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Mitchell F. Thompson, Esq.

R. Todd Thompson, Esq.

Thompson Gutierrez & Alcantara, P.C.

238 Archbishop Flores Street, Suite 801

Hagatna, Guam 96910
Telephone: (671)472-2089
Facsimile: (671)477-5206

William D. Pesch, Esq.

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DISTRICT COURT OF GUAM

APR 1 3 2015
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Guam Family Law Office

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JEANNE G. QUiMATA
CLERK OF COURT

173 Aspinall Avenue, Suite 203

Hagatna, Guam 96910
Telephone: (671) 472-8472
Facsimile: (671)477-5873

Attorneys for Plaintiffs Kathleen M. Aguero and

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Loretta M. Pangelinan

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IN THE DISTRICT COURT OF GUAM

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TERRITORY OF GUAM

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KATHLEEN M. AGUERO and LORETTA

00 Of
CIVIL CASE NO.

M. PANGELINAN,
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Plaintiffs,
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DECLARATION OF
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LORETTA M. PANGELINAN

EDDIE BAZA CALVO in his official capacity as

Governor of Guam; and CAROLYN GARRIDO
in her official capacity as Registrar in the Office
of Vital Statistics, Department of Public
Health and Social Services,

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Defendants.
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I, LORETTA M. PANGELINAN, do hereby declare that:

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1.

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Kathleen M. ("Kate") Aguero and I have been in a committed, loving

relationship for over nine years.

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Case 1:15-cv-00009 GEIGINAL

Document 7 Filed 04/13/15 Page 1 of 3

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I runa maintenance and cleaning company.

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I was born and raised on Guam.

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I am a hard working life-long Guam resident with deep roots in the local

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community.

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I feel that it is important to give back, to the community by helping to raise and

care for children in need on Guam.

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Kate and I are registered foster parents with the Department of Public Health

and Social Services ("DPHSS"), and together we have cared for numerous foster children

through the years. Kate and I are currently caring for three foster children.

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7.

I wish to marry Kate because I love her and I am committed to her for life.

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8.

Kate and I want to celebrate our mutual love through marriage, and we wish to

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marry on Guam so that all our friends and family may attend and participate in our joyous

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occasion.

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9.

While Kate and I could travel thousands of miles to get married in another

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jurisdiction where same-sex marriage is recognized, such travel would be costly and difficult to

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arrange, given our busy schedules and responsibilities.

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10.

More importantly, Kate and I want to be able to invite our family and friends on

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Guam to bear witness to our love and commitment for each other in the same way that

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different-sex couples in Guam are able to do through marriage.

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I believe that Kate and I should not have to leave Guam to have our love and

commitment recognized.

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Case 1:15-cv-00009 Document 7 Filed 04/13/15 Page 2 of 3

12.

On April 8, 2015, Kate and I personally brought our application for a marriage

license to the Vital Statistics Office of DPHSS, in Mangilao, the office that processes marriage

license applications on Guam.

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DPHSS officials refused to accept the application and handed Kate and I two

documents, one, a 2009 opinion letter from the Acting Guam Attorney General and a copy of

certain provisions from Tile 10 of the Guam Code Annotated, including 10 G.C.A. 3207(h),

with language indicating, "[mjarriage means the legal union of persons of the opposite sex."

I declare under penalty of perjury that the foregoing is true and correct.

Dated this 13th day ofApril, 2015.

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LORE! TA M. PANGELINAN
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P153027.RTT

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Case 1:15-cv-00009 Document 7 Filed 04/13/15 Page 3 of 3