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Perry v. Scharzenneger Exhibits to Prop. 8 Proponents' Response to April 13, 2010, Order to Show Cause Why Record of Evidence Should Not Be Closed, And Motion for Contempt, No. 09-Cv-2292 (N.D.cal. Apr. 16, 2010)

Perry v. Scharzenneger Exhibits to Prop. 8 Proponents' Response to April 13, 2010, Order to Show Cause Why Record of Evidence Should Not Be Closed, And Motion for Contempt, No. 09-Cv-2292 (N.D.cal. Apr. 16, 2010)

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COOPER AND KIRK, PLLC Charles J. Cooper (DC Bar No. 248070)* ccooper@cooperkirk.com David H. Thompson (DC Bar No. 450503)* dthompson@cooperkirk.com Howard C. Nielson, Jr. (DC Bar No. 473018)* hnielson@cooperkirk.com Nicole J. Moss (DC Bar No. 472424)* nmoss@cooperkirk.com Peter A. Patterson (Ohio Bar No. 0080840)* ppatterson@cooperkirk.com 1523 New Hampshire Ave. N.W., Washin
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COOPER AND KIRK, PLLC Charles J. Cooper (DC Bar No. 248070)* ccooper@cooperkirk.com David H. Thompson (DC Bar No. 450503)* dthompson@cooperkirk.com Howard C. Nielson, Jr. (DC Bar No. 473018)* hnielson@cooperkirk.com Nicole J. Moss (DC Bar No. 472424)* nmoss@cooperkirk.com Peter A. Patterson (Ohio Bar No. 0080840)* ppatterson@cooperkirk.com 1523 New Hampshire Ave. N.W., Washin

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Case3:09-cv-02292-VRW Document633

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COOPER AND KIRK, PLLC Charles J. Cooper (DC Bar No. 248070)* ccooper@cooperkirk.com David H. Thompson (DC Bar No. 450503)* dthompson@cooperkirk.com Howard C. Nielson, Jr. (DC Bar No. 473018)* hnielson@cooperkirk.com Nicole J. Moss (DC Bar No. 472424)* nmoss@cooperkirk.com Peter A. Patterson (Ohio Bar No. 0080840)* ppatterson@cooperkirk.com 1523 New Hampshire Ave. N.W., Washington, D.C. 20036 Telephone: (202) 220-9600, Facsimile: (202) 220-9601 LAW OFFICES OF ANDREW P. PUGNO Andrew P. Pugno (CA Bar No. 206587) andrew@pugnolaw.com 101 Parkshore Drive, Suite 100, Folsom, California 95630 Telephone: (916) 608-3065, Facsimile: (916) 608-3066 ALLIANCE DEFENSE FUND Brian W. Raum (NY Bar No. 2856102)* braum@telladf.org James A. Campbell (OH Bar No. 0081501)* jcampbell@telladf.org 15100 North 90th Street, Scottsdale, Arizona 85260 Telephone: (480) 444-0020, Facsimile: (480) 444-0028 ATTORNEYS FOR DEFENDANT-INTERVENORS DENNIS HOLLINGSWORTH, GAIL J. KNIGHT, MARTIN F. GUTIERREZ, MARK A. JANSSON, and PROTECTMARRIAGE.COM – YES ON 8, A PROJECT OF CALIFORNIA RENEWAL * Admitted pro hac vice UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA KRISTIN M. PERRY, SANDRA B. STIER, PAUL T. KATAMI, and JEFFREY J. ZARRILLO, Plaintiffs, v.

CASE NO. 09-CV-2292 VRW DECLARATION OF JESSE PANUCCIO IN SUPPORT OF DEFENDANT-INTERVENORS’ RESPONSE TO APRIL 13, 2010 ORDER TO SHOW CAUSE AND MOTION FOR CONTEMPT Judge: Chief Judge Vaughn R. Walker

24 25 26 27 28 ARNOLD SCHWARZENEGGER, in his official capacity as Governor of California; EDMUND G. BROWN, JR., in his official capacity as Attorney General of California; MARK B. HORTON, in his official capacity as Director of the California Department of Public Health and State Registrar of Vital Statistics; LINETTE

DECLARATION OF JESSE PANUCCIO CASE NO. 09-CV-2292 VRW

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SCOTT, in her official capacity as Deputy Director of Health Information & Strategic Planning for the California Department of Public Health; PATRICK O’CONNELL, in his official capacity as Clerk-Recorder for the County of Alameda; and DEAN C. LOGAN, in his official capacity as Registrar-Recorder/County Clerk for the County of Los Angeles, Defendants, and PROPOSITION 8 OFFICIAL PROPONENTS DENNIS HOLLINGSWORTH, GAIL J. KNIGHT, MARTIN F. GUTIERREZ, HAKSHING WILLIAM TAM, and MARK A. JANSSON; and PROTECTMARRIAGE.COM – YES ON 8, A PROJECT OF CALIFORNIA RENEWAL, Defendant-Intervenors.

Additional Counsel for Defendant-Intervenors ALLIANCE DEFENSE FUND Timothy Chandler (CA Bar No. 234325) tchandler@telladf.org 101 Parkshore Drive, Suite 100, Folsom, California 95630 Telephone: (916) 932-2850, Facsimile: (916) 932-2851 Jordan W. Lorence (DC Bar No. 385022)* jlorence@telladf.org Austin R. Nimocks (TX Bar No. 24002695)* animocks@telladf.org 801 G Street NW, Suite 509, Washington, D.C. 20001 Telephone: (202) 393-8690, Facsimile: (202) 347-3622 * Admitted pro hac vice

DECLARATION OF JESSE PANUCCIO CASE NO. 09-CV-2292 VRW

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I, Jesse Panuccio, declare as follows: 1. I am an attorney licensed to practice law in the State of Florida and the District of

Columbia and am admitted pro hac vice in this case. I am an associate at the law firm of Cooper & Kirk, PLLC, counsel of record for Defendant-Intervenors Dennis Hollingsworth, Gail Knight,

5 6 7 8 9 10 11 12 3. 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 1
DECLARATION OF JESSE PANUCCIO CASE NO. 09-CV-2292 VRW

Martin Gutierrez, Mark Jansson, and ProtectMarriage.com. I make this declaration in support of Defendant-Intervenors’ Response to the Court’s April 13 Order to Show Cause. I have personal knowledge of the facts stated herein and could testify and would testify competently thereto if called upon to do so. 2. Attached hereto as Exhibit A is a true and correct copy of a letter counsel for

Californians Against Eliminating Basic Rights sent to me on March 31, 2010. Attached hereto as Exhibit B is a true and correct copy of a letter I sent on March 23,

2010, to counsel for No on Proposition 8, Campaign for Marriage Equality, A Project of the American Civil Liberties Union (“ACLU”) and Equality California (“EQCA”). Attached hereto as Exhibit C is a true and correct copy of a letter counsel for ACLU sent to me on March 31, 2010. Attached hereto as Exhibit D is a true and correct copy of a letter counsel for EQCA sent to me on April 16, 2010. 4. Attached hereto as Exhibit E is a true and correct copy of a letter I sent on April 13,

2010, to counsel for the ACLU and EQCA. 5. Attached hereto as Exhibit F is a true and correct copy of a letter counsel for ACLU sent

to me on April 15, 2010. 6. Attached hereto as Exhibit G is a true and correct copy of a letter I sent on April 15,

2010, to counsel for the ACLU and EQCA. 7. Attached hereto as Exhibit H is a true and correct copy of a letter counsel for Plaintiffs

sent to counsel for the ACLU sent to me on April 15, 2010.

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8.

Attached hereto as Exhibit I is a true and correct copy of a letter counsel for ACLU sent

to me on April 16, 2010. 9. Attached hereto as Exhibit J is a true and correct copy of a letter counsel for ACLU sent

to counsel for Plaintiffs on April 16, 2010. 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 2
DECLARATION OF JESSE PANUCCIO CASE NO. 09-CV-2292 VRW

I declare under penalty of perjury that the foregoing is true and correct. Executed this 16th day of April, 2010. By: /s/ Jesse Panuccio Jesse Panuccio

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Exhibit A

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Exhibit B

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Cooper & Kirk
Lawyers
Jesse Panuccio jpanuccio@cooperkirk.com

1523 New Hampshire Avenue, N.W. Washington, D.C. 20036 March 23, 2010 VIA ELECTRONIC MAIL

A Professional Limited Liability Company

(202) 220-9600 Fax (202) 220-9601

Mr. Stephen V. Bomse Orrick, Herrington & Sutcliffe LLP 450 Howard Street San Francisco, CA 94105-2669 Ms. Lauren Whittemore Fenwick & West LLP 555 California Street, Suite 1200 San Franciso, CA 94104 Re: Perry v. Schwarzenegger, et al., N.D. Cal. Case No. C-09-2292-VRW

Dear Mr. Bomse and Ms. Whittemore: I write in regards to the ongoing discovery dispute between the Defendant-Intervenors and your clients (hereinafter “ALCU” and “EQCA”) in the above-referenced matter. At the hearing on March 16, 2010, you twice represented that the ACLU and EQCA had produced all “public” documents responsive to the document requests in the subpoenas served by DefendantIntervenors. See Hr’g of March 16, 2010, Tr. (rough) at 20:2-3 (“And of course all of the public documents were produced voluntarily.”); id. at 64:10-12 (“I think [Plaintiffs’ counsel] also has made the argument that I was about to make in this reply which is all public documents were produced.”). See also id. at 55:3-5 (statement of Plaintiffs’ counsel) (“There were many radio ads, many television ads, many print materials, many documents that were produced by the third parties before trial.”). A similar representation was also made in your clients’ joint filing of March 11, 2010. See Doc # 614 at 6 (“But if it was public, then EQCA and the ACLU have already produced it voluntarily.”). To date, the has ACLU produced a total of only 149 pages (81 documents) and EQCA has produced a total of only 286 pages (also consisting of fewer total documents). Upon rereview of these minimal productions, we are concerned that the ACLU and EQCA are in possession of responsive, public documents that have not, in fact, been produced by these organizations. For example, it appears that neither the ACLU nor EQCA has, to the best of our knowledge, produced a single audio-video file of radio, television, or Internet advertisements, despite the massive volume of radio, television, and Internet advertising conducted by the

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Cooper & Kirk
Lawyers

Stephen V. Bomse, Esq. Lauren Whittemore, Esq. March 23, 2010 Page 2 of 2 ACLU, EQCA, and other No-on-8 groups. Indeed, the following responsive videos appear on the ACLU’s website, yet were not produced by the ACLU: http://www.aclu.org/lgbtrights/freedom-alert-we-could-lose-marriage; http://www.aclu.org/lgbt-rights/why-marriagematters; http://www.aclu.org/lgbt-rights/freedom-alert-california-marriage-danger. Given the representations made in the ACLU’s and EQCA’s declarations in recent days—including that hundreds of individuals were deeply engaged in the formulation of $45 million worth of an umbrella coalition’s messaging and strategy (and thus received final copies of public messaging such as blast emails, audio-video files, and the like)—the organizations and their members presumably possess all such public documents that are responsive to the subpoenas. See, e.g., Doc # 609 at ¶ 12 (averring that “[m]any of the staff and board members of EQCA joined campaign-related email lists and as a result received numerous emails each week during the campaign.”); Doc # 610 at ¶ 7 (averring that the ACLU was “regularly working with approximately 10 … groups” to “formulate[] messages tailored to [specific] communities”). Accordingly, Defendant-Intervenors must respectfully request that, pursuant to the representations made to the Court, the ACLU and EQCA immediately supplement their limited productions with all responsive, public documents—including, but not limited to, television, radio, and other audio-video files, flyers, Internet and blog posts, print ads, and blast emails—in their possession. If the ACLU and EQCA refuse to make such a production, then we must respectfully request that you provide a basis for withholding such documents and correct the record with the Court so that Defendant-Intervenors can promptly consider what further action may be necessary. Thank you for your attention to this matter.

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Exhibit C

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Exhibit D

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Exhibit E

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Cooper & Kirk
Lawyers
Jesse Panuccio jpanuccio@cooperkirk.com

1523 New Hampshire Avenue, N.W. Washington, D.C. 20036 April 13, 2010 VIA ELECTRONIC MAIL

A Professional Limited Liability Company

(202) 220-9600 Fax (202) 220-9601

Mr. Stephen V. Bomse Orrick, Herrington & Sutcliffe LLP 450 Howard Street San Francisco, CA 94105-2669 Ms. Lauren Whittenmore Fenwick & West LLP 555 California Street, Suite 1200 San Franciso, CA 94104 Re: Perry v. Schwarzenegger, et al., N.D. Cal. Case No. C-09-2292-VRW

Dear Mr. Bomse and Ms. Whittemore: I write in regards to the ongoing discovery dispute between the Defendant-Intervenors (hereinafter “Proponents”) and your clients (hereinafter “ALCU” and “EQCA”) in the abovereferenced matter. The Ninth Circuit’s April 12 order dismissing your clients’ appeal of the District Court’s March 5 and March 22 orders means that the stay of those orders is no longer in place. Accordingly, the ACLU and EQCA are under an obligation “to produce all documents in [their] possession that contain, refer or relate to arguments for or against Proposition 8, except those communications solely among members of [the] core group[s]” the District Court has identified. Doc # 610 at 14. According to the District Court’s March 22 order, the ACLU and EQCA were to meet that obligation in full by March 31, 2010, leaving Proponents twelve days— until April 12, 2010—to review the documents and “make [an] appropriate motion or submission” to “supplement their trial record with documents obtained through this production.” Doc # 623 at 24. In an order issued today, the District Court noted that the Ninth Circuit stay was no longer in effect and that Proponents had not yet made the April 12 submission contemplated in the March 22 order. Proponents have not made that submission, of course, because during the pendency of the stay the ACLU and EQCA did not produce any documents pursuant to the District Court’s orders. The District Court has now ordered Proponents to “show cause in writing not later than April 16, 2010 at 5 PM PDT why the evidentiary record should not now be closed.” See Doc # 631 at 2. Accordingly, Proponents must have possession of the documents

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Stephen V. Bomse, Esq. Lauren Whittemore, Esq. April 13, 2010 Page 2 of 2 the ACLU and EQCA are under an obligation to produce. We therefore respectfully request that the ACLU and EQCA immediately meet their production obligations under the March 5 and March 22 orders. Thank you for your prompt attention to this matter.

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Exhibit F

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Exhibit G

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Cooper & Kirk
Lawyers
Jesse Panuccio jpanuccio@cooperkirk.com

1523 New Hampshire Avenue, N.W. Washington, D.C. 20036 April 15, 2010 VIA ELECTRONIC MAIL

A Professional Limited Liability Company

(202) 220-9600 Fax (202) 220-9601

Mr. Stephen V. Bomse, Esq. Orrick, Herrington & Sutcliffe LLP 450 Howard Street San Francisco, CA 94105-2669 Ms. Lauren Whittenmore, Esq. Fenwick & West LLP 555 California Street, Suite 1200 San Franciso, CA 94104 Re: Perry v. Schwarzenegger, et al., N.D. Cal. Case No. C-09-2292-VRW

Dear Mr. Bomse and Ms. Whittemore: Thank you for your letter of today responding to Proponents’ April 13 letter requesting that, in light of the Ninth Circuit’s dismissal of your clients’ appeal, the ACLU and EQCA immediately meet their production obligations under the District Court’s March 5 and March 22 orders. In your letter, you note that the “ACLU and EQCA continue to believe that the orders from which their prior appeal and writ petition were taken were erroneous.” Ltr. from S. Bomse to J. Panuccio (April 15, 2010) at 1 (hereinafter “Bomse Ltr.”). You nonetheless advance the following proposal: “if the district court is willing to amend its March 22, 2010 Order, Doc #623, in a manner consistent with the observations of the Ninth Circuit concerning the existence of a privilege for communications regarding the formulation of campaign strategy and messages among persons who are members of a core group associated in a political campaign, without regard to whether such persons ‘span[] more than one entity,’ [then] the ACLU and EQCA will promptly comply with the order for production as thus amended and will not seek a further stay of that order.” Bomse Ltr. at 1. We agree that while the Ninth Circuit’s most recent order did not address all of your clients’ First Amendment objections to the March production orders, it does make clear that the Court of Appeals, in its January 4 opinion, “did not hold that the privilege cannot apply to a core group of associated persons spanning more than one entity.” Accordingly, we are amenable to your clients’ proposal so long as the Ninth Circuit’s further guidance is applied consistently and evenhandedly to both your clients’ and Proponents’ claims of privilege—which would involve

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Stephen V. Bomse, Esq. Lauren Whittemore, Esq. April 15, 2010 Page 2 of 2 revisiting not only the March 5 and March 22 Orders, but also the Court’s prior discovery and evidentiary rulings with respect to Proponents’ claims of privilege. We also note that to the extent the District Court requires further “information from which a functional interpretation of [an inter-organizational] core group … could be derived,” the opportunity to furnish such information must be afforded to both your clients and Proponents. Order, Perry v. Schwarzenegger, No. 10-15649 (9th Cir. Apr. 12, 2010) at 9 (quoting Doc # 623 at 10). Short of such consistent and evenhanded application of the Ninth Circuit’s additional guidance, Proponents would have no choice but to oppose any amendment to the March 5 and March 22 Orders. As I detailed in my April 13 letter, the March 22 Order contemplated that Proponents would have twelve days from the date of your clients’ production to “make [an] appropriate motion or submission” to “supplement their trial record with documents obtained through this production.” Doc # 623 at 24. Because the ACLU and EQCA have not produced any documents to date, Proponents have, of course, been unable to make such a submission. Nonetheless, the Court has ordered Proponents to “show cause in writing not later than April 16, 2010 at 5 PM PDT why the evidentiary record should not now be closed.” Doc # 631 at 2. In our response to the April 13 Order, we will explain that the ACLU and EQCA have not yet produced any documents and we will advise the Court of this chain of correspondence. For purposes of drafting our response, would you please advise as to when, and in what manner, you plan to approach the Court with your proposal? Lastly, I note that in our response to the April 13 Order, we will request that if the Court rejects your proposal to amend the March 22 Order, then it hold your clients in contempt for failure to comply with the March 5 and March 22 Orders. Thank you for your continued and prompt attention to this matter.

Cc: Theodore J. Boutrous Jr. James Esseks

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Exhibit H

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Client Matter No.: T 36330-00001 Theodore J. Boutrous Jr. Direct: 213.229.7804 Fax: 213.229.6804 TBoutrous@gibsondunn.com April 15, 2010 VIA E-MAIL Stephen V. Bomse Orrick The Orrick Building 405 Howard Street San Francisco, CA 94105-2669 Re: Perry v. Schwarzenegger, N. D. Cal. Case No. C-09-2292-VRW Dear Steve: I write in response to your letter proposing that the parties agree to the district court’s amendment of its March 22, 2010 order (Doc. #623) directing the ACLU and Equality California to produce documents in response to Proponents’ document requests in light of the Ninth Circuit’s April 12, 2010 ruling. In principle, Plaintiffs would not object to the district court’s amending its order in light of the Ninth Circuit’s ruling, but Plaintiffs reserve the right to weigh in with the district court regarding the content of any such amendment. As you know, while the Ninth Circuit noted that it “did not hold [in Perry v. Schwarzenegger, 591 F.3d 1147 (9th Cir. 2010) (“Perry I”)] that the privilege cannot apply to a core group of associated persons spanning more than one entity,” slip op. at 9, it also noted that the district court had ruled that, even if such a privilege did provide protection in some circumstances, the ACLU and Equality California “‘in any event failed to furnish the magistrate [judge] information from which a functional interpretation of [an inter-organizational] core group . . . could be derived.’” Id. (quoting Doc #623 at 10). In addition, as to Proponents’ claim, Magistrate Judge Spero declined to deem privileged communications between Proponents and organizations other than ProtectMarriage.com on the ground that “[P]roponents have never asserted a First Amendment privilege over communications to other organizations.” Doc #372 at 2-3. The magistrate judge further held

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Stephen V. Bomse April 15, 2010 Page 2

that “[e]ven if the Court were to conclude that the First Amendment privilege had been properly preserved as to the communication among the members of core groups other than the Yes on 8 and ProtectMarriage.com campaign, proponents have failed to meet their burden of proving that the privilege applies to any documents in proponents’ possession, custody or control.” Id. The magistrate judge explained that “[t]here is no evidence before the Court regarding any other campaign organization, let alone the existence of a core group within such an organization,” and “no evidence before the Court that any of the documents at issue are private internal communications of such a core group regarding formulation of strategy and messages.” Id. at 3. Lastly, Plaintiffs appreciate your clients’ desire and willingness to end this discovery dispute and request a copy of the production your clients provide to Proponents. Very truly yours, /s/ Theodore J. Boutrous Jr. Theodore J. Boutrous Jr. TJB/eam cc: Jesse Panuccio Lauren Whittemore James Esseks

100850163_1.DOC

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Exhibit I

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Exhibit J

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Case3:09-cv-02292-VRW Document633-10

Filed04/16/10 Page3 of 3

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