ends”
4
Gary Michael Segura Errata Sheet for July 8, 2011 Deposition
REASON:
Transcription Error
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CHANGE FROM:
“politicians candidates”
CHANGE TO:
“politicians or candidates”
REASON:
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“successful, valid”
CHANGE TO:
“successful, ballot”
REASON:
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CHANGE FROM:
“cost”
CHANGE TO:
“costs”
REASON:
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26:15
CHANGE FROM:
“You could have someone says”
CHANGE TO:
“You could have someone who says”
REASON:
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30:9–10
CHANGE FROM:
“If legislator”
CHANGE TO:
“If a legislator”
5
Gary Michael Segura Errata Sheet for July 8, 2011 Deposition
REASON:
Transcription Error
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31:4
CHANGE FROM:
“That’s powerful”
CHANGE TO:
“That’s a powerful’”
REASON:
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CHANGE FROM:
“are able”
CHANGE TO:
“is able”
REASON:
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33:11
CHANGE FROM:
“some in”
CHANGE TO:
“some. In’”
REASON:
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33:18
CHANGE FROM:
“?”
CHANGE TO:
“.”
REASON:
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35:4
CHANGE FROM:
“just as easily choose not advocate on behalf”
CHANGE TO:
“just as easily choose not to advocate on behalf”
6
Gary Michael Segura Errata Sheet for July 8, 2011 Deposition
REASON:
Transcription Error
PAGE LINE:
36:19–20
CHANGE FROM:
“presence or absence of significant gay population”
CHANGE TO:
“presence or absence of a significant gay population”
REASON:
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37:5
CHANGE FROM:
“And if answer is”
CHANGE TO:
“And if the answer is”
REASON:
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37:15
CHANGE FROM:
“I can look at two party votes”
CHANGE TO:
“I can look at the party votes”
REASON:
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38:3–4
CHANGE FROM:
“knowing for sure counterfactual”
CHANGE TO:
“knowing for sure the counterfactual”
REASON:
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PAGE LINE:
38:19
CHANGE FROM:
“evidence”
CHANGE TO:
“evidenced”
7
Gary Michael Segura Errata Sheet for July 8, 2011 Deposition
REASON:
Transcription Error
PAGE LINE:
40:15
CHANGE FROM:
“think of good”
CHANGE TO:
“think of a good”
REASON:
Transcription Error
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40:20
CHANGE FROM:
“a heterosexual coup;e”
CHANGE TO:
“a heterosexual couple”
REASON:
Typographical Error
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40:24
CHANGE FROM:
“those basics rights”
CHANGE TO:
“those basic rights”
REASON:
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43:13
CHANGE FROM:
“groups interest are”
CHANGE TO:
“group’s interests are”
REASON:
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43:18
CHANGE FROM:
“as or”
CHANGE TO:
“as gay or”
8
Gary Michael Segura Errata Sheet for July 8, 2011 Deposition
REASON:
Transcription Error
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44:18
CHANGE FROM:
“but isn’t this the in case of any”
CHANGE TO:
“but isn’t this the case in any”
REASON:
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45:19
CHANGE FROM:
“disadvantage”
CHANGE TO:
“disadvantaged”
REASON:
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“valid”
CHANGE TO:
“ballot”
REASON:
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46:3
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“cornered”
CHANGE TO:
“concerned”
REASON:
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46:13
CHANGE FROM:
“valid”
CHANGE TO:
“ballot”
9
Gary Michael Segura Errata Sheet for July 8, 2011 Deposition
REASON:
Transcription Error
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48:13
CHANGE FROM:
“there is, not to my knowledge,”
CHANGE TO:
“there is not, to my knowledge,”
REASON:
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CHANGE FROM:
“violences”
CHANGE TO:
“violence”
REASON:
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49:14
CHANGE FROM:
“they would vote fort he hate”
CHANGE TO:
“they would vote for the hate”
REASON:
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49:25
CHANGE FROM:
“acts”
CHANGE TO:
“Acts”
REASON:
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50:19
CHANGE FROM:
“basics”
CHANGE TO:
“basic”
10
Gary Michael Segura Errata Sheet for July 8, 2011 Deposition
REASON:
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52:19
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“they have”
CHANGE TO:
“they would have”
REASON:
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52:21
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“had the administration switched position”
CHANGE TO:
“had the administration switched positions”
REASON:
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“that Obama administration”
CHANGE TO:
“that the Obama administration”
REASON:
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CHANGE FROM:
“That is, Obama administration”
CHANGE TO:
“That is, the Obama administration”
REASON:
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CHANGE FROM:
“changes”
CHANGE TO:
“change”
11
Gary Michael Segura Errata Sheet for July 8, 2011 Deposition
REASON:
Transcription Error
PAGE LINE:
177:16,
55:16, 55:21, 129:6, 171:13, 172:21, 175:2, 176:3, 177:8, 177:10,
177:21
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“Dont”
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“Don’t”
REASON:
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61:18
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“votes”
CHANGE TO:
“voters”
REASON:
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“are little”
CHANGE TO:
“are a little”
REASON:
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“constitutionally-establish inequality”
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“constitutionally-established inequality”
REASON:
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CHANGE FROM:
“,,”
12
Gary Michael Segura Errata Sheet for July 8, 2011 Deposition
CHANGE TO:
“,”
REASON:
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66: 19
CHANGE FROM:
“matter”
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“marry”
REASON:
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68: 7
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“Couldn’t it simple demonstrate”
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“Couldn’t it simply demonstrate”
REASON:
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“last”
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“lasted”
REASON:
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70:25
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“Imagine you are Maine voter”
CHANGE TO:
“Imagine you are a Maine voter”
REASON:
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71:6
CHANGE FROM:
“enactment of marriage right”
13
Gary Michael Segura Errata Sheet for July 8, 2011 Deposition
CHANGE TO:
“enactment of marriage rights”
REASON:
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“possible”
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“possibly”
REASON:
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75:10
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“in other state where”
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“in other states where”
REASON:
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“activist might feel”
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“activists might feel”
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“pervail”
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“prevail”
REASON:
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76:19
CHANGE FROM:
“activists’”
14
Gary Michael Segura Errata Sheet for July 8, 2011 Deposition
CHANGE TO:
“activists”
REASON:
Transcription Error
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78:8
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“was preemptive”
CHANGE TO:
“was a preemptive”
REASON:
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78:10
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“during that 2004 waive”
CHANGE TO:
“during that 2004 wave”
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“to a”
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“to be a”
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82:20
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“reduce”
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“reduces”
REASON:
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84:19
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“and the district safe”
15
Gary Michael Segura Errata Sheet for July 8, 2011 Deposition
CHANGE TO:
“and the district is safe”
REASON:
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84:24
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“that 60 percent”
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“that of the 60 percent”
REASON:
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86:10
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“and reason”
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“and the reason”
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87:15
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“is”
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“are”
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88:7, 88:9
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“receive much”
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“receive a much”
REASON:
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88:8
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“packed donations”
16
Gary Michael Segura Errata Sheet for July 8, 2011 Deposition
CHANGE TO:
“PAC donations”
REASON:
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88:23
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“at”
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“as”
REASON:
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“costal”
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“coastal”
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“I a lawyer, not accountant”
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“I am a lawyer, not an accountant”
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“group”
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“groups”
REASON:
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91:10
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“outcome process”
17
Gary Michael Segura Errata Sheet for July 8, 2011 Deposition
CHANGE TO:
“outcome and process”
REASON:
Transcription Error
PAGE LINE:
92:4
CHANGE FROM:
“political power numerous”
CHANGE TO:
“political power or numerous”
REASON:
Transcription Error
PAGE LINE:
93:8
CHANGE FROM:
“that is”
CHANGE TO:
“that are”
REASON:
Transcription Error
PAGE LINE:
93:22
CHANGE FROM:
“infectious decease”
CHANGE TO:
“infectious disease”
REASON:
Transcription Error
PAGE LINE:
94:17
CHANGE FROM:
“Randy Schultz”
CHANGE TO:
“Randy Shilts”
REASON:
Transcription Error
PAGE LINE:
94:22
CHANGE FROM:
“have”
18
Gary Michael Segura Errata Sheet for July 8, 2011 Deposition
CHANGE TO:
“has”
REASON:
Transcription Error
PAGE LINE:
99:19
CHANGE FROM:
“individuals or who know”
CHANGE TO:
“individuals who know”
REASON:
Transcription Error
PAGE LINE:
100:2
CHANGE FROM:
“crime study about Latino”
CHANGE TO:
“crime study about Latinos”
REASON:
Typographical Error
PAGE LINE:
101:8
CHANGE FROM:
“worse”
CHANGE TO:
“worse,”
REASON:
Transcription Error
PAGE LINE:
101:22
CHANGE FROM:
“and as consequence”
CHANGE TO:
“and as a consequence”
REASON:
Transcription Error
PAGE LINE:
104:2
CHANGE FROM:
“propose”
19
Gary Michael Segura Errata Sheet for July 8, 2011 Deposition
CHANGE TO:
“proposing”
REASON:
Typographical Error
PAGE LINE:
104:3
CHANGE FROM:
“have better”
CHANGE TO:
“have a better”
REASON:
Typographical Error
PAGE LINE:
104:24
CHANGE FROM:
“advocates our positio”
CHANGE TO:
“advocates our position”
REASON:
Typographical Error
PAGE LINE:
107:5
CHANGE FROM:
“We promise they anonymity”
CHANGE TO:
“We promise them anonymity”
REASON:
Transcription Error
PAGE LINE:
107:16
CHANGE FROM:
“The question is is”
CHANGE TO:
“The question is, is”
REASON:
Typographical Error
PAGE LINE:
108:16
CHANGE FROM:
“virtual”
20
Gary Michael Segura Errata Sheet for July 8, 2011 Deposition
CHANGE TO:
“virtually”
REASON:
Transcription Error
PAGE LINE:
109:23
CHANGE FROM:
“vary”
CHANGE TO:
“very”
REASON:
Transcription Error
PAGE LINE:
112:10
CHANGE FROM:
“time and profession”
CHANGE TO:
“time in profession”
REASON:
Transcription Error
PAGE LINE:
116:12
CHANGE FROM:
“heterosexual erotic art was not in any funded”
CHANGE TO:
“heterosexual erotic art was not in any way funded”
REASON:
Transcription Error
PAGE LINE:
116:20
CHANGE FROM:
“home”
CHANGE TO:
“here”
REASON:
Transcription Error
PAGE LINE:
120:15
CHANGE FROM:
“tough flowing”
21
Gary Michael Segura Errata Sheet for July 8, 2011 Deposition
CHANGE TO:
“tough going”
REASON:
Transcription Error
PAGE LINE:
121:10–11
CHANGE FROM:
“I believe it was Senator could he burn”
CHANGE TO:
“I believe it was Senator Coburn”
REASON:
Transcription Error
PAGE LINE:
121:14
CHANGE FROM:
“imagine”
CHANGE TO:
“imagine an”
REASON:
Transcription Error
PAGE LINE:
122:6
CHANGE FROM:
“we had should”
CHANGE TO:
“we should”
REASON:
Transcription Error
PAGE LINE:
122:7
CHANGE FROM:
“and a perverts.”
CHANGE TO:
“and perverts.”
REASON:
Transcription Error
PAGE LINE:
125:17
CHANGE FROM:
“It would”
22
Gary Michael Segura Errata Sheet for July 8, 2011 Deposition
CHANGE TO:
“It would be”
REASON:
Transcription Error
PAGE LINE:
126:10
CHANGE FROM:
“content”
CHANGE TO:
“contempt”
REASON:
Transcription Error
PAGE LINE:
128:18
CHANGE FROM:
“An”
CHANGE TO:
“And”
REASON:
Transcription Error
PAGE LINE:
129:15
CHANGE FROM:
“in the Old”
CHANGE TO:
“to the Old”
REASON:
Transcription Error
PAGE LINE:
130:7
CHANGE FROM:
“that’s answer you are looking for”
CHANGE TO:
“that’s the answer you are looking for”
REASON:
Transcription Error
PAGE LINE:
131:6
CHANGE FROM:
“Paper”
23
Gary Michael Segura Errata Sheet for July 8, 2011 Deposition
CHANGE TO:
“Papers”
REASON:
Transcription Error
PAGE LINE:
134:15
CHANGE FROM:
“discrimination”
CHANGE TO:
“nondiscrimination”
REASON:
Transcription Error
PAGE LINE:
134:19
CHANGE FROM:
“majority of the Americans”
CHANGE TO:
“majority of Americans”
REASON:
Transcription Error
PAGE LINE:
134:22
CHANGE FROM:
“END”
CHANGE TO:
“ENDA”
REASON:
Transcription Error
PAGE LINE:
135:9
CHANGE FROM:
“if you are performing job”
CHANGE TO:
“if you are performing your job”
REASON:
Transcription Error
PAGE LINE:
139:5–6
CHANGE FROM:
“tremendous detail the about sources”
24
Gary Michael Segura Errata Sheet for July 8, 2011 Deposition
CHANGE TO:
“tremendous detail about the sources”
REASON:
Transcription Error
PAGE LINE:
139:9
CHANGE FROM:
“EAP”
CHANGE TO:
“APA”
REASON:
Transcription Error
PAGE LINE:
140:7
CHANGE FROM:
“and as”
CHANGE TO:
“and as a”
REASON:
Transcription Error
PAGE LINE:
141:9
CHANGE FROM:
“undermines gay and lesbians”
CHANGE TO:
“undermines gay and lesbians’”
REASON:
Transcription Error
PAGE LINE:
142:19
CHANGE FROM:
“who”
CHANGE TO:
“whom”
REASON:
Transcription Error
PAGE LINE:
143:6
CHANGE FROM:
“valid”
25
Gary Michael Segura Errata Sheet for July 8, 2011 Deposition
CHANGE TO:
“ballot”
REASON:
Transcription Error
PAGE LINE:
144:4
CHANGE FROM:
“contestation over basics rights”
CHANGE TO:
“contestation over basic rights”
REASON:
Typographical Error
PAGE LINE:
144:13
CHANGE FROM:
“a group as powerless”
CHANGE TO:
“a group as powerful”
REASON:
Transcription Error
PAGE LINE:
144:19
CHANGE FROM:
“very”
CHANGE TO:
“varies”
REASON:
Transcription Error
PAGE LINE:
144:20
CHANGE FROM:
“shorts”
CHANGE TO:
“short”
REASON:
Transcription Error
PAGE LINE:
145:11
CHANGE FROM:
“so the one”
26
Gary Michael Segura Errata Sheet for July 8, 2011 Deposition
CHANGE TO:
“so the one that”
REASON:
Transcription Error
PAGE LINE:
146:12
CHANGE FROM:
“I think it primarily”
CHANGE TO:
“I think it is primarily”
REASON:
Transcription Error
PAGE LINE:
146:23
CHANGE FROM:
“various come forms”
CHANGE TO:
“various forms”
REASON:
Transcription Error
PAGE LINE:
147:10
CHANGE FROM:
“profession”
CHANGE TO:
“professionals”
REASON:
Transcription Error
PAGE LINE:
149:19
CHANGE FROM:
“that very significantly by geography”
CHANGE TO:
“that varies significantly by geography”
REASON:
Transcription Error
PAGE LINE:
151:4
CHANGE FROM:
“so it”
27
Gary Michael Segura Errata Sheet for July 8, 2011 Deposition
CHANGE TO:
“so it is”
REASON:
Transcription Error
PAGE LINE:
151:10
CHANGE FROM:
“there are still few”
CHANGE TO:
“there are still a few”
REASON:
Transcription Error
PAGE LINE:
154:11–12
CHANGE FROM:
“it very equivalent”
CHANGE TO:
“it was very equivalent”
REASON:
Transcription Error
PAGE LINE:
154:17
CHANGE FROM:
“money reason”
CHANGE TO:
“money for a reason”
REASON:
Transcription Error
PAGE LINE:
155:4
CHANGE FROM:
“quite expense”
CHANGE TO:
“quite expensive”
REASON:
Transcription Error
PAGE LINE:
156:17
CHANGE FROM:
“older people”
28
Gary Michael Segura Errata Sheet for July 8, 2011 Deposition
CHANGE TO:
“younger people”
REASON:
Transcription Error
PAGE LINE:
157:6
CHANGE FROM:
“that’s central argument”
CHANGE TO:
“that’s the central argument”
REASON:
Transcription Error
PAGE LINE:
157:13
CHANGE FROM:
“some of nuance”
CHANGE TO:
“some of the nuance”
REASON:
Transcription Error
PAGE LINE:
160:9
CHANGE FROM:
“defining stories”
CHANGE TO:
“defining what stories”
REASON:
Transcription Error
PAGE LINE:
160:13
CHANGE FROM:
“that the arguments”
CHANGE TO:
“that the argument”
REASON:
Transcription Error
PAGE LINE:
161:24
CHANGE FROM:
“lesbians remain hotly”
29
Gary Michael Segura Errata Sheet for July 8, 2011 Deposition
CHANGE TO:
“lesbians remains hotly”
REASON:
Transcription Error
PAGE LINE:
163:20–21
CHANGE FROM:
“defending the ing statute”
CHANGE TO:
“defending the statute”
REASON:
Typographical Error
PAGE LINE:
165:5
CHANGE FROM:
“So it less”
CHANGE TO:
“So it’s less”
REASON:
Transcription Error
PAGE LINE:
166:11
CHANGE FROM:
“Bartolmucci”
CHANGE TO:
“Bartolomucci”
REASON:
Transcription Error
PAGE LINE:
169:19–20
CHANGE FROM:
“he is poor judge”
CHANGE TO:
“he is a poor judge”
REASON:
Transcription Error
PAGE LINE:
174:16
CHANGE FROM:
“separately equal”
30
Gary Michael Segura Errata Sheet for July 8, 2011 Deposition
CHANGE TO:
“separate but equal”
REASON:
Transcription Error
PAGE LINE:
176:8–9
CHANGE FROM:
policital
“By themselves, they are not neither nor sufficient to demonstrate
power.”
CHANGE TO:
dem
“By themselves, they are neither necessary nor sufficient to
onstrate political power.”
REASON:
Transcription Error
PAGE LINE:
176:18
CHANGE FROM:
“I am political scientist”
CHANGE TO:
“I am a political scientist”
REASON:
Transcription Error
PAGE LINE:
177:22
CHANGE FROM:
“repeal was”
CHANGE TO:
“repeal which is”
REASON:
Transcription Error
PAGE LINE:
180:13, 180:19
CHANGE FROM:
“Galinsky”
CHANGE TO:
“Golinski”
REASON:
Typographical Error
31
Gary Michael Segura Errata Sheet for July 8, 2011 Deposition
32
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