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

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G. Segura

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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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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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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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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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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
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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.

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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:

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Gary Michael Segura Errata Sheet for July 8, 2011 Deposition
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“outcome and process”

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92:4

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“political power numerous”

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“political power or numerous”

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93:8

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“that is”

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“that are”

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93:22

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“infectious decease”

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“infectious disease”

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94:17

CHANGE FROM:

“Randy Schultz”

CHANGE TO:

“Randy Shilts”

REASON:

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94:22

CHANGE FROM:

“have”

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Gary Michael Segura Errata Sheet for July 8, 2011 Deposition
CHANGE TO:

“has”

REASON:

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99:19

CHANGE FROM:

“individuals or who know”

CHANGE TO:

“individuals who know”

REASON:

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100:2

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“crime study about Latino”

CHANGE TO:

“crime study about Latinos”

REASON:

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101:8

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“worse”

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“worse,”

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101:22

CHANGE FROM:

“and as consequence”

CHANGE TO:

“and as a consequence”

REASON:

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104:2

CHANGE FROM:

“propose”

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Gary Michael Segura Errata Sheet for July 8, 2011 Deposition
CHANGE TO:

“proposing”

REASON:

Typographical Error

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104:3

CHANGE FROM:

“have better”

CHANGE TO:

“have a better”

REASON:

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104:24

CHANGE FROM:

“advocates our positio”

CHANGE TO:

“advocates our position”

REASON:

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107:5

CHANGE FROM:

“We promise they anonymity”

CHANGE TO:

“We promise them anonymity”

REASON:

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107:16

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“The question is is”

CHANGE TO:

“The question is, is”

REASON:

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108:16

CHANGE FROM:

“virtual”

20

Gary Michael Segura Errata Sheet for July 8, 2011 Deposition
CHANGE TO:

“virtually”

REASON:

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109:23

CHANGE FROM:

“vary”

CHANGE TO:

“very”

REASON:

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112:10

CHANGE FROM:

“time and profession”

CHANGE TO:

“time in profession”

REASON:

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116:12

CHANGE FROM:

“heterosexual erotic art was not in any funded”

CHANGE TO:

“heterosexual erotic art was not in any way funded”

REASON:

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116:20

CHANGE FROM:

“home”

CHANGE TO:

“here”

REASON:

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120:15

CHANGE FROM:

“tough flowing”

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Gary Michael Segura Errata Sheet for July 8, 2011 Deposition
CHANGE TO:

“tough going”

REASON:

Transcription Error

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121:10–11

CHANGE FROM:

“I believe it was Senator could he burn”

CHANGE TO:

“I believe it was Senator Coburn”

REASON:

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121:14

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“imagine”

CHANGE TO:

“imagine an”

REASON:

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122:6

CHANGE FROM:

“we had should”

CHANGE TO:

“we should”

REASON:

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122:7

CHANGE FROM:

“and a perverts.”

CHANGE TO:

“and perverts.”

REASON:

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125:17

CHANGE FROM:

“It would”

22

Gary Michael Segura Errata Sheet for July 8, 2011 Deposition
CHANGE TO:

“It would be”

REASON:

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126:10

CHANGE FROM:

“content”

CHANGE TO:

“contempt”

REASON:

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128:18

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“An”

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“And”

REASON:

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129:15

CHANGE FROM:

“in the Old”

CHANGE TO:

“to the Old”

REASON:

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130:7

CHANGE FROM:

“that’s answer you are looking for”

CHANGE TO:

“that’s the answer you are looking for”

REASON:

Transcription Error

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131:6

CHANGE FROM:

“Paper”

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Gary Michael Segura Errata Sheet for July 8, 2011 Deposition
CHANGE TO:

“Papers”

REASON:

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134:15

CHANGE FROM:

“discrimination”

CHANGE TO:

“nondiscrimination”

REASON:

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134:19

CHANGE FROM:

“majority of the Americans”

CHANGE TO:

“majority of Americans”

REASON:

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134:22

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“END”

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“ENDA”

REASON:

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135:9

CHANGE FROM:

“if you are performing job”

CHANGE TO:

“if you are performing your job”

REASON:

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139:5–6

CHANGE FROM:

“tremendous detail the about sources”

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Gary Michael Segura Errata Sheet for July 8, 2011 Deposition
CHANGE TO:

“tremendous detail about the sources”

REASON:

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139:9

CHANGE FROM:

“EAP”

CHANGE TO:

“APA”

REASON:

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140:7

CHANGE FROM:

“and as”

CHANGE TO:

“and as a”

REASON:

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141:9

CHANGE FROM:

“undermines gay and lesbians”

CHANGE TO:

“undermines gay and lesbians’”

REASON:

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142:19

CHANGE FROM:

“who”

CHANGE TO:

“whom”

REASON:

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143:6

CHANGE FROM:

“valid”

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Gary Michael Segura Errata Sheet for July 8, 2011 Deposition
CHANGE TO:

“ballot”

REASON:

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144:4

CHANGE FROM:

“contestation over basics rights”

CHANGE TO:

“contestation over basic rights”

REASON:

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144:13

CHANGE FROM:

“a group as powerless”

CHANGE TO:

“a group as powerful”

REASON:

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144:19

CHANGE FROM:

“very”

CHANGE TO:

“varies”

REASON:

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144:20

CHANGE FROM:

“shorts”

CHANGE TO:

“short”

REASON:

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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

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146:12

CHANGE FROM:

“I think it primarily”

CHANGE TO:

“I think it is primarily”

REASON:

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146:23

CHANGE FROM:

“various come forms”

CHANGE TO:

“various forms”

REASON:

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147:10

CHANGE FROM:

“profession”

CHANGE TO:

“professionals”

REASON:

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149:19

CHANGE FROM:

“that very significantly by geography”

CHANGE TO:

“that varies significantly by geography”

REASON:

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151:4

CHANGE FROM:

“so it”

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Gary Michael Segura Errata Sheet for July 8, 2011 Deposition
CHANGE TO:

“so it is”

REASON:

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151:10

CHANGE FROM:

“there are still few”

CHANGE TO:

“there are still a few”

REASON:

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154:11–12

CHANGE FROM:

“it very equivalent”

CHANGE TO:

“it was very equivalent”

REASON:

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154:17

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“money reason”

CHANGE TO:

“money for a reason”

REASON:

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155:4

CHANGE FROM:

“quite expense”

CHANGE TO:

“quite expensive”

REASON:

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156:17

CHANGE FROM:

“older people”

28

Gary Michael Segura Errata Sheet for July 8, 2011 Deposition
CHANGE TO:

“younger people”

REASON:

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157:6

CHANGE FROM:

“that’s central argument”

CHANGE TO:

“that’s the central argument”

REASON:

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157:13

CHANGE FROM:

“some of nuance”

CHANGE TO:

“some of the nuance”

REASON:

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160:9

CHANGE FROM:

“defining stories”

CHANGE TO:

“defining what stories”

REASON:

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160:13

CHANGE FROM:

“that the arguments”

CHANGE TO:

“that the argument”

REASON:

Transcription Error

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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

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163:20–21

CHANGE FROM:

“defending the ing statute”

CHANGE TO:

“defending the statute”

REASON:

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165:5

CHANGE FROM:

“So it less”

CHANGE TO:

“So it’s less”

REASON:

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166:11

CHANGE FROM:

“Bartolmucci”

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“Bartolomucci”

REASON:

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169:19–20

CHANGE FROM:

“he is poor judge”

CHANGE TO:

“he is a poor judge”

REASON:

Transcription Error

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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

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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

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176:18

CHANGE FROM:

“I am political scientist”

CHANGE TO:

“I am a political scientist”

REASON:

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177:22

CHANGE FROM:

“repeal was”

CHANGE TO:

“repeal which is”

REASON:

Transcription Error

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180:13, 180:19

CHANGE FROM:

“Galinsky”

CHANGE TO:

“Golinski”

REASON:

Typographical Error

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Gary Michael Segura Errata Sheet for July 8, 2011 Deposition

32