Professional Documents
Culture Documents
2 1. I am an attorney licensed to practice law in the State of California and in the Northern
3 District of California. I am an associate in the law firm of Gibson, Dunn & Crutcher LLP, counsel of
4 record for Plaintiffs Kristin M. Perry, Sandra B. Stier, Paul T. Katami, and Jeffrey J. Zarrillo in the
5 above-captioned matter. I make this declaration in support of Plaintiffs’ Motion for Leave to Reopen
6 the Deposition of Ronald Prentice in His Personal Capacity and as the Rule 30(b)(6) Representative
7 for ProtectMarriage.com. The information below is stated on personal knowledge and if called as a
9 2. Attached hereto as Exhibit A is a true and correct copy of relevant excerpts of Volume
11 3. Attached hereto as Exhibit B is a true and correct copy of relevant excerpts of Volume
14 to Plaintiffs. On January 13, Proponents produced 5,007 pages of documents on behalf of Dr. Tam’s
15 counsel. On January 14, Proponents produced 5,741 pages of documents in three separate
17 beginning at approximately 11:22 p.m. and continuing over the next twelve hours, counsel for
18 Proponents notified counsel for Plaintiffs that it had produced over 9,000 pages of documents on
19 behalf of themselves and Dr. Tam. On January 13, Proponents produced approximately 2,600 pages
20 of documents on behalf of themselves and approximately 5,000 pages on behalf of Dr. Tam’s
21 counsel.
23 rolling basis.
24 6. Since Friday, January 15, Plaintiffs’ team of approximately eight lawyers spent a
25 substantial portion of the weekend reviewing over 15,000 pages of documents produced since
26 January 14.
3 9. Attached hereto as Exhibit C is a true and correct copy of a document bates numbered
5 17, 2010.
6 10. Attached hereto as Exhibit D is a true and correct copy of a document bates numbered
8 17, 2010.
9 11. Attached hereto as Exhibit E is a true and correct copy of a document bates numbered
11 12. Attached hereto as Exhibit F is a true and correct copy of a document bates numbered
13 2010.
14 13. Attached hereto as Exhibit G is a true and correct copy of a document bates numbered
16 14. Attached hereto as Exhibit H is a true and correct copy of a document bates numbered
18 17, 2010.
19 I declare, under penalty of perjury under the laws of the United States, that these facts
20 are true and correct and that this Declaration is executed this 19th day of January, 2010, at San
21 Francisco, California.
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2 Pursuant to General Order No. 45 of the Northern District of California, I attest that
3 concurrence in the filing of the document has been obtained from each of the other signatories to this
4 document.
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