3:09-cv-02292 #191

Case3:09-cv-02292-VRW Document191 Filed09/18/09 Page1 of 18
1 GIBSON, DUNN & CRUTCHER LLP

Theodore B. Olson, SBN 38137
2 tolson@gibsondunn.com
Matthew D. McGill, pro hac vice
3 Amir C. Tayrani, SBN 229609
1050 Connecticut Avenue, N.W., Washington, D.C. 20036
4 Telephone: (202) 955-8668, Facsimile: (202) 467-0539
5 Theodore J. Boutrous, Jr., SBN 132009

tboutrous@gibsondunn.com
6 Christopher D. Dusseault, SBN 177557
Ethan D. Dettmer, SBN 196046
7 Sarah E. Piepmeier, SBN 227094
Theane Evangelis Kapur, SBN 243570
8 Enrique A. Monagas, SBN 239087
333 S. Grand Avenue, Los Angeles, California 90071
10 BOIES, SCHILLER & FLEXNER LLP

David Boies, pro hac vice
11 dboies@bsfllp.com
Theodore H. Uno, SBN 248603
12 333 Main Street, Armonk, New York 10504
Telephone: (914) 749-8200, Facsimile: (914) 749-8300
13
Attorneys for Plaintiffs KRISTIN M. PERRY, SANDRA B. STIER,
14 PAUL T. KATAMI, and JEFFREY J. ZARRILLO
[Additional counsel listed on signature page]
15
16 UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF CALIFORNIA
17
KRISTIN M. PERRY, SANDRA B. STIER, CASE NO. 09-CV-2292 VRW
18 PAUL T. KATAMI, and JEFFREY J. ZARRILLO,
Plaintiffs, PLAINTIFFS’ AND PLAINTIFF-
19 INTERVENOR’S JOINT OPPOSITION
v. TO DEFENDANT-INTERVENORS’
20 MOTION FOR A PROTECTIVE ORDER
ARNOLD SCHWARZENEGGER, in his official
21 capacity as Governor of California; EDMUND Date: September 25, 2009
G. BROWN, JR., in his official capacity as Time: 10:00 a.m.
22 Attorney General of California; MARK B. Judge: Chief Judge Walker
HORTON, in his official capacity as Director of Location: Courtroom 6, 17th Floor
23 the California Department of Public Health and
State Registrar of Vital Statistics; LINETTE
24 SCOTT, in her official capacity as Deputy
Director of Health Information & Strategic
25 Planning for the California Department of Public
Health; PATRICK O’CONNELL, in his official
26 capacity as Clerk-Recorder for the County of
Alameda; and DEAN C. LOGAN, in his official
27 capacity as Registrar-Recorder/County Clerk for
the County of Los Angeles,
28 Defendants.
Gibson, Dunn &
Crutcher LLP
09-CV-2292 VRW PLAINTIFFS’ AND PLAINTIFF-INTERVENOR’S JOINT OPPOSITION TO
DEFENDANT-INTERVENORS’ MOTION FOR A PROTECTIVE ORDER
1 TABLE OF CONTENTS
2 Page
3 I. INTRODUCTION .................................................................................................................... 1
4 II. ARGUMENT............................................................................................................................ 2
5 A. The Disputed Discovery Is Relevant to the Factual Disputes the Court
Identified as Requiring Resolution and to the State Interests Advanced
6 by Defendant-Intervenors.............................................................................................. 2
7 1. Defendant-Intervenors Misconstrue Relevance Standards and
Conflate Relevance with Admissibility ............................................................ 3
8
2. Plaintiffs’ Discovery Is Reasonably Calculated to Lead to the
9 Discovery of Party Admissions and Impeachment Evidence
Regarding Defendants’ Positions in this Case and the Factual
10 Disputes Identified by the Court ....................................................................... 4
11 3. Plaintiffs’ Discovery Is Reasonably Calculated to Lead to the
Discovery of Admissible Evidence Concerning the
12 “Motivations for Supporting Prop. 8”............................................................... 5
13 4. Defendant-Intervenors’ Position Is Internally Inconsistent and
Designed to Prevent Discovery Going to Issues Relevant to this
14 Case................................................................................................................... 7
15 B. Defendant-Intervenors’ Claim to a Sweeping First Amendment
Privilege Against Party Discovery Is Makeweight ....................................................... 8
16
III. CONCLUSION....................................................................................................................... 13
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1 TABLE OF AUTHORITIES
2 Page(s)
3 CASES
4 Adolph Coors Co. v. Wallace,
5 570 F. Supp. 202 (N.D. Cal. 1983) .................................................................................................... 8
6 Anderson v. Hale,
No. 00-C-2021, 2001 WL 503045 (N.D. Ill. May 10, 2001)....................................................... 8, 11
7
Bates v. City of Little Rock,
8 361 U.S. 516 (1960)........................................................................................................................... 8
9 Bates v. Jones,
131 F.3d 843 (9th Cir. 1997)(en banc)............................................................................................... 6
10
11 Brock v. Local 375,

860 F.2d 346 (9th Cir. 1988).......................................................................................................... 8, 9
12
Castaneda v. Burger King Corp., --- F.R.D. ---,
13 2009 WL 2748932 (N.D. Cal. Aug. 19, 2009)................................................................................... 3
14 Christ Covenant Church v. Town of Sw. Ranches,
No. 07-60516, 2008 U.S. Dist. LEXIS 49483 (S.D. Fla. June 29, 2008) .......................................... 9
15
16 City of Los Angeles v. County of Kern,

462 F. Supp. 2d 1105 (C.D. Cal. 2006) ................................................................................... 5, 6, 10
17
Crawford v. Board of Education,
18 458 U.S. 527 (1982)........................................................................................................................... 6
19 Del Campo v. Kennedy,

236 F.R.D. 454 (N.D. Cal. 2006)....................................................................................................... 3
20
Dep’t of Agric. v. Moreno,
21
413 U.S. 528 (1973)........................................................................................................................... 5
22
Dole v. Service Employees Union,
23 950 F.2d 1456 (9th Cir. 1991)............................................................................................................ 8
24 Gibson v. Florida Legislative Investigation Committee,

372 U.S. 539 (1963)........................................................................................................................... 8
25
Grandbouche v. Clancy,
26 825 F.2d 1463 (10th Cir. 1987).......................................................................................................... 9
27
In re Motor Fuel Temperature Sales Practices Litig.,
28 No. 07-MD-1840-KHV, 2009 U.S. Dist. LEXIS 66005 (D. Kan. May 28, 2009) ................ 8, 10, 11
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1 TABLE OF AUTHORITIES
[Continued]
2
Page(s)
3
Jones v. Bates,
4
127 F.3d 839 (9th Cir. 1997).............................................................................................................. 6
5
NAACP v. Alabama,
6 357 U.S. 449 (1958)........................................................................................................................... 8
7 Pers. Adm’r of Mass. v. Feeney,

442 U.S. 256, 260 (1979)................................................................................................................... 5
8
S.D. Farm Bureau, Inc. v. Hazeltine,
9 340 F.3d 583 (8th Cir. 2003).............................................................................................................. 5
10
SASSO v. Union City,
11 424 F.2d 291 (9th Cir. 1970).............................................................................................................. 6
12 Washington v. Davis,
426 U.S. 229 (1976)........................................................................................................................... 5
13
Washington v. Seattle Sch. Dist. No. 1,
14 458 U.S. 457 (1982)........................................................................................................................... 5
15
Wilkinson v. FBI,
16 111 F.R.D. 432 (C.D. Cal. 1986) ..................................................................................................... 10
17 RULES
18 Fed. R. Evid. 801(d)............................................................................................................................... 5
19
20
21
22
23
24
25
26
27
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1 I. INTRODUCTION
2 Defendant-Intervenors—the official proponents of Proposition 8 and intervenors in this
3 case—seek a protective order preventing any and all discovery into documents or communications
4 concerning Proposition 8, except those “available to the public at large.” Doc #187-14 at 3. Despite
5 Plaintiffs’ attempts to negotiate the scope of discovery and willingness to maintain the confidentiality
6 of specific information where confidentiality is appropriate, Defendant-Intervenors instead stake out
7 a rigid, across-the-board position that virtually none of their documents are discoverable no matter
8 what they may say or address. Defendant-Intervenors’ position, and their broad-strokes motion for
9 protective order, lack merit.
10 In defense of their position, Defendant-Intervenors try to distract this Court from the
11 numerous important issues in play in this case, and to recast the case altogether as one about
12 “protection of core First Amendment activities.” Doc #187 at 7. But this case is, and always has
13 been, about the vindication of Plaintiffs’ rights under the United States Constitution—rights that are
14 violated every day that California’s Proposition 8 remains in effect. In order to build their case and
15 be in a position to address issues that may arise at trial, Plaintiffs are entitled under the Federal Rules
16 of Civil Procedure to liberal discovery of any non-privileged information that may lead to the
17 discovery of admissible evidence.
18 Defendant-Intervenors’ attempt to portray themselves as like any other “California voter or
19 any person who weighed in on the Prop. 8 debate,” id. at 10, is disingenuous and must fail.
20 Defendant-Intervenors voluntarily made themselves parties to this case. As such, they have a
21 responsibility, not necessarily co-extensive with that of third-parties, to produce any and all non-
22 privileged documents that are relevant to any issue that may be part of a trial of Plaintiffs’ important
23 claims. Moreover, Defendant Intervenors’ attempt to invoke the First Amendment to block the
24 discovery of virtually all of their documents cannot be supported. Defendant-Intervenors’ attempts to
25 avoid such discovery entirely and shield relevant documents—documents that may contradict the
26 very arguments they advance in this case—lack merit, and their motion should be denied.
27
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1 II. ARGUMENT
2 A. The Disputed Discovery Is Relevant to the Factual Disputes the Court Identified
as Requiring Resolution and to the State Interests Advanced by Defendant-
3 Intervenors
4 Defendant-Intervenors have consistently argued that “there are no genuine issues of material
5 fact that must be resolved at trial” and that they “are entitled to judgment as a matter of law.” Doc
6 #172-1 at 30. It thus comes as no surprise that they believe all discovery propounded to them is
7 irrelevant and that the Court need only rely on public records and prior California Supreme Court
8 opinions to adjudicate this matter. Doc #187 at 9, 11-13. While Plaintiffs believe that there are
9 certain issues in this case that can be resolved in Plaintiffs’ favor as a matter of law and without resort
10 to detailed factual inquiry (and so argued in their motion for a preliminary injunction), the Court has
11 set this case for trial in January 2010 and set a discovery schedule within which the parties must
12 prepare the case for a full trial on the merits. The issues on which Plaintiffs intend to prepare a
13 record for trial include, but are not limited to, the fifteen specific factual issues that the Court
14 identified in its June 30, 2009 Order. Doc #76 at 7-9.
15 In spite of the Court’s direction that the parties prepare this case for trial, Defendant-
16 Intervenors have steadfastly maintained their position that no trial is needed and that there are no
17 factual issues to be resolved. This motion is simply the latest manifestation of that position, as
18 Defendant-Intervenors ask the Court to prohibit virtually all discovery sought by Plaintiffs, taking the
19 remarkable position that even readily accessible “documents that were available to the electorate at
20 large” are not relevant or admissible. Doc #187 at 9 n.2. Thus, according to Defendant-Intervenors,
21 documents distributed to millions of potential voters specifically laying out why they should support
22 Prop. 8 are not discoverable if the list of recipients was targeted, for example, to all registered
23 Republicans or voters who had supported particular causes in the past. Defendant-Intervenors also
24 would take the position that no internal document, or communication with a third party, including
25 consultants or other vendors assisting them on the campaign, could possibly be relevant regardless of
26 what it says, even if it would constitute a binding admission or a statement directly at odds with
27 representations that Defendant-Intervenors now make to the Court.
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1 In an effort to reach compromise, Plaintiffs negotiated in good faith with Defendant-
2 Intervenors to narrow document requests, even offering to enter into confidentiality agreements in
3 order to address their fears of harassment and reprisal. See Declaration of Matthew D. McGill, ¶ 2-3,
4 attached hereto as Exh. A. Plaintiffs’ offers to compromise, however, were rejected. Id. at ¶ 3.
5 1. Defendant-Intervenors Misconstrue Relevance Standards and Conflate

Relevance with Admissibility
6
Defendant-Intervenors’ limited view of what is relevant and discoverable runs counter to the
7
broad scope of discovery permitted by the Federal Rules of Civil Procedure. “The scope of discovery
8
under Rule 26 is broad; ‘[r]elevant information need not be admissible at the trial if the discovery
9
appears reasonably calculated to lead to the discovery of admissible evidence.’” Castaneda v. Burger
10
King Corp., --- F.R.D. ---, 2009 WL 2748932, at *2 (N.D. Cal. Aug. 19, 2009) (quoting Fed. R. Civ.
11
P. 26(b)(1)) (alteration in original). Here, Defendant-Intervenors assert that they will only produce
12
documents “available to the public at large.” Doc #187-14 at 3. This position is plainly designed to
13
prevent Plaintiffs from ever seeing anything but the most carefully crafted and broadly disseminated
14
messages relating to their campaign. And Defendant-Intervenors offer no explanation of why a
15
communication to the voters “at large” may be relevant, but a communication to a targeted but still
16
large group of voters could not possibly be relevant.
17
Moreover, Defendant-Intervenors’ position confuses the separate standards for admissibility
18
at trial and for discovery by improperly seeking to limit Plaintiffs’ discovery to those documents
19
admissible at trial. See Doc #187 at 10 (“The Supreme Court, however, has never authorized the use
20
of the type of [nonpublic] information at issue here to ascertain the purpose of an initiative”). But
21
“[a]s emphasized in the Advisory Committee Notes [to Rule 26], the language of Rule 26(b) ‘make[s]
22
clear the broad scope of examination and that it may cover not only evidence for use at trial but also
23
inquiry into matters in themselves inadmissible as evidence but which will lead to the discovery of
24
evidence.’” Del Campo v. Kennedy, 236 F.R.D. 454, 457 (N.D. Cal. 2006) (emphasis added)
25
(alteration in original). Defendant-Intervenors cannot draw a bright line, as they attempt to here, that
26
a document is under no circumstances discoverable unless it was shared with the public at large.
27
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1 Furthermore, Defendant-Intervenors focus myopically on a single issue—voter intent—while
2 ignoring all other issues to which Plaintiffs’ discovery requests may be relevant and other purposes
3 for which documents produced may be admissible. Doc #187 at 10. Specifically, and as explained
4 below, Plaintiffs’ discovery requests are reasonably calculated to lead to the discovery of
5 (1) admissible evidence concerning the rationality and strength of Defendant-Intervenors’ purported
6 state interests and whether voters could reasonably accept them as a basis for supporting Prop. 8, and
7 (2) admissible evidence related to the factual disputes the Court identified as matters to be resolved at
8 trial in its June 30, 2009 Order. As such, the discovery Plaintiffs seek is reasonably calculated to lead
9 to the discovery of admissible evidence and is thus discoverable.1
10 2. Plaintiffs’ Discovery Is Reasonably Calculated to Lead to the Discovery of

Party Admissions and Impeachment Evidence Regarding Defendants’
11 Positions in this Case and the Factual Disputes Identified by the Court
12 Defendant-Intervenors advance just one argument about the relevance of the disputed
13 discovery: that it is irrelevant because the requests seek to “ascertain the purpose of an initiative.”
14 Doc #187 at 10. While Plaintiffs believe that much of their discovery is in fact relevant to this issue,
15 Plaintiffs’ discovery is not, and does not have to be, limited just to the discovery of the motivations
16 for supporting Prop. 8; rather, the discovery propounded is also calculated to lead to the discovery of
17 party admissions and impeachment evidence regarding the purported state interests that Defendant-
18 Intervenors’ advance and the factual disputes identified in the Court’s June 30, 2009 Order. Certainly
19 statements made by Defendant-Intervenors that are at odds with the positions they are taking in this
20 action would not just be discoverable, but would be admissible at trial as a party admission, or could
21
22
1 The discovery does not intrude on the “subjective, unexpressed motivations” of Prop. 8’s
23 proponents. Doc #187 at 8. Defendant-Intervenors refuse to produce communications they
made to tens of thousands of voters, on the theory that those communications were targeted
24 and not made available to every voter in the State. They refuse to produce communications,
even when made outside of their own organization, that would demonstrate their conclusions
25 about what voters might accept as purposes and rationales for Prop. 8. They refuse to produce
information that would show the size and strength of forces mustered against gay and lesbian
26 individuals, even as they assert that gay and lesbian individuals are a politically powerful
group. Defendant-Intervenors’ evaluation of Prop. 8 and communications with others about it
27 are relevant to understanding the “immediate objective” and “ultimate effect” of Prop. 8,
Doc #76 at 9, necessary to prepare for depositions and cross-examination at trial, and
28 reasonably calculated to lead to the discovery of other relevant information.
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1 be used as impeachment evidence. See, e.g., Fed. R. Evid. 801(d). Indeed, given the Defendant-
2 Intervenors’ role as the official proponents of Prop. 8, their voluntary and willful participation in the
3 case, and their role as the defenders of Prop. 8 in this case, their prior statements or admissions
4 regarding the purported state interests they now advance and the factual underpinnings of those
5 asserted interests are relevant as to whether these interests are indeed legitimate. Simply put,
6 Plaintiffs have the right to discover these prior statements or admissions to properly challenge
7 Defendant-Intervenors’ current characterizations of the positions they espouse in this case.
8 3. Plaintiffs’ Discovery Is Reasonably Calculated to Lead to the Discovery of

Admissible Evidence Concerning the “Motivations for Supporting
9 Prop. 8”
10 Similarly, whether a defendant acted with discriminatory intent or purpose is a relevant
11 consideration in an equal protection challenge. See Washington v. Davis, 426 U.S. 229, 239-40
12 (1976); Washington v. Seattle Sch. Dist. No. 1, 458 U.S. 457, 484-85 (1982) (“when facially neutral
13 legislation is subjected to equal protection attack, an inquiry into intent is necessary to determine
14 whether the legislation in some sense was designed to accord disparate treatment on the basis of
15 racial considerations.”); see also Pers. Adm’r of Mass. v. Feeney, 442 U.S. 256, 260 (1979); Dep’t of
16 Agric. v. Moreno, 413 U.S. 528, 534-35 (1973). The Court has already recognized the relevance of
17 this evidence, identifying the “motivations for supporting Prop. 8” as one of the fifteen factual
18 disputes that likely need to be resolved at trial. Doc #76 at 9.
19 More specifically, where intent is relevant, “the Court may look to the nature of the initiative
20 campaign to determine the intent of the drafters and voters in enacting it.” City of Los Angeles v.
21 County of Kern, 462 F. Supp. 2d 1105, 1114 (C.D. Cal. 2006) (citing Seattle Sch. Dist. No. 1, 458
22 U.S. at 471); see also S.D. Farm Bureau, Inc. v. Hazeltine, 340 F.3d 583, 593-96 (8th Cir. 2003)
23 (“Plaintiffs have the burden of proving discriminatory purpose and can look to several sources to
24 meet that burden.”). In South Dakota Farm Bureau, the Court considered whether the drafters of a
25 referendum purposely discriminated against interstate commerce. 340 F.3d at 593. The Court
26 observed that “[t]he most obvious [source of evidence] would be direct evidence that the drafters of
27 Amendment E or the South Dakota populace that voted for Amendment E intended to discriminate
28 against out-of-state businesses.” Id. Accordingly, the Court reviewed both public and nonpublic
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1 materials, including notes from the amendment drafting meetings and testimony by individuals
2 involved with the drafting of the proposed amendment, focusing on the “desire” of the drafters to
3 block out of state entities from farming in South Dakota. Id. The court noted that it would be
4 impossible to ascertain the intention of all of the voters; however, the Court did “have evidence of the
5 intent of individuals who drafted the amendment that went before the voters. It is clear that those
6 individuals had a discriminatory purpose.” Id. at 596. Thus, on the strength of the drafters’ public
7 and nonpublic statements, the court held that the referendum was unconstitutional as it was motivated
8 by a discriminatory purpose. Id. at 596-98.
9 Defendant-Intervenors’ reliance on SASSO v. Union City, 424 F.2d 291 (9th Cir. 1970) is
10 unavailing.2 SASSO is not on point, both because it did not concern a discovery dispute, and also
11 because Plaintiffs are not seeking the “private attitudes of voters.” That decision sheds no light on
12 whether the beliefs of Prop. 8’s official proponents—voluntary parties to this litigation who willfully
13 sought out party status and likely will present testimony at trial—are relevant to a determination of
14 discriminatory purpose. Furthermore, SASSO was decided in 1970, six years before the Supreme
15 Court decided Washington v. Davis, 426 U.S. 229 (1976), which held that a neutral law does not
16 violate the Equal Protection Clause solely because it results in a racially disproportionate impact;
17 instead, the disproportionate impact must be traced to a purpose to discriminate on the basis of a
18 protected class. In Washington, the Supreme Court held that whether there was a discriminatory
19 intent in passing a law was a relevant inquiry. 426 U.S. at 239-40. Accordingly, discovery into
20 Defendant-Intervenors’ “motivations for supporting Prop. 8” is relevant and appropriate.
21
22
23
2 Defendant-Intervenors’ reliance on other case law cited in its motion is equally misplaced.
24
Jones v. Bates, 127 F.3d 839 (9th Cir. 1997) was reversed en banc. Bates v. Jones, 131 F.3d
25 843 (9th Cir. 1997)(en banc). The en banc panel determined that the proper inquiry was voter
notice, not voter intent and did not address the type of discovery at issue in this action. See id.
26 at 846. Crawford v. Board of Education, 458 U.S. 527 (1982) is irrelevant to this inquiry as it
concerned a legislatively created referendum—not the type of discovery at issue in this action.
27 Finally, Defendant-Intervenors’ reliance on California law is unavailing given that federal
courts “may look to the nature of the initiative campaign to determine the [discriminatory]
28 intent of the drafters and voters in enacting it.” City of Los Angeles, 462 F. Supp. 2d at 1114.
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1 4. Defendant-Intervenors’ Position Is Internally Inconsistent and Designed

to Prevent Discovery Going to Issues Relevant to this Case
2
Defendant-Intervenors maintain that the only documents they will produce are
3
communications that were “available to the public at large.” Doc #187-14 at 3. This “compromise
4
position,” Doc #187 at 9 n.2, is at odds with the reality of their Yes on 8 campaign, which relied
5
heavily on targeted messaging, which by definition constitutes messages not “available to the public
6
at large.” See F. Schubert & J. Flint, Passing Prop 8; Smart Timing and Messaging Convinced
7
California Voters to Support Traditional Marriage, Politics (Feb. 2009), attached hereto as Exh. B.
8
Accordingly, the documents that will be produced under Defendant-Intervenors’ “compromise
9
position” will not accurately reflect the “motivations for supporting Prop. 8” or provide Plaintiffs
10
with a complete picture of relevant evidence regarding their purported state interests and the factual
11
disputes identified by the Court. Such a limitation would allow Defendant-Intervenors to paint an
12
incomplete picture of the information they deliberately communicated to voters and the positions they
13
took on issues that are now directly relevant to this lawsuit. The Court should not allow the
14
Defendant-Intervenors the opportunity to game their discovery obligations.
15
Ironically, Defendant-Intervenors’ argument that Plaintiffs’ discovery is irrelevant is
16
undermined by the discovery they propounded on third-parties, which seeks the same information
17
that Defendant-Intervenors now argue is irrelevant and privileged.3 Doc #182 at 4-48. While
18
Defendant-Intervenors are asserting the complete irrelevance of any documents that they possess as a
19
party to this litigation, they simultaneously are aggressively pursuing documentary evidence from
20
other parties and non-parties alike.
21
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25
26
3 Since Prop. 8 was passed and became the law of California, information obtained from its
27
proponents is obviously relevant to the issues in this litigation in a way that information
28 sought from those who unsuccessfully opposed it is not.
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1 B. Defendant-Intervenors’ Claim to a Sweeping First Amendment Privilege Against

Party Discovery Is Makeweight
2
Defendant-Intervenors contend that even if the documents Plaintiffs seek are discoverable, all
3
of them nevertheless are subject to a First Amendment privilege against disclosure. That sweeping
4
claim of privilege fails for at least three reasons.
5
1. Although Defendant-Intervenors’ communications concerning the Prop. 8 referendum
6
campaign are core political speech and undeniably entitled to broad First Amendment protection,
7
Defendant-Intervenors should not now be heard to complain that Plaintiffs are seeking discovery of
8
the communications most relevant to Plaintiffs’ claims for relief. Rather than participate as amici
9
curiae, Defendant-Intervenors elected to intervene in this action as parties, and they cannot now
10
evade the responsibilities that attach to the party status they voluntarily assumed, including the
11
obligation to comply with reasonable requests for discovery.
12
Defendant-Intervenors cite several cases upholding a First Amendment privilege against
13
compelled disclosure of confidential membership information, but in none of those cases was the
14
entity resisting disclosure a voluntary participant in underlying litigation. In NAACP v. Alabama, 357
15
U.S. 449 (1958), the NAACP was the respondent to an equity suit brought by the Attorney General of
16
Alabama. Id. at 452-53. Bates v. City of Little Rock, 361 U.S. 516 (1960) involved generally-
17
applicable ordinances requiring organizations within the municipalities to provide lists of their
18
members. Id. at 517-18. Gibson v. Florida Legislative Investigation Committee, 372 U.S. 539
19
(1963) concerned a legislative committee’s subpoena to which the NAACP was the respondent. Id.
20
at 540. Likewise, Dole v. Service Employees Union, 950 F.2d 1456 (9th Cir. 1991) and Brock v.
21
Local 375, 860 F.2d 346 (9th Cir. 1988), involved subpoenas issued by the Department of Labor to
22
certain labor unions. See Dole, 950 F.2d at 1458; Brock, 860 F.2d at 348.4
23
24
4 The district court rulings cited by Defendant-Intervenors are no different. See In re Motor
25 Fuel Temperature Sales Practices Litig., No. 07-MD-1840-KHV, 2009 U.S. Dist. LEXIS
66005 (D. Kan. May 28, 2009) (defendants resisting discovery of communications with trade
26 associations); Anderson v. Hale, No. 00-C-2021, 2001 WL 503045 (N.D. Ill. May 10, 2001)
(defendant resisting subpoena of third-party electronic records); Adolph Coors Co. v. Wallace,
27 570 F. Supp. 202 (N.D. Cal. 1983) (defendant LGBT advocacy group resisting discovery
from plaintiffs). Though, in Coors, the district court seemed to frown upon the notion that
28 one could “impl[y] a waiver of . . . constitutional safeguards by reason of the party’s decision
[Footnote continued on next page]
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1 Unlike the NAACP and the unions in Dole and Brock, Defendant-Intervenors chose to be
2 parties in this litigation. And their resistance to Plaintiffs’ reasonable discovery is particularly
3 inappropriate given that, in their recent motion for summary judgment, Defendant-Intervenors have
4 squarely placed at issue the subjective intentions of Prop. 8’s supporters by denying that Prop. 8 was
5 motivated by discriminatory animus toward gay and lesbian individuals. See Doc #172-1 at 107 (“It
6 is simply implausible that in acting with surgical precision to preserve and restore the venerable
7 definition of marriage, the people of California somehow transformed that institution into an
8 instrument of bigotry against gays and lesbians.”); id. at 111 (“Plaintiffs’ claim that animus against
9 gays and lesbians is the only possible explanation for the enactment of Proposition 8 is false”).
10 Similarly, in their case management statement, Defendant-Intervenors announced that they would not
11 be able to reach stipulations with Plaintiffs regarding any of the factual underpinnings of the
12 governmental interests on which they now rely. See, e.g., Doc #139 at 23 (refusing to take a position
13 on “[w]hether the exclusion of same-sex couples from marriage leads to increased stability in
14 opposite sex marriage or alternatively whether permitting same-sex couples to marry destabilizes
15 opposite sex marriage”). It is therefore Defendant-Intervenors’ own litigating positions that
16 necessitate the discovery sought by Plaintiffs.
17 2. Defendant-Intervenors have failed to demonstrate how the discovery Plaintiffs seek will
18 diminish Defendant-Intervenors’ associational freedoms. Quite unlike nearly all of the cases
19 Defendant-Intervenors cite, Plaintiffs’ discovery requests do not seek ProtectMarriage.com’s
20 membership list, or a list of donors to the “Yes on 8” cause—even though the latter is available for
21 public inspection under California law. California Sec’y of State, Campaign Finance: Proposition
22 008, http://cal-access.sos.ca.gov/Campaign/Measures/Detail.aspx?id=1302602&session=2007 (last
23
24 [Footnote continued from previous page]

to instigate litigation,” the district court itself recognized that “given the facts at bar” the issue
25 was not implicated there. 570 F. Supp. at 209. Defendant-Intervenors do cite two cases
where the party initiating the litigation thereafter resisted discovery, see Grandbouche v.
26 Clancy, 825 F.2d 1463 (10th Cir. 1987); Christ Covenant Church v. Town of Sw. Ranches,
No. 07-60516, 2008 U.S. Dist. LEXIS 49483 (S.D. Fla. June 29, 2008), but in each case the
27 court found that the First Amendment privilege could not be sustained where the plaintiff
“ha[d] placed certain information into issue.” Grandbouche, 825 F.2d at 1467; see also
28 Christ Covenant Church, 2009 U.S. Dist LEXIS 49483, at *28-*32.
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1 visited Sept. 18, 2009). Plaintiffs rather seek documents relating to the issues the Court has identified
2 as central to this litigation and Defendant-Intervenors’ factual contentions concerning the same,
3 including “the nature of the initiative campaign to determine the intent of the drafters and voters in
4 enacting it.” City of Los Angeles, 462 F. Supp. 2d at 1114.
5 Courts in this Circuit have rejected claims of First Amendment privilege where a litigant
6 seeks to apply it “not to specific membership documents, but instead to prevent any discovery of her
7 files.” Wilkinson v. FBI, 111 F.R.D. 432, 436 (C.D. Cal. 1986); see also id. (“While it is clear that
8 the privilege may be asserted with respect to specific requests for documents raising these core
9 associational concerns, it is equally clear that the privilege is not available to circumvent general
10 discovery.”). Yet, relying principally on an unpublished district court decision from Kansas,
11 Defendant-Intervenors argue that all of their political advocacy communications except those
12 disseminated to the “electorate at large” are privileged from disclosure. Doc #187 at 18 (citing In re
13 Motor Fuel Temperature Sales Practices Litig., No. 07-MD-1840-KHV, 2009 U.S. Dist. LEXIS
14 66005 (D. Kan. May 28, 2009)).
15 Above and beyond the fact that Defendant-Intervenors chose to participate in the lawsuit and
16 chose to place their political communications in issue, there at least two features that distinguish this
17 case from In re Motor Fuel Temperature Sales Practices Litigation.
18 First, Defendant-Intervenors’ claim of privilege is not remotely limited to “confidential
19 communications.” Motor Fuel Litigation, 2009 U.S. Dist. Lexis 66005, at *45. To the contrary,
20 Defendant-Intervenors’ claim of privilege sweeps in all documents responsive to Plaintiffs’ request
21 except those that were disclosed to the “electorate at large.” Doc #187 at 9 n.2; see also Doc #187-7
22 at 6 (Moss Decl.). On Defendant-Intervenors’ view, all communications that were targeted in any
23 manner or fashion to particular recipients are privileged—even if the communications were received
24 by tens of thousands (or more) California voters. See Exh. A (McGill Decl.) at ¶ 3. Thus,
25 Defendant-Intervenors’ claim of privilege sweeps in every article of mail they ever sent—postal or
26 electronic.
27 At the other end of the spectrum, Defendant-Intervenors’ claim of privilege also sweeps in all
28 of their communications with their paid political consultants notwithstanding the fact that those
Gibson, Dunn &

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1 consultants have published articles describing their strategy, Exh. B, and indeed, have sought
2 accolades from trade associations for that strategy. See “The 18th Annual Pollie Awards &
3 Conference,” attached hereto as Exh. C (identifying Schubert Flint Public Affairs’ work on the “Yes
4 on 8” campaign as the recipient of multiple 2009 Pollie Awards).
5 When communications and strategies are widely disseminated and discussed (indeed,
6 trumpeted) in public—as were many of the documents Defendant-Intervenors now claim are
7 privileged from disclosure—it is difficult to envision how disclosure of those documents to Plaintiffs
8 could chill Defendant-Intervenors’ speech.
9 And, in fact, Defendant-Intervenors have made no credible showing of how the discovery
10 Plaintiffs have requested in this case is likely to lead to reprisals against Defendant-Intervenors or
11 their supporters. This is the second feature that distinguishes this case from In re Motor Fuel
12 Temperature Sales Practices Litigation.
13 Defendant-Intervenors have produced declarations that describe “many instances of
14 harassment and retaliation against Protect Marriage’s donors and volunteers that occurred after their
15 affiliation with Protect Marriage became public.” Doc #187-2 at 5 (Prentice Decl.). But the
16 inescapable fact is that Defendant-Intervenors’ affiliation with Protect Marriage has been widely
17 known to the public for more than a year, as has that of their political consultant, Frank Schubert.
18 There is no additional chilling effect on their speech that will accrue, at this late date, from their
19 disclosure of the documents Plaintiffs seek. The public is already aware of the Defendant-
20 Intervenors’ “deeply held moral and political views,” Doc #187-12 at 4 (Tam Decl.), and Defendant-
21 Intervenors have suggested no reason why compliance with discovery is likely to generate a new
22 round of reprisals. Indeed, even Defendant-Intervenors’ own out-of-circuit authorities recognize that
23 “where a Plaintiff does not ask for a membership list, nor ... seek to identify a single anonymous ...
24 member” but rather seek only “to discover what the publicly identified ... members know about [the
25 subject of Plaintiff’s claims] through their personal information and communications with other
26 people,” it “cannot be said that Plaintiff’s subpoenas constitute an arguable threat to associational
27 rights by creating an apparent chilling effect.” Anderson v. Hale, No. 00-C-2021, 2001 WL 503045,
28 at *6. (N.D. Ill. May 10, 2001); see also In re Motor Fuel Temperature Sales Practices Litig., 2009
Gibson, Dunn &

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1 U.S. Dist. LEXIS 66005, at *44 (“To the extent, however, that defendants seek protection of
2 associational membership lists or financial contributor lists that have been publicly disclosed, ... A
3 chilling effect caused by additional disclosure cannot be presumed.”).
4 Even still, to assuage any concerns about the threat of reprisals, in their last meet-and-confer
5 on September 10, Plaintiffs offered to entertain any reasonable confidentiality agreement or
6 procedure for redaction or sealing if Defendant-Intervenors had a good-faith belief that particular
7 documents raised a threat of reprisal to persons whose affiliation with Protect Marriage is not already
8 widely known to the public. Exh. A at ¶ 3. Defendant-Intervenors, however, refused to discuss any
9 potential procedures for designation and treatment of confidential documents. This suggests that the
10 vow of Defendant-Intervenors and their agents to “drastically alter how [they] communicate in the
11 future,” if they are made to comply with ordinary discovery requests, Doc #187-10 at 4 (Jansson
12 Decl.), is motivated less by a fear of reprisals than an unwillingness to fulfill the obligations of a
13 party to litigation in federal court.
14 3. Even under the balancing test that Defendant-Intervenors argue is applicable, Defendant-
15 Intervenors’ claim of privilege must fail. The Court has advised the parties that it wishes to conduct a
16 trial on various factual questions that undergird the constitutional questions raised by Plaintiffs’
17 claims for relief. As detailed above, Plaintiffs’ requests for discovery are plainly relevant to those
18 inquiries and, absent discovery, Plaintiffs have no means available to obtain the documents they seek
19 from Defendant-Intervenors. And to the extent that Defendant-Intervenors have a well-founded,
20 good-faith belief that particular documents could generate reprisals if disclosed to the public,
21 Plaintiffs are willing to negotiate any reasonable confidentiality measures to ensure that the First
22 Amendment rights of Defendant-Intervenors, their agents, and their supporters, are not chilled.
23 ///
24 ///
25 ///
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III. CONCLUSION
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For the foregoing reasons, Plaintiffs and Plaintiff-Intervenor respectfully urge this Court to
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deny Defendant-Intervenors’ motion for protective order and require that they produce all documents
4
responsive to Plaintiffs’ First Set of Requests for Production on or before September 28, 2009.
5
DATED: September 18, 2009
6
GIBSON, DUNN & CRUTCHER LLP
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By: /s/
9 Theodore B. Olson
10 and
12 David Boies
13 Attorneys for Plaintiffs KRISTIN M. PERRY,

SANDRA B. STIER, PAUL T. KATAMI, and
14 JEFFREY J. ZARRILLO
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16 DENNIS J. HERRERA
City Attorney
17 THERESE M. STEWART
Chief Deputy City Attorney
18 DANNY CHOU
Chief of Complex and Special Litigation
19 RONALD P. FLYNN
VINCE CHHABRIA
20 ERIN BERNSTEIN
CHRISTINE VAN AKEN
21 MOLLIE M. LEE
Deputy City Attorneys
22
23
By: /s/
24 Therese M. Stewart
25 Attorneys for Plaintiff-Intervenor

CITY AND COUNTY OF SAN FRANCISCO
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1 ATTESTATION PURSUANT TO GENERAL ORDER NO. 45
2 Pursuant to General Order No. 45 of the Northern District of California, I attest that concurrence
3 in the filing of the document has been obtained from each of the other signatories to this document.
4
6 By: /s/ Theodore B. Olson

Theodore B. Olson
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Case3:09-cv-02292-JW Document191-1 Filed09/18/09 Page1 of 4
EXHIBIT A
1 GIBSON, DUNN & CRUTCHER LLP

Theodore B. Olson, SBN 38137
2 tolson@gibsondunn.com
Matthew D. McGill, pro hac vice
3 Amir C. Tayrani, SBN 229609
1050 Connecticut Avenue, N.W., Washington, D.C. 20036
5 Theodore J. Boutrous, Jr., SBN 132009

tboutrous@gibsondunn.com
6 Christopher D. Dusseault, SBN 177557
Ethan D. Dettmer, SBN 196046
7 Sarah E. Piepmeier, SBN 227094
Theane Evangelis Kapur, SBN 243570
8 Enrique A. Monagas, SBN 239087
333 S. Grand Avenue, Los Angeles, California 90071

David Boies, pro hac vice
11 dboies@bsfllp.com
Theodore H. Uno, SBN 248603
12 333 Main Street, Armonk, New York 10504
Telephone: (914) 749-8200, Facsimile: (914) 749-8300
13
Attorneys for Plaintiffs KRISTIN M. PERRY, SANDRA B. STIER,
14 PAUL T. KATAMI, and JEFFREY J. ZARRILLO
15 UNITED STATES DISTRICT COURT

16 NORTHERN DISTRICT OF CALIFORNIA
17 KRISTIN M. PERRY, SANDRA B. STIER, CASE NO. 09-CV-2292 VRW
PAUL T. KATAMI, and JEFFREY J.
18 ZARRILLO,
Plaintiffs, DECLARATION OF MATTHEW D.
19 MCGILL IN SUPPORT OF PLAINTIFFS’
v. AND PLAINTIFF-INTERVENOR’S
20 JOINT OPPOSITION TO DEFENDANT-
ARNOLD SCHWARZENEGGER, in his official INTERVENORS’ MOTION FOR A
21 capacity as Governor of California; EDMUND PROTECTIVE ORDER
G. BROWN, JR., in his official capacity as
22 Attorney General of California; MARK B.
HORTON, in his official capacity as Director of
23 the California Department of Public Health and
State Registrar of Vital Statistics; LINETTE
24 SCOTT, in her official capacity as Deputy
Director of Health Information & Strategic
25 Planning for the California Department of Public
Health; PATRICK O’CONNELL, in his official
26 capacity as Clerk-Recorder for the County of
Alameda; and DEAN C. LOGAN, in his official
27 capacity as Registrar-Recorder/County Clerk for
the County of Los Angeles,
28 Defendants.
Gibson, Dunn &

Crutcher LLP
09-CV-2292 VRW DECLARATION OF MATTHEW D. MCGILL

1 I, Matthew D. McGill, declare as follows:
2 1. I am a partner at the law firm of Gibson, Dunn & Crutcher LLP, and I am one of the
3 attorneys of record for Plaintiffs Kristin M. Perry, Sandra B. Stier, Paul T. Katami, and Jeffrey J.
4 Zarrillo (“Plaintiffs”) in this action. I make this declaration in support of Plaintiffs’ Opposition to
5 Defendant-Intervenors’ Motion For a Protective Order. I have personal knowledge of the facts set
6 forth herein and if called as a witness, I could and would competently testify hereto.
7 2. On September 4, 2009, after an exchange of correspondence between counsel on the
8 subject, I conferred with counsel for Defendant-Intervenors regarding the scope of our pending
9 discovery. On this September 4 call, counsel for the parties clarified the parties’ respective positions
10 on the scope of discovery. Defendant-Intervenors’ counsel stated that their position was that only
11 publicly-available documents were discoverable in this matter and that documents that were not
12 publicly available were not subject to discovery and would not be produced. I stated that Plaintiffs
13 were not seeking purely internal communications (i.e., communications between or among
14 Defendant-Intervenors), but that communications between the Defendant-Intervenors and third-party
15 individuals or entities should be subject to discovery, if responsive and not otherwise privileged.
16 Neither side agreed to or acquiesced in the other side’s stated positions during that call, but another
17 call was scheduled.
18 3. On September 10, 2009, the parties met and conferred again regarding Plaintiffs’
19 discovery requests. Counsel for Defendant-Intervenors stated their intention to object to Plaintiffs’
20 discovery requests on the grounds of relevance and First Amendment privilege. Defendant-
21 Intervenors further advised that they would produce only documents and communications that were
22 publicly available, and further stated that they construed “publicly available” documents and
23 communications to mean only those that were available to, or accessible by, the electorate at large.
24 Accordingly, Defendant-Intervenors would not produce those documents or communications that
25 were communicated directly to particular groups (for example, registered Republicans). In an
26 attempt to address Defendant-Intervenors’ First Amendment concerns, Plaintiffs offered to agree to
27 any reasonable confidentiality protection for persons whose affiliation with the “Yes on 8” campaign
28 was not already widely known, but Defendant-Intervenors declined to entertain any such proposals.
Gibson, Dunn &

Crutcher LLP 1
09-CV-2292 VRW DECLARATION OF MATTHEW D. MCGILL
I I declare,wrderpenaltyof perjuryunderthe lawsof the United States,thatthesefactsaretrue
2 andcorrectandthat this Declarationis executedthis l Sthday of September2009at Alexandria,VA.
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O9.CV-2292VRW DECLARATION OF MATTHEW D. MCGILL

Case3:09-cv-02292-VRW Document191-2 Filed09/18/09 Page1 of 6
EXHIBIT B
Passing Prop 8: smart timing and messaging convinced Ca... http://www.accessmylibrary.com/article/print/1G1-1947...
Passing Prop 8: smart timing and messaging convin ced California voters to support
traditional marriage.(CASE STUDY)(California Prop osition 8)
Politics Magazine | February 1, 2009 | Schubert, Frank; Flint, Jeff
When we signed our firm up to manage the Yes on Proposition 8 campaign to put the traditional definition of marriage--one
man, one woman--into California's constitution, Frank Schubert's brother told him we had "no chance" to win the campaign.
That view reflected conventional wisdom. After all, California is one of the most liberal states in the nation. It's a state
whose Supreme Court had just legalized same-sex marriage. A state where the Democratic nominee for president hasn't
had to aggressively campaign in nearly two decades. A state where millions of young, first-time voters were poised to go to
the polls to send a message to George Bush and elect Barack Obama. And a state where for the first time in history,
according to a major polling outfit, a majority of voters supported gay marriage.
[ILLUSTRATION OMITTED]
This is the story of how conventional wisdom was stood on its head and how Proposition 8 was enacted by a 700,000-vote
margin.
The Early Campaign Period
Schubert Flint Public Affairs signed onto the Yes on Prop 8 campaign right before the first of what would eventually total
18,000 gay weddings took place after the California Supreme Court legalized gay marriage. We immediately faced our first
important strategic challenge: How to respond to the marriages? We decided to withhold criticism of the same-sex couples
who were getting married (after all, they were simply taking advantage of the rights the Court had granted them), and urged
all our supporters to refrain from demonstrations, protests or rallies opposing the marriages. This initial strategic
positioning, later validated in qualitative and quantitative research, recognized that passing Proposition 8 would depend on
our ability to convince voters that same-sex marriage had broader implications for Californians and was not only about the
two individuals involved in a committed gay relationship.
On the first day that same-sex marriages took place, June 16, we fielded nearly 300 media calls from reporters around the
globe. Our message was calm and low-key: Our fight was not with the gay couples getting married, our fight was with the
flawed reasoning of a narrow majority of the California Supreme Court.
Over the next three months, sympathetic news articles and television reports appeared daily across the state. Traditional
marriage supporters were routinely portrayed as right-wingers holding onto outdated, bigoted ideas. Gay marriage backers
spent $6 million airing a sympathetic 60-second issue advocacy ad. And state Attorney General Jerry Brown shamelessly
rewrote the official summary of the measure in a way clearly designed to bias voters against the initiative.
A survey released by the Field Institute in mid-September showed that fully 55 percent of likely voters were opposed to
Prop 8, with just 38 percent in favor. The political elite all but wrote off Proposition 8 as being dead once the Field Poll was
published. To make matters worse for us, less than a week after the Field Poll came out, the No on 8 campaign began its
television advertising in the state's major media markets.
We worked hard during this period to urge our supporters to have faith that Prop 8 could still be enacted despite what they
saw on the news. We organized countless meetings and conference calls of pastors and other campaign leaders. And we
restructured our online presence and delivered a stream of messages to supporters designed to keep them informed and
engaged.
Define the Terms; Win the Debate
One of the most important aspects of our behind-the-scenes work during this critical early period was to develop messages
that would result in voters casting a Yes vote for traditional marriage. To do so, we had to have messages that appealed to
a much broader audience than the 40 percent or so of voters who made up our base.
The dynamics of the Proposition 8 campaign were unique. We were asking voters for a Yes vote to ban same-sex
9/15/2009 1:00 PM
marriage and restore traditional marriage. We strongly believed that a campaign in favor of traditional marriage would not
be enough to prevail. We needed to convince voters that gay marriage was not simply "live and let live"--that there would
be consequences if gay marriage were to be permanently legalized. But how to raise consequences when gay marriage
was so recently legalized and not yet taken hold? We made one of the key strategic decisions in the campaign, to apply
the principles of running a "No" campaign--raising doubts and pointing to potential problems--in seeking a "Yes" vote. As
far as we know, this strategic approach has never before been used by a Yes campaign.
We reconfirmed in our early focus groups our own views that Californians had a tolerant opinion of gays. But there were
limits to the degree of tolerance that Californians would afford the gay community. They would entertain allowing gay
marriage, but not if doing so had significant implications for the rest of society.
We probed long and hard in countless focus groups and surveys to explore reactions to a variety of consequences our
issue experts identified. The California Supreme Court ruling put gay couples in a protected legal class on the basis of
sexual orientation, and then found that gay couples had a fundamental constitutional right to marriage. This decision
significantly changed the legal landscape. No longer would it be enough for Californians to tolerate gay relationships, they
would have to accept gay marriage as being equivalent to traditional marriage. Tolerance is one thing; forced acceptance
of something you personally oppose is a very different matter.
Whenever a conflict occurred between the rights of a gay couple and other rights, the rights of the gay couple would prevail
because of their "protected class" legal status. We settled on three broad areas where this conflict of rights was most likely
to occur: in the area of religious freedom, in the area of individual freedom of expression, and in how this new "fundamental
right" would be inculcated in young children through the public schools. And we made sure that we had very concrete
examples we could share with voters of things that had actually occurred.
Of equal importance to developing "consequence" messages was assembling a massive grassroots campaign. In most
ballot measure campaigns, volunteers and activists are generally not as inspired as they are in candidate campaigns,
where they feel a personal connection to the cause. This is particularly true in California, a state with 40 million residents,
17 million registered voters and well over 20,000 voting precincts. But we knew from the petition phase, where we gathered
more than 500,000 signatures, that this campaign could very well prove to be the exception.
Our ability to organize a massive volunteer effort through religious denominations gave us a huge advantage, and we set
ambitious goals: to conduct a statewide Voter ID canvass of every voter; to distribute 1.25 million yard signs and an equal
number of bumper strips; to have our volunteers re-contact every undecided, soft yes and soft no voter; and to have
100,000 volunteers, five per voting precinct, working on Election Day to make sure every identified Yes on 8 voter would
vote. All of these goals, and more, were achieved.
We built a campaign volunteer structure around both time-honored campaign grassroots tactics of organizing in churches,
with a ground-up structure of church captains, precinct captains, zip code supervisors and area directors; and the latest
Internet and web-based grassroots tools. Our campaign website was rebuilt to serve as an incredibly effective organizing
tool. Online volunteer sign-ups were immediately sent electronically to the appropriate ZIP code supervisor for follow up.
We set up a statewide voter file with remote access for regional volunteer leaders, which allowed them to input results for
canvassing efforts remotely, and then download and print updated voter lists.
We held the campaign's first statewide precinct walk the weekend of Aug. 16. We had hoped for 20,000 volunteers, which
would have been unprecedented in California ballot initiative politics, but were stunned when almost 30,000 people walked
their neighborhoods that first weekend.
We produced campaign materials in more than 40 languages, and worked with church and community leaders to distribute
these through the many ethnic networks that make up the fabric of California.
[ILLUSTRATION OMITTED]
This intense commitment to distributing materials throughout the state was the result of another key strategic decision.
Supporting traditional marriage is not considered to be "politically correct. "We wanted voters who supported our position to
know that they were not alone and so we made sure they saw our signs in their neighborhoods and our campaign
materials at their church. And if they were part of an ethnic minority, all these were in their native language.
The final phase of the volunteer campaign, GOTV, was really a month-long operation. California allows early voting,
9/15/2009 1:00 PM
starting 29 days ahead of Election Day. From Day 1 of this period, we tracked voters who either appeared on the
permanent absentee voter list, or had applied for a vote-by-mail ballot. Those who were identified as persuadable received
additional volunteer and direct mail contacts. Definite Yes on 8 voters were reminded to return their ballots as early as
possible. The effort paid off, as the early returns reported on Election Night--which consisted of votes cast before Election
Day--showed us with a commanding 57 percent to 43 percent lead.
Fundraising was also a critical activity of this early period, the success of which enabled us to ultimately exceed our initial
voter contact objectives. By this time, leaders of the Church of Jesus Christ of Latter Day Saints had endorsed Prop 8 and
joined the campaign executive committee. Even though the LDS were the last major denomination to join the campaign,
their members were immensely helpful in early fundraising, providing much-needed contributions while we were busy
organizing Catholic and Evangelical fundraising efforts. Ultimately, we raised $22 million from July through September with
upwards of 40 percent coming from members of the LDS Church. Our fundraising operation also relied heavily on small
contributions from some 60,000 individual donors via an extensive direct mail operation, and an extraordinarily effective
online fundraising campaign. When we filed our finance report electronically with the secretary of state, it was more than
5,000 pages thick and crashed the fishing system. We ultimately raised more than $5 million online, and $3 million from
direct mail.
Our initial television ad began airing on Sept. 29, a week after the other side began its campaign ads, and six weeks after
its issue advocacy spot began airing. We knew that this initial ad needed to be a home run--and boy was it! Our
campaign's general counsel had alerted us to a press conference San Francisco Mayor Gavin Newsom held following the
Supreme Court's marriage decision in May. Like Howard Dean once did, Newsom got increasingly excited the longer he
addressed the crowd until, with a smirk on his face and his arms fully extended, he exclaimed, "This door's wide open now.
It's gonna happen--whether you like it or not." That 7-second sound bite perfectly summarized for California voters why this
issue was before them, reminding voters that four judges had overruled four million voters by imposing same-sex marriage
on California. We then segued into potential consequences by featuring a prominent law school professor warning about
implications for religious freedom and freedom of expression, and letting voters know that as a result of the court's
decision, gay marriage would be taught in the public schools.
The "Whether You Like It or Not" television ad immediately solidified (and excited) our base and captured the attention of
voters across the state. We invested heavily in airing this television ad and a companion radio spot. We had a lot of ground
to make up (our internal polls had us behind by 6 points), but more importantly, it was critical for us to define Prop 8 on our
terms. In a little over a week of advertising, we went from being significantly behind, to taking the lead in two published
polls.
The Response Period
The gay community sounded the alarm by releasing to the gay media an internal poll showing them behind and telling their
supporters they would lose unless more money was raised. This emergency cry for contributions was incredibly effective.
Whereas they had raised $15 million in the previous nine months, they raised another $25 million in the ensuing seven
weeks of the campaign.
But their failure to respond to the "consequences" messages (especially the education message) in a timely fashion
ultimately led to their downfall. After blanketing the state with "Whether You Like It or Not," we focused our message on
education. We ran an ad featuring a young Hispanic girl coming home from school, explaining how she had learned in
class that a prince could marry another prince, and she could marry a princess! This ad was based on the actual
experience in Massachusetts, the only state in the nation where gay marriage had been legalized long enough to see how
it would be handled by the public school system. This was followed by another education ad, this one featuring a
Massachusetts couple whose son had been introduced to gay marriage in second grade. The launch of that ad included a
press conference with the Massachusetts couple and corresponded with the kick-off of a statewide bus tour designed to
rally our supporters before the final push on Election Day.
The response to our ads from the No on 8 campaign was slow and ineffectual. They enlisted their allies in the education
system to claim that we were lying. They held press conferences with education leaders to dismiss our claims. They got
newspaper editorial boards to condemn the ads as false. What they never did do, because they couldn't do, was contest
the accuracy of what had happened in Massachusetts.
Finally, three weeks after the Yes on 8 campaign had introduced education as a message, the No on 8 campaign
9/15/2009 1:00 PM
responded with what would be their best ad of the campaign. It featured State Superintendent of Public Instruction Jack
O'Connell claiming that Prop 8 had nothing to do with education and that our use of children in our ads was "shameful."
This in-your-face response, much delayed but very effective, foretold the final period of the campaign--it would be largely
about education.
Even though our campaign clearly had the better ads and grassroots operation, the success of the No side's fundraising
effort threatened to undo all our work. Voters were seeing their commercials at least twice as often as ours as the
campaign headed into its final 12 days. Our lead evaporated. Frank Schubert wrote an e-mail to our 90,000 online
supporters called "Code Blue for Marriage," letting them know we needed more money to be victorious. This e-mail, along
with other emergency fundraising activities, helped produce $7.5 million in contributions from people of faith in the next 72
hours.
The Final Push
Our strategy had anticipated that the No on 8 campaign would label as "shameful lies" any claim that gay marriage had
anything to do with schools, so we went to great lengths to document our ads. We were prepared to play this scenario out
to the finish, trading our ads of what happened in Massachusetts, with the No side's ads saying it wouldn't happen in
California. But then we got the break of the election. In what may prove to be the most ill-considered publicity stunt ever
mounted in an initiative campaign, a public school in San Francisco took a class of first graders to City Hall to witness the
wedding of their lesbian teacher. And they brought along the media.
Now we not only had an example of something that had happened in California (as opposed to might happen), we had
video footage to prove it. Within 24 hours of the No side airing their best ad, the one featuring O'Connell claiming that Prop
8 had nothing to do with schools, we were on statewide TV showing bewildered six-year-olds at a lesbian wedding
courtesy of their local public school.
There were multiple skirmishes in the press over the education issue during the final days of the campaign. The other side
claimed the wedding episode wasn't really as we described it, while we defended the ad as accurate and highlighted other
examples where gays had forced their agenda into the public schools (including an episode in Hayward where a school
celebrated "coming out week" while urging kindergartners to sign pledge cards promising to be an ally of gay students).
After several days of dueling ads featuring Jack O'Connell and kids at the lesbian wedding, the No side effectively
conceded they had lost the education debate. They pulled the O'Connell ad and went in a new direction in the final few
days--attempting to equate a Yes vote with racial discrimination. One ad with U.S. Sen. Dianne Feinstein said that
regardless of how people felt about gay marriage, "we must always oppose" discrimination. They even tried to compare
banning gay marriage to interning Japanese Americans during World War II camps in an ad narrated by Samuel L.
Jackson.
We decided to not respond to this line of attack, confident that it would backfire. The basic message that supporters of
traditional marriage are bigots, guilty of discrimination, had never worked in focus groups. For liberal whites like Feinstein
to lecture black Californians about discrimination was not a winning message. We brought into rotation a positive ad that
reminded voters, in a non-threatening, calm way about the potential consequences to California, and especially children, if
gay marriage was permanently legalized.
As the campaign headed into the final days, we launched a "Google surge." We spent more than a halfmillion dollars to
place ads on every single website that had advertising controlled by Google. Whenever anyone in California went online,
they saw one of our ads in the final two days of the election.
We always believed that if we went into Election Day tied, or even a point or two behind, that we would win. This was
because of the superior nature of our GOTV effort and because the history of polling on the gay marriage issue always
understated support for traditional marriage.
Our last pre-election tracking poll showed the race tied at 48 percent on Election morning. We won 52.3 percent to 47.7
percent, a 700,000-vote margin. Post-election polls showed that upwards of 70 percent of African American voters
supported Prop 8. Latinos voted Yes by about 56 percent, as did a majority of Asian voters.
Members of the Mormon faith played an important part of the Yes on 8 coalition, but were only a part of our winning
coalition. We had the support of virtually the entire faith community in California. Prop 8 didn't win because of the
9/15/2009 1:00 PM
Mormons. It won because we created superior advertising that defined the issues on our terms; because we built a diverse
coalition; and, most importantly, because we activated that coalition at the grassroots level in a way that had never before
been done.
The Prop 8 victory proves something that readers of Politics magazine know very well: campaigns matter.
Frank Schubert is president of Schubert Flint Public Affairs. Jeff Flint is a partner at the firm.
COPYRIGHT 2009 Campaigns & Elections, Inc. This material is published under license from the publisher through the Gale Group, Farmington Hills,
Michigan. All inquiries regarding rights should be directed to the Gale Group.
©2009 Gale, a part of Cengage Learning. All rights reserved.

www.accessmylibrary.com
9/15/2009 1:00 PM
EXHIBIT C
A p A FE.
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TABLE OF CONTENTS THE 18TH ANNUAL POLLIE AWARDS 8t CONFERENCE
The Judges Internet

Individuals Candidate .......,.,.,.,.,.,............ 13 THE JUDGES
and Organizations ............... 3-5 Ballot....................................... 14 Each year the AAPC is host to the world's only awards
Public Affairs ....................... 15 competition solely for political and public affairs consultants,
Overall Campaign and it could not be done without the time, talent and contributions
Candidate ............................6 Newspaper of the many individuals and organizations listed below!
Ballot.,...,....,.,." .....',.....,.w ..... 7 Candidate .......,...,...,.....,...,.. 16
Public Affairs ........................ 6 Ballot............................... 16 Andrew Acosta, Shannon J Bilger, Bmce Cain. Center Chris Cooper, Debra DeShong
AoostalSalazar. LLC Pennsylvania for Campaign MSHC Partners Reed. Point Blank
Public Affairs .,.,.,.,.,.,.,............ 16 Democratic Party Leadership Public Affairs, LLC
Kim Alfano Meghan Cox.
Collateral Doyle, Alfano Brent Blackaby, Sean Carr Lincoln Strategy Iva Ellen
Candidate Phones Communications Blackrock Sean Cartwright, Group Deutchman, Hooart
Ballot........................................7 Candidate .............................. 16 Associates and William Smith
Jill Alper, Dewey Ken nedy Bernard Craighead.
Square Group Bob Blaemire, Communications IEM Message
Colleges
Public Affairs ........................8 Ballot................................ 18
Public Affairs .......................... 18 Holly Armstrong Catalist Chris Casey, NGP Management Raghu
Devaguptapu, Rapid
Direct Mail Gerald J. Austin, Todd Blair. Blair' SoftNare Christopher J. Strategies
Biggs Campaigns Crotty, Crotty
Candidate ...,.,.,............,...,...,..8 Radio Gerald J. Austin & Meredith Chaiken.
Associates I Burges Nancy Bocskor. The M ell man Group Consulting, Inc. Tad Devine, Devine
Ballot...................................... 10 Candidate .............................. 19 & Burges Strategists The Nancy Bocskor Bill Crounse. Mulvey
Public Affairs .,.,.,..........,.,.,.,., 11 Ballot.................................... 19 Lorena Chambers,
Company Bill Crounse Tracy Dietz, Politics
Steve Ayscue. Chambers Lopez & Communications Magazine
Public Affairs ..........................19 Haddon Capital Glen Bolger, Puolic Gaitan LLC
Field Ventures. LLC Opinion Strategies Kathy Chan, Allan Crow. Allan B. Jenny Dombrowski.
Candidate ............................. 12 Television Cro-w & Associates JDiDC Strategic
David Bain. Viral James Bowers, Facebook Communications,
Ballot...................................... 12 Candidate ......................... æ Media Productions Berman and Christian Curto,
Cathrine Charles. LLC
Bruce Barcelo,
Company Various Campaigns Campaign Solutions
Public Affairs .,.,.,..........,.,.,.,., 12 Ballot.................................... 21 Becki Donatelli,
Public Affairs .......................... 22 Barcelo&Company PaulW. Field Director Carol Dahmen. Campaign Solutionsl
Michael Bassik. Air Brandenburger. The Melissa Chernaik, Comcast Spotlight
Fundraising University of Kansas CD Online Ads
America Media' Grove Insight, Ltd. Shaun Dakin. The
Candidate ............................. 12 International Pete Brodnitz. National Political
Angela Douglas
Ross Bates. Bates Andrei Cherny
Ballot...................................... 12 European ..........................23 Consulting Benenson Strategy Do Not Contact Jennifer Duff,
Public Affairs ........................ 12 Latin America .........................23 Group Kari Chisholm. Registry The Cook Political
Carol Baudler, The Mandate Med ia Reporl
Nature Conservancy Edward Brookover. Nick Daisey.
Case3:09-cv-02292-VRW Document191-3
Greener and Hook Scott Cîmmarusti, Campaign Solutions Myles Duff, 360jmg
Student Tony Bawidamann. Curtis Scott
Categories ........................ 23 Stephen Brooks, James Dandeneau, Scott Dworkin.
MWW Group Advertisi ng I nc.
Ray C Bliss Institute New York State Bulldog Finance
Margie Becker, M BA of Applied Politics Molly Clancy. Senate Group
Roy Behr, Behr at The University of Politics Magazine Maurice Daniel, Frank Eaton, The
Communications Akron Tim Clark. eye2eye Bully Documentary
David Brovvne, JohnsonClark Communications Co.
Anthony Bellotti, CD David Browne & Associates
Online Ads Michelle Davidson. Ekaterina Egorova,
Associates Michael Clarke. The Media Guys Niccolo M Group
Terry Benham.
I mpact Management Jeff Browne, CapAd Internet Association Fred N. Davis IIi. Thomas C. Ellington.
'-../ AAPC
i,t~= ..\~ "cor 1;'.T:J~ OF P(.\,ÍT :llL AND Group Communications
Julie Buckner. Laurel
Corporation Chief
Political Consultant
Strategic Perception
Inc.
Wesleyan College
PUBLIC !\F,i\IR5 PROFESSiC' :.ìLS Krista Benner Dale Emmons.
Canyon Media David Cohen, Ray
Paul W. Bentz, Group, Inc. C, Bliss Institute of John Del Cecato. Emmons &
HighGround. Inc. Applied Politics at AKPD Message and Company. Inc.
Mark Bunge, Hart The University of Media Jamie Emmons,
Achim Bergmann, Research Associates
SC Strategies. LLC Akron Marcus DellArtino. Emmons &
Jennifer Burton, Travis Considine, FirstStrategic. Company. Inc.
Michael Beychok. envision Campaign Solutions Communications Matthew Erickson,
Ourso Beychok Communications and Public Affairs
Johnson, Inc. Katie Cook. Direct Laguens Kully Klose
Michael John Line Pol itics James Delorey, Partners
Aaron Beyti n. Burton, Ohio Glooal Strategy Edward Espinoza.
Kennedy University Todd Cook. Main Group America Votes
Communications Street Strategies
Filed09/18/09 Page3 of 14
Edward Cafiero. The Kelly Evans. Kelly

Garrett Biggs. Blair' Clinton Group Evans Consulting
Biggs Campaigns
3
AAPC: The Association of Political and Public Affairs Professioncls THE '8TH ANNUAL POLLIE AWARDS 8c CONFERENCE
Patricia Ewing. Mattis Goldman. Dav id Howard. Matt Latham, Peggy Maze Johnson Bob Moore. Moore Robert W. Pearson, Melissa Roy. The Tom Squitieri. TS Debra Walker. Artist
eye2eye SeeChange Media California Association Oklahoma Association Doug McAlarney, Information'. Inc. Fels Institute of Organizing Group Navigations, LLC John Wallace, Politics
Communications of REAL T ORSQj, for Justice Government.
Adam Goodman. The Brown & McAlarney Chad Morgan. University of Barry Rubin, infoUSA Evan Stavisky. The Magazine
Gayle Lynn Victory Group, Inc. Michael Hudome, MH Natalie LeBlanc, Communications Visteva Parkside Group
Falkenthal, Falcon Media MSHC Partners Pennsylvania Maya Russell. NOW Btian Walsh. NRCC
Rachel Gorlin. Tipping Sean McCarthy, Chtis Mottola, Chris Communications Jared Stimson, Btian Walsworth.
Valley Group Point Strategies Jackie Huelbig. CD Chtistopher Lee. CGL Jackson McCarthy & Mottola Consulting. Ryan Peene. Capital Faulkner Strategies
Impact Group Public Marcy Rye, Walsworth Political
Marilyn Fancher, Online Ads Consulting Group Associates Inc
APCO Worldwide Chad W, Gosselink. Affairs WireMedia Marty Stone. Stones' Joshua Wander
Zatal3 Consulting Aleita Huguenin, Roger Lee. The Roger Elizabeth Jane Michael Mulé, UPT Communications, Inc. Phones
Chris Faulkner. Aleita & Partners Lee Group McCune Strateg ies Robert Penner. Bret Wask
Julie Greene, AFL- Strateg ic Michael Sais. New Roger Stone,
Faulkner Strategies
cia Larry Huynh. Dotty E. LeMieux. Jon McHenry. Millard Mulé, UPT Communications York State Assembly Advocacy. Inc. Ruth Watry, Northern
Michael Favilla, New Blackrock Associates Green Dog Ayres, McHenry & Strateg ies Michigan University
J05h Grossfeld, Michael Pereira. New Barb Sallee. Meridian Angela Struebing.
York State Senate Campaigns and Associates, Inc.
Mammen Group, Inc. Cassand ra III idge- Michael Muller. York State Senate Chiles The Lukens Company Mark Watts, Anacus
Jessica Fawson, Roberts. Getty Communications Bil Mcintyre. Democratic Assembly Associates
Michael Grossman. Renecca Perkins. The Jacob saFcerstein, Sean Sullivan. HSC,
Guidant Strategies Images Kevin Lenaburg, Grassroots Enterprise Campaign Committee
Fifty Plus One Perkins Partnership Ground F oor Public Inc. Amy Weiss, Point
Donald Ferguson Kay Israel, Rhode Bonner & Associates Gibson McKay, Julian Mulvey, Devine Affairs Blank Punlic Affairs.
Lisa Grove, Grove Karen Petel. Petel & Jim Sype
Island College Mitchell Lester. Lester Verid us Mulvey LLC
Christie Findlay. I nsight, Ltd. Co. Scott Schmidt, RSC Mary Szczepanik.
Politics Magazine Bud Jackson. Connec1 Bryon McKim. McKim Andrew Mrers. Myers Partners. I nc. Steve Weichert.
Joaquin Guerra. SEIU Elizabeth Pine, The Lester Connect
Jackson Group Catherine Lew, The Strategies Research Strategic Weichert & Britz, Inc.
Stephanie Findley, Communications Athena Group Matt Schneider. Field
Fast & Accurate Center I nc. Media. LLC Lew Edwards Group Jamie McKown, Seivices Strateg ies Jim Tabilio. Winning Liz Welsh. Executive
Wade Plank, Plank's Directions
Business Solutions Reed Guice, The Karen Jagoda. E- Krista Lewie-Cepero College of the Atlantic Luis Navarro Heating and Air Eric Schnurer. Public Communications. Inc.
Voter Institute Jose Manuel Talero
Celia Fischer. Laurel Guice Agency Jordan Lieberman. Rod McLeod Nathan Nayman. Visa Works. LLC John Whitehurst.
Canyon Med ia Group. Evelyn Jerome Politics Magazine Jefrey Pollock. Global Garcia, more2say Whitehurst/Mosher
Jeff Gumbinner, Francine McMahon. Samuel Nitz, Petel & Strategy Group Paul Seale. Alien GmbH Campaign Strategy
Inc. 360jmg Alexander. SJA Alice Lincoln. Plus The Hill Co. Media.lnc:
Strateg ies Ernie Powell. AARP Rick Thomas, Quinn and Media
Hal Fischer, Mount Three
Vernon Printing John p, Guyette. New Michael Johns Matthew McMillan. Julia Norton. Brandon Powers. Jaimey Sexton. Thomas Public Juli-anne Whitney.
York State Senate Ann Liston, Adelstein BuzzMaker Squier Knapp Dunn Telephone Strategies Affirs, LLC Groundswell
Sarah Flowers. Jennifer Johnson. Communications Communications. Inc. Group
Janis Hahn, Hahn and I Liston Howell Medley Jeremy Thompson. Communications
Laguens Kully Klose Lauer Johnson Josh Pulliam,
Partners Associates. LLP Research Jef Loeb. Brainchild Bynum Thompson Timothy Nurnberger. JPM&M, Inc. Colleen Shogan. Reelpolitik Campaign Jay Williams. The
Baha Hariri. Creative Ryer Strategic Campaign Solutions Cong ressional Media Stonetidge Group
Stephen Fong Benjamin Jones, New Communications Joe Qualls, The Research Service
Committee on Jons Luther Lowe, Yelp. Michael O'Connor, Waldo Tinnetts,
Pa rtners, Inc Parkside Group (CRS) Lynne Williams
George Fontas. New Denorah Harkins, com Patrick C. Meirick. Bose Public Affairs Politico
Gotham Strategies Dan Jud y, Ayres, The University of Group Marko Rakar. MRAK Amy Simon. Goodwin Chris Wilson, Wilson
McGlinchey Stafford Marina Luderer. Sean Tipton,
Ondine Fortune. PLLC McHenry & Winning Directions Oklahoma Marc 0 'Hara.
Services Simon Victoria American Society Research Strategies
Associates.lnc, Research
Fortune Med ia. Inc. Jon Melzer Precision Politics - Jason Ralston, for Reproductive Ken Winneg.
Ryan Hawkins, The Walter Ludwig, Annennerg Punlic
Aram Kailian, Leo A Hired Gun Media Ralston Lapp Media Scott Simpson, Medicine
Brian Franklin. Impact Winding Creek Group. Daly TeamBlue Politics. Brian Michael. Hamilton Campaigns Policy Center
Politics. LLC Inc, Inc. Integrated Web Kevin O'Neill. Joe Reunens, The Brad Todd,
Joe Fuld. MSHC Mitchel Herian. Tug ba Kalafatoglu. Kevin Mack, Strategy Grassroots Enterptise Parkside Group Sean Sinclair. Sinclair OnMessage. Inc Mircalla Wozniak
Partners University of
Tug ba Kalafatoglu & MacklCrounse Group Erin Micheletti. Joseph Oddo. Write Erica RickeL. Hamilton Strateg ies J. Toscano. GMMB Chris Wtight,
Nebraska Associates Kennedy Consult, LLC Companies Brett Sm iley, Committee on Jons
Chris Gallaway, Lisa MacLean. Moxie Ed Traz. thetrazgroup
FieldWorks, LLC Craig Hickox, KTVU- Larry Kamer. Kamer Media Communications Margie Omero, Bart Robnett, Campaign Finance Amos Young Jr..
Consulting Group Officers. LLC Stanley Tsao, The
TV Jason C. Miller. Momentum Analysis Robbett Advocacy California Democratic
Sean Gamble. Special Lance Mangum. Connections Group
Carter Kidd, MSHC Partners Media, LLC Michael Smith. Part
Projects Nevada Bill Hillsman, North Capital One Stuart OsnolN: Prime
Woods Advertising Campaign Solutions Rohn Jay Miller. New York Rich Robinson. ConnectCallUSA. Gail C. Tuzzolo. GTA. Amy Young,
Anthony Garrett. Susan Markham. com/1VDSA Strategic Inc.
Ad am Ki rsch. Marion Icon Nicholson Robinson Progressive Solutions
Anthony Garrett and Michael EMILY's List Kyle Osterhout. Communications
County Democratic Communications Eugene Uehling, Group
Associates Hoffan. See3 Will Miller. The Med ia Strategies and
Communications Party Read Scott Marti n. UniversitY of Akron Research Rick Robinson, Ronald Smith. Smith Gannett Company. Matthew Zablud.
Harry E. Giannoulis, WIT Strategy CommunÎcations, Inc Adfero Group
The Parkside Group Jason HOII~
Christopher Klose. Erik Milman. Milman John Owens-Ream, Author LLC
Laguens Kully Klose Cesar Martinez. MAS Drew Veeneman, The
Leviathan trategy Research and Design Different Will Robinson, New Rachel Zenner.
John Giesser. Spoken Pa rtners Consulting Group Steve Snider, University of Akron
Consulting Consulting Med ia Firm Safeway, Inc,
Hub, LLC Bradley Honan, Penn, Yvette Martinez. PSP National Ed ucati on Dan Vermillion, MT
Schoen and Berland Rob Kubasko. Iguana. Vinny M inchilo, Scott Alan Packman, LSG Chuck Rocha. United Association Suzanne Zurn. 720
Buddy GilL. Texas Inc. Democrats
Associates Michael Matthews. Howell & Company Strateg ies Steelworkers Union Strategies
Credit Union League Karen Kunz, West LSG Strategies . Mark SooHoo, Bill Wachob. The
Ttish Hoppey, MSHC Patrick Moir. Moir & Van Parish, The Lindsay Roitman Campaign Solutions
Christy Gleason. Virginia University Campaign Group
Camden County Partners Lewis Mazanti. Associates Parish Group Paul Rosennerg
An drea Land is. The University of Jim Spencer, The Ryan Waite, CD
Democratic Misha Houser. Brad Mont, Media Ad Chtis Paulitz. Senator Campaign Network
Kaufm an Cam paig n Oklahoma John Rowley, Online Ads
Committee Superior Campaigns Ventures, Ine George V. Voinovich,
Consultants Ohio Fletcher Rowley

Riddle
4 5
Yea on Propo8ition 8 Bes Use I)f Hum(ir Gus DOllgla:ee for IAFF Toolkit Yas.oi, A,
THE WINNERS Online Marketing Agriciilture MacklCrounse Group San Francisco - The
Please join us in recognizing the winning firms Cain paigii Class Elecions Rainmaker Media Groiip Bronze Heart of the Ci1y Sign
SChii bart Flint Pll blie Bermal1 and Comp8iiy Bronz.e \1'/1' itehiir:etJlvlosher
and entries within the following categories. Affair5 and Connell Cam paign S1ralegy
Donatelli, Inc.
Gold Dean Barkley for U.S. and Media
Leno for State Senate - Senate -Independence
Bronze Best Choice for Party Tmtoos Bronze
Overall Campaign Local VOiC65 Best of Show; Gone, Gone TV/Radio Campaign UnÎon Boss Game
Democrat Change Sign North Woods
TrLlthandHope.org PAC The Jack50n GroLlp Bermal1 and Comp8iiy
For Maryland for Our WhitehilrstfMosher Adverti5ing Yes on SAFE
CandJdare Silver Honorable rvlention Yes on Proposition 8: Future Silver
CQm paign Strmeg Honorable Mention RBI Strategies &
Rocking Chairs Televisioii Ccipaign
Blue State Digital and Media Research
Direct Mail rvlark Begich for Squier KnQPp Dunn Best Use of Hum or: Scliubert Flint Public Dollhouse
Honorable Mention Honorable Mention Ni:n-Mail Brochure Honorable Mention
Campaign: D.mQcrai U.S. Sen8te Comm ull ication:e Republican Affairs Berml:n and Comp8iiy
Murphy Putn8m Media Gold Gold Bronze
Public Affa.i,s Di(i:rhanger Obama Announcemerit Di(i:rh.ager
Obama Iowa Bronze The CapÎtl:no Kid
Obama Iowa BIO'DVD Buisson Creative 2GOES2FAR TV Tiie Strategy Groiip
The Strategy Group Din~(:t Mail Cainpaign RNC Online Advertisiiig Main Street Yas oii A, San
Koster for Missouri TI1e Strategy Groiip Strategiee C8mpaign Silver
Gold Connell Donl:telli. liic. and Ivlill Street Francisco - Children
Attomey General Silver Bronze H8noii McKendry
AAPC 2008 Hall of Honorable Meiition Mad Dog Mail Deserve Great Teacher:e
a-political Silver Sanchez Comrmltlit~l
Steve Stivers' Lobl~iist Fame Booklet Silver WhitehurstíMosher
Honorable Mention "King of Big Oil" Internet/New Tabloid
Games 'Winning Directions InternetJNew Cam paign S1ralegy
Rhym ing Cartoon Technology Campaign: Approve 67 Left COa6t l:nd Medil:
rvli55ion Control. Inc. Bronze Teehnology Change
TV/Radio Campaign: 360jm 9 Democrat Murphy PLltn am rvledia Communicatioiis Silver
Silver Ciipaign Compass rvledia Group
RepubliçZln Bronze Vern':e Ofice Bronze Bronze
Laguens Kiilly Klose AAPC 2008 Winners Bronze
Larry Marek fOir State Booklet Pickens Plan Web "Eartli" Doorhanger
Representa1ive John SLlllivan Barack Obama Partners SLlpport Rail Tran5it Cam paign Iowa Barn Door Stel:l1s Consultiiig,
Neiglibor-to-Neighbor Silver Winning Directions McMahon Doorhanger Tiie Strategy Group
360jmg for Coiigreaa McNeil,"'Vilson Network Rell:tioiis LLC
Honorable Mention The Parkside Groiip Bronze
Bronze S1rategic Blue Stl:te Digltl:1 Com m lln icatiOli:e Gold Bronze
Perception. Inc. Honorable Mention I Believe in God Honorable Mention Honorable rvlention
Silver The Elei50n GroLlp, LLC TVlRadio Campaign IAFF Q&A Booklet
Bl:rack Obama for WCV - Dino Rossi's Yas Oil A, San
President IFL) Best of Show: Bronze Best Fundraising Record oil 1I1e Logo Ml:cklCrounse Group Francisco - Save
John SLlmlnu for Senate R.publi-ean Pickens Plan Media Eiwironment: 32% Honorable Mention SF General
rvlacklCroutlae Groiip Cain paigii
S1rategic InternelJNew Yes on Proposition 8 The Connecions Group Gu:e DOllgla:es for \1'/11 itehiir:etJlvlosher
Honorable Mention Net'u/ork Relations
Perceptioii. liic. 2008 Repiiblican Technology Online rvlarketing Silver Agriculture Ballot Cam paign S1ralegy
Bronze Convention - Campaign: C8mpaign Gold Rainmaker Media Group l:lld Medil:
Hodes G OPColwent ion Republiçzn Honorable Meiition
Scliubert Fli1i1 Public The Cures Chronicles Silver Billboard
rvliseion Control, Inc. 2008,com Accee:e to Care
Jim Inliofe for Sen8te Affair:e and Connell
Honorable Mention Cam paign Solut ion5 2008 RepLiblican Donatelli. Inc. Car paign laiien5 Klilly Klo5e Logo
Strategic Partners Business Ml:n Yes on A. Saii
Perception, Inc. Silver Convention - Silver American Cancer "Maii of Faith" Logo
GOPConvention Bronze Fraiiciaco - Children
Dir&ct Mail Honorable Mention
Society Jolin rvl anlove Yes on A, Saii
Campaign; 200a.com De5erve Great Teacher5
John McCain Best Use of Hum or Silver Marketing & Fraiicisco - Everi
Republican C8mpaigii Solutions 2008 Republican \iVhitehurstllvlo5her
for President - Communicl:tiiOiis Campaign Strategy and Child Deserve5 a
Field/Ph"ne Convention -
"Celeb" TV Silver EFAC Rod io Ads Bronze Great Teaclier

Campaign; Demoond Invasion of the Two- GOPConvention Media
Jolin Caroiia - "Little Strategic Faced Lawyers Berman and Company Wil itehiir:etJlvlosher
2008.com Silver
John" Campaign Perception, Inc. Ballot Bronze Fam ily Court Cam paign S1ralegy
VOILin1ee Tithing H8ckney & Hl:ckney Campaign Solutiona
Allyn & Company Bronze JLldge Logo l:lld Medil:
111itil:tive Silver Honorable rvlention Yes on A. San
Silver Direct Mail Campaign Buis50n Creative Silver
The Eleisoii Group. LLC Real Abortion Solutions Francisco - San
Silver McCain Iwo Jima "Professor" TV The Eleison Group, LLC Strategies Fraiiciaco'a Heart
Stivers Campaign Re5ponse America V01e Yes Minnesotl:: Honorable Meiition Wliitel111rsVlvlosher Kids Logo: Yes on
H8noii McKendry Honorable Mention Collateral
King Strategic Honorable Mention Targeting Women Cl:mp8igii S1mtegy and Mea:lle 00 City
Communic8tiOollS, 111C. Best Fundraising: and Sportsmen Bronze of Oakl""d
Dem(lcrat Most Original' Media
Bronze FieidlPhone Candida.te The Lew Edl.'Jmds
Best Use of Hum or: Wampold Strategie5 Campaign Innovative Collateral Bronze
Godzilll: Material Group
Dem(l-eral Silver
Obama for America The Strategy Group Bilboard Bronze
Myers Republican Yard/Outdo", Sign
A.B. Data. Ltd. Honorable Mention Picken:e Plaii
Primary Job Interview Series Napa Pipe ,"Get Out Obama Poster
Silver Field Campaign
thetrazgroup 1I1e Vote"' YOll Don't Kno"",, Jack "CHANGE" Yas Oil GINo on F
Murphy Putnam Medil: Net'i'.'ork RelatÎon5 "Yee. on J" Window Sign
Honorable Mention DAVIES InternetJNew Biii:eEln Creative Continentl:1 Colorcraft Stearne Conaultiiig.
Terris, Bamee & Watter:e
8.st Fundraising:
Gold Technology Gold Strateg ies
Bronze Gold LLC Honorable Mention
RepubliçZln Ci:mpiign Bronze
TV/Radio Campaign: Foreign Lmguage Silver
Democrat Best Fundniising
Squier Klil:pp Dunn C8liforiil: Proposition 8 Mobile Device Tags
RNC Online Adverli5ing M icrotargeted Yard/Outdoor Sign
Comm ull ication:e Bieber Communication/ Petel & Co.
Connell Donatelli, Inc. Television Biiying - RNC Online Adverti5ing
SKDiDSCC Ad Silver Schubert Flint Public Silver
Campaign Against Bronze Defend Oregon Connell Donatelli, Inc.
Affairs Sanchez Activist Banner
Senator Elizabeth Dole Changing Targets Bronze
Hoiiorable Mention Media, MSHC Left Coast
Sqiiier Knapp Dilnll Varn's Offce Communicl:tiiOiis
Lagiien:e Kully Klose Partners and The
Communic8tiOoI1S Silver
Partners New Media Firm

Gold
Bronze Silver
6 1
Most OriginalI Doorhanger Direct Mail Senator Lindsey Grandma Mollie For National lack of "Giimption" \i'Jlw Daddv Was Independent Jackson Response
Innovative Ci:llateral EnvlronmentQ,1 Vote Graham - Line in the Kennedy Organization RQ,lnmQ,ker MediQ, Group a Dem ocråt Expenditure JohnsonClark
Material Updale - Gillibrand Sand Communications Honorable Mention The Chadderdon Group Campaign: U.S. A550ciate5
Candidate H(iuse: Demo-eral
Gold Commiinication5 Firs1 TuesdQ,y Stmtegies Honorable rvlention Windows Honorable Mention Bronz.e
SQ,lt Shaker Bronz.e Bronze Moxie Media Slate: local
Fiir President: Ivlusgrave!Bueh
SteQlns Coiisulting. Democrat For Stmewide Gold Vole-by-Moil Bollot Training \il'/heels
LLC Logo For U.S. House: Constitutional Office War Hero? Request IvlSHC Parliier. Bieber Communicatione-
Hooters
Silver Demoi:at IvlSHC Partners Silver Honorable rvlention
Pa~ Eqii il~ Lisella Public Affairs.
Biofuel for Tl10iiglit The Slralegy Groiip Allen Alley for Treasurer Silver LLC Meet Your New
Measiire FF Bookmark The Eppetein Group, Haunted How~e Bio Brocliiire Silver Voting Bootl1 Sweetlieart Independent
Gold
BergDavis Piiblic Affairs Inc. Checkmate Consulting Quinn Tliomas Piiblìc The American Dream 360jmg Ivlissioii Control Expenditure
Bronze Silver Gold Affairs. LLC Silver Bronze Campaign: Governor:
Obama for America Message Aiidience & Clear
Bronz.e Presentation. Inc. Democrat
Rally Sign Campaign Compass rvledia Group
Non-Mail Brochure Arts+Labs Hands Bronze More of the Same Realtors PAC - Doors
A.B. Dala. Ltd. Bronze
Mercur)( Miesion Control Peter Goldmark MacklCroiinse Group Terris. Barnes & WQ,lters Big Perk.
Silver
Yes oii SAFE Walk Card Gold Harassment Broiize Honomble Mention Thomas rvlills
Bronz.e Flag A Belter World Is
RBI Sirategie. & Northwes1 PQ,ssage CommunicQ,tions. Inc.
Tliey Agree Ivli5sion Control Possible
Research Consulting Independent Silver
CEEL Logo MQ,cklCrounse Group Concrete Evidence of Bronze Winning Directions Do YOll ComrYllte?
Silver Pay.lo-Play Honorable rvlention Expenditure
Berman and Company Bronze Honorable rvlention MacklCroiinse Group
The Sirateg~ Groiip Campaign: U.S, FQ,bric
Honorable Mention John McCain'5 Phone Hoiiorable Mention
Vote Yes Brochure Silver For Stme legisl.zture; H(iuse: Republi-ean ThomQ,s Mills
ObQ,mQ, Iowa Senior 2 Democrat Ivli5sion Control SI"te: St"tewide
Wampold Stra1egiee Communicatione-. Inc.
Most Originiill The Stmtegy Group Honorable Mention Vote-by-MQ,il Chase
A Record of V'Jorking for Bronze
Bronze Innovative Collateral Dahlkem per for AFRW Shoe Siale One Little Stamp
Honomble Men1ion Leno for S1Q,te SellQ,te - West Virgin ia Fam i lies
MateriZlI Congress - Time JPM&M, Iiie.
Right Here Riglit Now For State Faulkner Strategies Cornerstone Solutions Trains
Public Afaii"* Terris, Bames & Walters Orgaiization Silver
For President: WI1itehiir:et/Moslier Bronz.e Silver TIioma:e rvlill:e
San Mamie!. A New Bronze Cam paign Strategy and
Republi-ean CommunicQ,tions. Inc.
Billboard Beginning Media Barry's Treasure Dog
Gay rvlarriage Convict Honorable Mention
JolinsonClark Bmlo\' for Congress- Silver LisellQ, Public Affairs, Slate Card MQ,cklCrounse Group
Obama GWi Contrast InnovQ,tive Advertising
Water Water ASSúciates Bull LLC
The Stoneridge Group Steams Consulting, Bronze Bronze
EverY'i'.rhere Bronze Terris, Bames & Walters Silver LLC
Independent
Silver Belt's BQ,il Bonds Expenditure
The Epp5tein Group, Honorable rvlention Mõimmen Group. Inc. Honorable fvlention Independent MQ,ny FQ,ces Ciipiign; Shrtewide
Inc. A.k tile Expert. Bronze NO! Expenditure Constitutional Office
McCain Iwo Jiina InnovQ,tive Advertising
Silver Winning DirectiOlls For U.S. Hou.e: Kennedv GOTV: Statewde Campaign: U.S.
Respon:eeArnerica Republiç.n Honomble Mention
Honorable Mention Fishy Commiinication5 Senate: De ocrat FQ,ir and BQ,lanced
Don't Target Colomdo Bronze
Kennedy Bronze Vote for Cliange MSHC Partners
RBI Strategies & N(m-Mail Brl)-ehure Here's the TrLlth Vote Against Independent
Communications VOTE EARLY Expenditure Silver
Research Fiir President: Other Jamestown Associates ElizQ,betli Dole
Honorable rvlention Old Eiiough eye2eye Cam paign: State
Bronze WCV Legi.lative Silver Commiinicatione MQ,cklCrounse Group
IvlacklCroiin5e Groiip Legislature: Membership
Scorecard for Bring Oliio Back Direct Silver Silver
Mail Cam paign For State legislature: Honorable Mention Demoçr.zt Politi".. Mail
2007 -2008
Woret Unionizei Make a Difference Republican

TeQ,clier Contest The Connections Group Winning Directione- BI""kel
Clirti. Scott For loç.I/Muniçipall Cliange Is Ju:et a Vo1e No1 a Hero Meltdown
Berman Q,nd Com pany Gold Bronze Advertising, 111C Away (ObamaiNixon) Mission Contml
Odd Maii Ou1 Regional Candidate IvlacklCroiin5e Groiip MacklCroiin:ee Group
Honomble Men1ion Bronze MacklCrounse Group Bronze
The S10neridge Group Silver Gold
Save WQ,1er Brochure For U.S. Senate; Bronz.e
Democrat Silver Assault Rifle
Mass Transit/Bus The Eppstein Group, Tooth FQ,iry Kennedv Clear Choice (Shalieen) Train Rwn ors
Sign Inc. JC-Evans, Inc. COmtnlltiications Obama Texa5 GOTV 3 MQ,cklCrounse Group
Hope Scott BrLliln for State Polka Con5LiIting MacklCroiin:ee Group
SilvEi Honorable Mention Gold The Sirateg~ GroLip Honorable Men1ion
MQ,cklCrounse Group Representative - Bronze Silver
10 'I"'.Io Be a Great 1m portant IS5iies Honorable rvlention
Dad BOMA - Guid. 10 tiie Bronze For Governol': Independent
QLlÍnn Thomas Public Yoii're Fired Sacrifice
Department of Social Jungle of San Franci5co Demoi:at Afroi,., LLC Expend iture Campaign: Big Oil
Services Politice
1hetrazgroup GOTV: Local IvlSHC Parlliel5 MacklCroiin:ee Group
Doing WI1Q,lS Right Bronze U.S. Senate: Republican
Silver Silver Honorable Mention
WliitehurstMo:elier MQ,cklCrounse Group Small Town Bronze
Campaign Strategy and Soldier
Honomble Men1ion Miesion Control John Cmona - Hmd Shaheen: Record Book
Sneo:kers MediQ, GrEir Redecorates MacklCroiin:ee Group Independent
Silver Work Per5Liasion PengllillS...
Robbett AdvoCQcy Bronze 50 Blue. LLC Silver Expenditure
For U.S. Senate; AII~(tl & Com paiiy Partners. Inc. M i:esion Control
Media Bronze Cam paign: State
Republi-ean Blueprint Honorable rvlention Broiize Legislmure; Honorable rvlention
Bronze Pickens PIQ,1l TQ,bloid Clirie rvlmphy "Bu1tone" An American Story
Mercur)( Kennedy Pill.burgh Slory 360jm 9
Republican
Energy Independence Communications Jenkins SlLint Doiible Shalieen Pil1oochio MSHC Partners
Cease tiie Greaee - Bu:e Honomble Mention Meridian Central Public Gold Comtnlinications Bronze Fau Ikner Stmteg ies Honorable Mentioii
Bronz.e Tl1e Stotleridge Group BLibble.
Tiie Eppetein Group, Affair5 Honomble Mention
Honorable rvlention Honorable Men1ion Bieber Communications
Inc. Silver Silver
Honorable Men1ion
8 9
For Coordinated Bilingual/ WI,at'_ With Mike Bes Use of Prom ieee For State Seconde Count: Yas oii A, San Fort Worth Bond Familiee
Campaign: Oem(leral Multilingual/Foreign Erick50n? NegativelC..ntrast: 50 Blue. LLC Organization Cathedral Cit~ Francisco - Our Proposition One Mmiie M ed iQ,
Language: u.s. Winning Mark Statewide Gold Sponsored MQ,iler Community's The Epp:rein Silver
Nowhere H(luse Honorable Mention TRUST TilE! Lev" Edl.vQ,rds Healllicare Hiib Group. Inc.
Yes on B - Puzzle
Kennedv End of the Line Welcliet1 & Britz, Inc. Group VI/ll itehiir:et/Mo:elier Honorable Mention
Terris. Bmnes & WQ,lters AAPC CQ,II for Entries
Commuilic8tioliS Bilngual Health Care The Strategy Group Honorable Mention CQm paign Strategy 811d
Best Use of Silver Silver ,,Vinning Directions
Gold Communicatione Media
Silver Negative/Contr ast: Silver Public Afairs Bronze
Bronze President y"te-by-Mail Baii..t Honorable rvlention
Best Use of Yes on B, F(lr LI)i:I/Munieipal
Whopper NegativelC..ntrast: San Francieco - OrgiiizZition Reques For Federal
LOC:Z!I/MuniçipZlI/ Best Use i:f Humi:r Represen1 Me
Kennedy Giiilty McCain & Palin: LifesQ,ver G(lv..nm..t
Regional Ml:cklCrounse Group
Communications Clieckinate Consiilting Out of Touch Whitehurst/Mosher Trap Texas T\,ijo Stamp PersuZ!sion
Iseue OVerload Honorable Mention
Bronze Honorable Mention MackiCroLin5e Groiip Campaign Strategy 50 BiLle. LLC Meseage ALldience &
Silver Bmri.s Trel:sure and Media Preeen1atlon. Inc. (Proposition F) Wind
Gold For State
Lisella Public Affl:lrs. Silver Gold San Francisco MercLiY
AmericQ,'s Ve1arans Bilingual/
LLC Association of Rooltors Organizati(in
Petel & Co. MultilinguallForeign T orget Ye5 on D - Stepping Silver
Language: Locall Gold y"te-by-Maíl Chase Bronze
Honomble Mention M i55ion Control The Secret i. o.it Terris. Barnes & Walters John McCain Didn't
Muni(:ipal/Regional Cl:re Enough Diapere
Bronze Corners1one SOiLition5 Silver
Fiehy San Mmcos No on 0 Mispll:ced Priorities eye2e)(e Miseion Control
Nation81 Gmssroots: Bronze
GrEir Redecorates Kennedy Absen1ee Cha5e (Propo:eitioii B) CommLinica1ions Silver
BilingLlal/Mult ilingiialf Killing the Middle Cia.. Sprinklers
(Sp8nish) Communicl:tions Tom Shepard & San Franciaco Bronze
Foreign L8nguage MackiCroLin5e Groiip IS51le OJerload Association of Rooltors
50 Biiie. LLC Silver Weichert & Brnz. Inc, Associ8tes. Inc. EC/Preven1ion Fir6:
Honorable Mention (Proposi1ion F) Bronze Honorable Mention
Outsource. Downsize. Silver San Francisco Si~ier For Stlite MacklCrounse Group
Sliu1doii.'n. Lak of "Gumption" ASElciation of Realtors Government Bronze
Best Use of HLlntington'5 Natural Best Use of
rvlacklCrounee Groiip Principal for Change Negative/Contr ast: Rainmaker rvledia Groiip Honorable Mention GOTV: Statewide Persuasi(in
(Spanishl Bronze Beauty NegativelC..ntraot We Believe in Planned
Silver U.S. Senate
50 Blue. LLC The Chl:dderdon Group No on 101 SWl1ner Reeorts Parenthood
F..r City Campaign lhuin bs Up, Thwn bs
Bronze Honorable Mention Harrah's Kansa5 MacklCroLlnse GroLlp
Obama S1or~( SlInwiu ECúnoiny The Sileo Fam ily Veridus Down Guys DAVIES Honorable Mention
rvlacklCrounee Groiip MacklCrounee Groiip Sm ith CommLlnication5, Beware Bronze
Immigrant's Journey LLC For Membership The Eppstein Silver
Bronze Silver Imprenta Organization Group, Inc.
Ste8lns Consulting, Honorable Mention CommLinicatiQn5 Bilinguall For LocZ!l/MuniçipZlI
Silver
LLC Group, Inc. Multilingual/F(lreign For County Organization
SlatelL..cal Bu:eh-Cheney-Smîti You Ive Tlieir Only Government
Grassroots; Bilinguii/ Honorable Mention Ballot Gold Languiige
MacklCrounee Groiip Voice Issue Overload PersuZ!sion
Multilingual/Foreign Smoke-Free Dalll:s
Bronze 'Winning Mark IPropo_itioii F)
Lznguage Best Use of Humor For Statewide Yes on D, San Beware Allyii & Com pany
Gold San Franciaco Smoke-Free
Campaign Francisco Sitting b~ Impren1a Association of Rooltors Silver
Wrong Is \i'/rong tlie Dock of 1he Bay Communica1ions Northern Kentucky
The Great Outdoors rvl ilk a COll.' Bronze
MacklCrounee Groiip Trap GroLlp. Inc. Competing Rights
IvlSHC Partners 360jmg Beach Closed Cl:11 for Ch8nge
Honorable Mention WhitehuretMo:elier 50 BiLle. LLC Gold Tiie Strategy Groiip
Silver Silver Wampold Strategies Misplaced Priorities Kenned)(
Campaign Strategyand Silver Bronze Cominunica1ioiis
Silver IPropo_itioii B)
Best Use (lr rvledia Fiiture
Gree1ings From Carson High-Five San Franciaco Bronze
Negidive/Contrast; Silver Emergency Gatefold linpren1a PromieeelVariable Data)

Crott~( Coneultiiig, Inc. Pelel & Co. U.S. House Defend Oregon - Association of Realtors
Stearns Consulting. Communica1ions 50 Blue, LLC
Bronze Bronze Tricked Honorable rvlention Promieee lVariable Data)
Help This Piggie LLC Group. Inc. Honorable Mention
Sweetheart Terri5, Barne5 & \ill/alters 50 Blue, LLC
Supporl OLlr Market Bronze Si~.'er
WliO Can You Tril6:? Busl1'e Biggest Fan Mission Control Bronze Best Use of Honorable Mention
North\,ijest Paseage Fi:r City Qávernmenl
Gold Communications rvlSHC Partners Gold Consulting Illustration
No QI110 Measure V Trabajos PersuZ!sion
Honorable Mention Honorable Mention No on 101 Bronze Perdidos
F"r Public Agency
MQ,cklCroulise Group A Better World Is
Stivers "Million Dollars" Veridu5
Honorable Mention Bieber CommLlnication/ Possible QLlarry Falls - San Diego
Bilingual/ MetTy Chrietmas to Me! King Strategic Bronze Welcome to Cliarter Sdiubert Flint Public Oveni'.'helining
DAVIES
Multilingual/Foreign Public Schools Affairs Winning Directioii:e Response
th€ltrazgroup Cominuiiications, Inc. Silver
Language: For OLltdoor Memorie5
For Public Agency Silver Bieber CommLlnications
Honorable Mention Silver rvlackiCroLin5e Groiip Bronze
President Wampold Strategie5 Honorable Mention Silver
Yes on A - Imagine Iseue OVerload Sick Da~
Bes Use of Two of a Kind Honorable rvlention Yea on 0 "Bilingiial" -
Who's He üslening To? Terris. Barnes & Walters (Proposition F) Kennedy Go Home
Illustration MSHC Partners F(lr Natiánal ,,Vestminster Sclool Communica1ions
(Californi8 Primary) Organization Silver Dis1ric1 San FrancÎsco Bieber CommLlnications
Bronze For County Campiign Ae:eociation of Realtors Bronze
360jmg Tiie Lev" Edward:e Bronze
"King of Big Oil"
Silver Rhyming Cm100n Localized Distrid5: GroLlp Broiize
Abandoned Bake Sale You Are Their Only For National
360jmg Voice LAUSD - Me..",e Q Bronze Your Ideae:
MacklCrounee Groiip 50 Biiie. LLC Organizati(in
Silver Winning Mark The Lew Edwards Misplaced Priorities Sclool District Public
Honorable Mention Gold Group
Gold Filipino Veteran5 Fight (Proposition B) Affairs Mail
Bronze for Democmcy San Francisco Di:eappearing Baby
Crushed Tiie Lev" Edl.i.'ard:e
Impren1Q, Association of Rooltors Tiie Lukene Company Groiip
Moxie Medi8 Honorable Mention Gold
CommLlnications Honorable Mention
Bronze Group. Inc.
Honorable Mention
10 11
For Membership Field Allen Allev for Treaeurer Fundraising Fill Rick's Boots RNC Searcli rvlarketing Persuasion Online BlOorull Best Blog Ad RNC Searcli Marketing
OrganizaUon Walk Pieëe Blackrock Associates Car paign Advertising: Ml:cWilllams Kirchner Car paign
Ca.ndidate Quinn Thomas PLlblic Ca.ndidate Honomble Mlliition Connell Donatelli, Inc. Independent Sander5 & Parlnere. Toilet Paper Connell Donatelli, Inc.
Wake Up \'al-Mart: Affl:irs. LLC Bronze Exp..ditur. Bronze Connell Donl:1elli. Inc. Bronze
Evangelicl:1 Candlelight Bronze Ciipaign
Be$:t Volunt..r Prospect Mailer: Best Use of User- Silver
Vigil Generated Content Obam atch Qii iz Optimizing Google
Recruitment Program Political Party Internet
360jm g Affordabili1y Agenda to Raise Funds Coin Adwords: Dick Durbin
Ne'i'.' Media Pork Survey
Silver tlie1razgroup (V..uTubel Connell Donatelli. Inc. Communicl:tions BklCkrock Associates
HLlman Righ1s Majority BLlildere Candidate Connell Donl:1elli. Inc.
Honomble Men1ion Silver Honorable Mention Honorable Mention
Campaign's Cam p The Stoneridge Groiip Bronze
Wake Up \'al-Mart: Equality '08 Campaign The Darcy Bumer Persuasion Online
Ci,i i Right. Bronze Online TO\'iJ Hall Triith Fight. Back
Cl:mps Ballot Advertising: Web AnimationlWeb Best Use of Game
Jindal Gala - Fleur on Iraq Neiman-Marxist
360jm g Grassroots Solutions Pr.sident BiLle State Digital Vid.o: U.S. Senate T...ßQI..gy
di Lie MSHC Partners
Bronze Silver Laguens Kully Bronze
Best Volunteer Iiinovative Advertising Klo5e Partners Honorable Mention
Best Use of New R.i:ruitm.nt Pr(lgram Honorable Mention Faux Video True to rvlaiiie Blunt DoclHnent
Change 15 in the AÎr Technology Bronze FLindrai5ing Ads Biish-McCain Qiiiz Dee.troyer: Taking Down
Devine Mulv8'l
Best Bl09 Governor Bliint
eye2eye Organizational House Mailer: l.lSHC Partne.. MSHC Partnere. Broiize
Communica1ions Barack Obama Developmeiit for a Ballot Bronze Honorable rvlention BklCkrock Associates
Decline to Sign U.S. Senore McCainBlogetle.com
Bronze Neiglibor-to-Neigh bor McConnell Senate Gold
Blue S1l:te Dignl:1 Cam paign Best Use of (Candidatel
Bob Schaffer Hippie Hillary Persuasion Online Committee '08-
Gmssroots Solutions Breakthrough Igul:na, Inc.
Promises (Varil:ble D8tl:) Gold Em ergency M ed il: Connell Donatelli, Inc. Advertising: Best Use Sclumer Dress Like Paliii
50 Blue. LLC Bronze Internet Fundraising I)f Hum(lr McCarthy M8ra.s Broiize MSHC Partners
Appeal Technique Honorable Mention
Hoiiomble Men1ion GPS Tracking of Tiie uikens Compan~( Henning5, Ltd. Silver
Canvasaere Minnel:polis Strong Aliene Honorable rvlention Best Use of E-Maill
Scliools Strong City Bronze The Wedding Registry: Persu.zsion Online Viral Marketing
Best Use of FieldWork. Advertising: Connell Donatelli. Inc. Pork Invaders
ReferendLlm No on a
Bilinguail Silver Hl)us. Mailer: U.S. Senate Silver W.b AnimationlWeb Connell Donatelli, lilc.
Gras5roots Solutions Blackrock Associates Spending Hole
Multilingu.zI/Foreign GoV'ernor Video: U.S. House Bronze
Language Honorable Men1ion Silver Meridian Pacific. Inc.
VolP Siirveyiiig IvlcConiiel1 Countdown Pork Siirvey
AG I SMARTech IvlSHC Partners Connell Donatelli. Inc. Bobblehead Bronze
Steak Invite Pubfic Affairs Best Use of Mobile
Coose the Grease Bronze Best GOTV Progriim Deviiie Mulve'l
FaLilkner Strategiee. Bronze Bronze T...ßQI..gy
Mailer Gold Best Use i:f New
The Eppstein Group, Vote Yes Minneso1a:
Gold House Mailer: Technology
Obaml: for Americ8 Shite Grassrootsl Suminii oii tiie IBeiieS Hippie Hillary Obama rvlobile
Inc. Campus Get-Out-1Iie-
Microtargeting Best Use of Issue Advocacy/ Connell Donatelli, Inc. Connell Donatelli. Inc. Leters From Tra'iie. Distribiitive Networks
Silver Vote Program Barack Obam a
Strategic Telemetry Breakthrough Public Affairs Honorable Mention Honorable rvlention BrabenderCox Gold
Gras5roots Solutions Neigli bor-to-Neigh bor
Honorable Men1ion Internet Fundriiising Bronze
A Trabl:jl:r! Bronze Technique Biiie State Digital
CSPF Save 0", State Persuasion Online Persuasion Online Bed Us. 01
Ml:cklCrounse Group Gold
Best Dl)orhanger: Parks C8mpaigii Advertising; Advertising; Best Use Reicherl on the le.sLIe6 FlIçebook
Bronze Best Use of New
Republican Technology Barack Obl:ma Adams Hussey & U.S. House of Negative/Contras Connell Dona1elli. Inc.
Graesroots Match Associates Interactive Mapping
Best Use (If
Honorable rvlention Widget5: Senator Barack Obama
Beck Doorlll:i-ger Biiie State Digital Silver He Can't Hide Rudv Giulil:ni: Facebook Connect
Negidive/ContrZlsl Text Messl:ge to Find Tim Johnson
tlietrazgroup Gold Connell Donatelli, lilc. Urbali Lagend Blull State Digital
Yom Polling Place Web AnimalionlWeb Blackrock Associmes

Bronze Mobile Com mons CSPF Save 0", State Bronze International Video: Statewide Silver
Who Really SLippOrl. Silver
McCain/Palin Elephant Trakker Parks Map Mailing A550ciation
Veterans? Gold of Fire Fighters
Doorlianger eNileson International, Adame Hw~e.ey Robo1ic BushiMyers Running Rich - Crnes Best Use of a Viral
eye2eye & AssocÍles Silver ElepliantScheduler
Tiie Stoneridge Group LLC MSHC Partners for Attorney General Video
CommLlnlcations B.st Dl)orhanger eNilssoli
Honorable Mention Silver Bronze Honorable Meiition Commiinica1ione
Silver International, LLC
McCoiinel1 Countdown Couiisel, Inc. Donna Edwards for
Beware MSHC Partnere Bronze
Best Walk Piece: WeloomeBackTim.com Put Prevention First Bronze Congress: Trick or Treat
Macias- Furnitiire linpr€lita Persuasion Online
Demoorir Coordinated R8ising MacklCrounse Group Adver1ising: Bronze GMMB
Murphy Turier and CommLlnications Group, With Video 2008 Republican
Associates Inc. Honomble Mlliitioii State Legislature Aliens Bronze
Blackrock Associates Convention
Bronze Energy Walkcard Bronze Worst Ever? Maybe Connell Dona1elli. Inc. GOPConv€lit ion
MacklCroLlnse GroLlp Bronze PACIT,ade Fried Chicken Not. Honorable rvlention 2008.com Website; Nirional
Bronze As$i)ciatif)n Program l.lSHC Partne.. MSHC Partnere. Campaign Solutions Organization
Public AfalTs
McCain-Palin 2008 Bronze Honorable rvlention Web AnimalionlWeb Honorable Mention
Searcli Ml:rketing FIREPAC BroGl,ure Vid.l): Lo-eal 2008 Repiibliæii
Stephanie Herse1h Best Volunteer Cam paign
Sandlin Walkpiece R.i:ruitm.nt Prt;gram rvlackiCrouns6 Groiip 290 Votes Web AnimationlWeb Best Use of Search Convention -
Connell Donatelli, Inc. Video: President GOPColwention
Petel & Co, Silver Com pass Med ia Groii p Sanchez Flash Engine Marketing
Honorable Mention An im at ion 2008.com
Honomble Men1ion Pickens Plan Field Honorable Mention
Sel:1 Let Coa.t Cainpaigii SOliitions
Cam paign Internet: Fundraising McCaill-Pl:lin 2008
Best Use (If E-mail tf) Progriim MH Media Communicl:tions Searcli Marketing Silver
Best Walk Piece: Network Rela1ions Raise Money Silver Silver Cl:m paigii
Republi-ean Silver
RNC Online Adverti5ing Connell Dona1elli. Inc. Democrats.org
smartoommLlnicator E- Silver Blue State Digital
Meet Chri. Trick or Vote Connell Donatelli, Inc.
m l:il Modu Ie Bronze
tlietrazgrOllp Silver
Biis Federation AGI SMARTeGIi

Silver Bronze Bronze
12 13
VOTE411 What Would Todd Do? Friends of eip Gas Banner Ads Save San Francisco Clean Up the Persuasion Online Best Blog Yes on Proposition 8 Website: State'
Kennedy Kennedy Gordon Smiih MSHC Partners General Hoe-pital Shipyard Website Advertising: Best Us. Search Marketing Nath:ial Campaign
Communications Communications GordonSmitli,com Bronze Spot-on,com Stearne. of Negative/Contras Wal-Mart W;:lch Crnp;õigii
Honorable rvlention Branz.e Campaign Solutions Bronze Consulting, LLC Blue State Digital Schubert Flint Public NJREBEL.com
Hoiiomble Manlioii Honorable Mention Palil1 Video Ad Affairs and Connell Winning Strategies
Bes Use of Web Bronze Donatelli, Inc.
Website; State Ton~ the Phon~ AnimirionJWeb Video The Wedding Registr~: MSHC Partners McCaÎIlBlogette.oom Silver
Organization Website: Noon 8 Website: City Ballot Gold Bronze
Compass rvledia Group (Piiblic Affairs)
Honorable rvlention C andidale: U.S. RepLlblicans Blackrock Associates Iguana, Inc. National Republican
JayNixon.com: House: Dem ocr at AgQ,ilist 8 - Join Us!! Honomble Mlliition Soottle Parks for All Headlines Best Use of Game Senatorial Committee
Hoiiorable Metltion
Engaging tiie Defend Freedom Websne BrabenderCox
Teehn~l~gy NRSC.org
Website: Best Us. of
Grassroots Negative/Contrast Maz.ie Hirono for Rse Parttlers, Itlc. Best Use of Search Mercury Bronz.e Campaign Solutions
Cotlgress Best Use (If E-m aill Bueh Ivloving Day
Blackrock A550ciates Silver Engine Mark.ting Silver Fan rvlai I Viral Marketing Bronze
Bronz.e NGP Software MSHC Partners
America's Worst BrabenderCox
Govemor Bronze Stop LaWSliit Abuee Yes on Proposition 8 Public Af8.irs Gold Video Game
Honorable rvlention Debbie Shank HQ,s Paid
RepLlblican Party of Proof Interactive in Arizona - No on Search Ivarketing EnOllgli Voters Network
PenllsYMUlia - Silver MarkScliailar.com 201 Video Campaign Persuêlsi(ln Onlin. Biiie Stae Digital B&st Use (If M(lbil. Gras5root5 Enterprise
PAGOPorg B",1 Use 01 Web Technology
BuzzMaker, LLC Integrated Web Strategy Schubert Flint Public Advertising for Shiite/ AnimationlWeb Video Gold Honorable Mention
Campaign Solution5 Honomble Mllntioii Bronze Affair5 and Connell National Campaign
What DeLay Taught DonQ,telli, Inc.
Honorable rvlention McCaLl1 HLlman Rights Website; Best Use of
Stand Tall for America: 1he Bu:eh-McCaitl
Website: Candidate: Bes Blog Ad Silver NegotiQ,tions Crnp8ign Mobile Humor
Me55age ALldience & Morning in Anierica Challenge (Planned Campaign
Website; Looal Presentation, Inc. U.S. House; BrabenderCox GMMB PC1entliood:i
Organization Republican Best Use MSHC Partners
Bronze Yes on Proposition 8 Silver Gold laguens Kully Klose The Great Schlep
Online Advertising of Fêleebof)k Parttlers Bronze
Liberty Concepts, Inc.
Fiona Ma for Califomia 290 Votes Steveforus. com C8mpaign Build America Silver Gold
Stat a Assembly Save JROTC Facebook
TIie ltisilrAtlimals CI1erry Tree Mobile &
Compass Media Group The Stoneridge Group Schubert Flint Public Tiie New Med ia Firm
Doorhanger Nortli \i'Jood:e Rock the Vote GOìV
Blackrock Associate:e Bronze Affair:e atld Contlell Yas Oil Propoeition 8 E-
Honorable Mention Bronze Advertising Text Bush Moving Day
Silver Donatelli. Inc. JKW Polnical mQ,il Marketing
Coneulting Silver CI1erry Tree Mobile l.lSHe Partners
Ballot Silver Cam paigtl
Website: Candidate: Bronze Coin Media Silver
Latino Inaiigiiral Gala President Scliiibert Flitlt Piiblic
Connell DonQ,tell, Inc. FTTH Exaflood Honorable Mention
2009 Persu.zsion Online B""t Bl09 Affairs and Connell
Website: Best Use of Honorable Mention Mercury Donatelli. Inc. Loii Do boo for Governor
PIU5 Three Advertising fi:r Slat.
BarackObam a. com Neg.zive/Contr.zst Bronz.e Bronze Best Use Blue State Dignal
Bronz.e Camp.zigns Stop Slots Daily
Blue State Digital Persuasion Online of Facebook Bronz.e
BlIzzMaker. LLC
Gold Read the Fine Print Advertising for Partnership to Fight Best Use of
Website; Lznding LaLlra \i''\eb Bronz.e County Campaigns
McCaitl for President Blue State Digital Clironic DiseQ,se Web New Technology Pledge to End Breast Americans for Higher
Page Joe Slade White & Video
N€I.. Media Com pQ,ny Bronze Cancer TQ.es
Communications B""t Use of E-M"ill Save San Francisco 720 Strategies Graesroots Enterpri:ee BmbenderCox
Sanchez Flasli Website Gold Viral Marketing Geneml HospitQ,1
ACCCE Power Hou5e
Bronz.e Website: State Ballot Honorable rvlention Viriliotl Silver Honorable Mention
Left COQ,st Spot-on.com
Commiinication:e Yeson 1 Q,nd2 .com Yes on 411 Tiie Ritz Gold
Website; C.zndid.zte: Silver B",1 Blog Ad B&st Use (If a Website: Best Use of
Silver HighGround, Inc. Carlton, Paradise Valley No on Proposition 8
U.S. Senate: Vinii Video
Integrated Web Strategy Campaign VOTE411

Negativ./Ci:ntrasl
Democrat Silver Persuasion Online
Blackrock Associates lAVA Soldier Blog Ads
Mari Latldrieu for Silver Advertising; Best Ketlnedy
Senåte Splash Page Silver MSHC Parttlere CommunicQ,tions The Grea1 Schlep wW'.N.leadersliipforam eri
Matv Latldrieu for Yes 011 Pro position 8 Use of Humor c8sfuture.oom
Blackrock Associates Silver Silver Liberty Concepts, Inc.
Senåte Otlliiie Adverti:eing Stop LaWSliit Abii:ee itl
Soutl1 Dakota Healtlw Gold McNally Temple
Bronz.e Blackrock Associates Car paign ArizQna - No on 201 Do It in the Booth
Families: No on PanCAN Blog Ads Associates, Inc.
Bronze SchLlbert Flint Piiblic Integrated Web Strategy Zoon Politikon Brennan Center Student
Measure 11 MSHC Parttlere Maybe It's Your Civic Bronze
No Good Nick Affairs and Connell Bronz.e Votiiig Giiidei
Blue StQ,te Digital Gold Duty Not to Vote
Kennedy Donatelli, Inc Bronze Biiie Stae Digital
TimJolinson.oom Bronze Bronze Bus Fedemtion Ne'iif Hampsliire Town
Commiinication:e Yes on Proposition 8 E- Broiize
Blackrock Associates True Grit Silver BrabetldetCox
Honorable rvlentiotl mail Marketitlg Ye:e Oil Propoeition 8
Honorable rvlention Yes 011 Proposition 8: Zoon Politikon Online Adverti5ing Honorable Mention
Mi550iiri Rene""'.'ables Cam paign 2008 Republicaii
Video BQ,nner Ad Protec1 Silver Cam paigtl Fork You
McCain HeQ,lth CQ,re Tax Schubert Flint Public Convention
Website; C.zndid.zte: MSHC PQ,rtners AffQ,irs and Connell Marri8ge Website Schubert Flint Public GOPConvention Innovmive Advertising Website: Bilnguall
CalcLllator
U.S. Senate: Honomble Mllntioii Donatelli. Inc. Schubert Flint The InsLlAnimal5: Affairs and Connell 2008.com Bronze Multilingual/Foreign
MSHC Partners Republiç.n Piiblic Affairs
Honorable rvlention Episode 1 Donatelli. Inc Campaigtl SOliltions Language
Honorable rvlentÎon Honorable Mentiotl North Woods Honorable Mention Hoiiorable Mention
Persuasion Online Pnrtnership to Figl,t
JohnCornyn.com Advertising fi:r Bes Use of Adverti5ing CI1ronic Disaase Viral Microsoft: Voices for
Website; Best Use of Upstream Bronze Innovation
Humor County Campaigns New Technology Website: Ci)unty Best Use (If Search Video
CommunicQ,tions B"llot Adfero Group
Engine Marketing 720 Strategi""
Silver Silver
Dress Like PQ,lín Save San Franci5co Yes on Proposition 8 Honorable Mention
Getleral Hoepital Online rvlarketing CTP Proposition rvl RNC Search Ivlarketing
MSHC Partners Jim DeMint for Website
Spot-otl.com Cam paign Cam paigtl
Silver U.S. Setlate, MSHC Pmtners
Silver Schubert Flint Public Contlell Donatelli, Itlc.
\'J1Ni.'J.jimdemiiit.com AffQ,irs and Connell Bronze Silver
Under the Power Lines Donatelli. Inc.

Bronz.e Silver
14 15
Newspaper Less Than Full Bilingual/Multilinguall Gas (English) Automated Calls: Automated Calls: Showdown iii ttie Automated Calls: GOTV Call for
Page: Organization F(ireign Language 50 Blue. LLC SlatelL..eal President Sho'i'.'-Me State Independent Evergreen Progres5
Bronze Gr assroots Zatal3 Con&,Hing Expenditure \Ninning Connections.
C8ooida.le Campaign: Stat..:
Goode Soldier Bill. Mama Obarna Bronz.e Inc.
360jing linpren1a Communications Leacli Williams/Rendell Zalal3 Consulling
Democrat Bronze
Full Page: State Closed for Business (English)
Silver Group, Inc. 50 Blue. LLC C PEC, LLC Silver Automated Call.:
Bronze Silver Best Use of Humor Remember V'ihen... Buckeye Teacliers
Identily Tliefl Honorable Mention
CPEC. LLC lital3 Consulting
Guidant Strategies. Best Use I)f NegativeJ Press 1 for Taxi'
Contrast Beware Fighting Back Press 2 for E-m ail Trick or Vote Event Silver Honorable Mention
Silver For National Organization
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360jing Honorable Mention Contest Bronze Gold
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Bronze Public Affairs He Ran a SmeQr Crowd Ever Dum p DenliC1
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Persuzusion Commuiiications, 111C. Honorable Mention
For Statewide C.zmpaign Concerned AboLlt Barack
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Obam a? Automated Call.: Elec1ioli Dav
Rainmaker rvledia Groiip Hand5hake YOll ShoLlld Be. Automated Call.: Loc.zl Government Multilngual/Fi)reign Troubleshoöting in
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Honorable Men1ion Change - rvl iami Silver
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Honorable Mention RailvlJay Inc. Silver Ohama Bilingul:1 '08 in
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Bronze Sile Didn" Use tlie 'T' Silver Lilt Ie Green Silver
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Bronze Bronze Zalal3 Con'Lllting Automated Call.: Live Calls;
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Gold National Organization Decline to Sign! local/Municipal Government Scliiibert Flint
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General Building Franken's Army You Call Thm Hunting? Telephone Town Hall Honorable Mention U.S. Senate-
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Governm ent latalS Coiisiilting Bilngual/ live Calls: National "YoLI're Oiit" - Pryor Best Use of Humor
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Live Calls: Statewide Mi FQJiliQ, Vota- Freshman Teleplione for Judge
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Live Calls: Broiize Fed Up Wnh Federal Government Commiinicatioii:e. Inc. Bilingu.zll
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Honorable Mention Honorable rvlention Honorable Mention Presentation, Inc.

Connections, Inc, Rip Van Winkle
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Government Communiætions, Inc. Best Use af Humi:r Honorable rvlention
Live Calls: Gold Like Fish in a Barrel Persuasion Riddle, Inc.
Independent Persuasii:n Broiize Blessed
Zatal3 ConE-Lilting Silver
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Organizath)n America: "Mother" Derr..:u::rat Murpliy Putnam Medil: The Strategy Group for Wild Buncli Consulting "Police" Committee - Message Audience &
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Advertising Kitchen Father "Running Man" Honorable Mention Eieenhower
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Congressional Honomble Mention Sirategio Constitutional Bronze NegativefContr ast: Silver Silver
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Obaml: Media Team Silver Blair Jennings Rachel Silver Honorable rvlention
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Bronze Sottile Ad
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Best Use of First Tuesday Strategies Ballot

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"I Bel ieve" Bronz.e Bronz.e
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Presidential Primar: Silver Advertising Republiç.n Expect Senate/Hou se/ Gold The HLlmane Society of Density
Honorable Mention the United States
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Case3:09-cv-02292-VRW Document191 Filed09/18/09 Page1 of 18

1 GIBSON, DUNN & CRUTCHER LLP

5 Theodore J. Boutrous, Jr., SBN 132009

10 BOIES, SCHILLER & FLEXNER LLP

16 UNITED STATES DISTRICT COURT

Gibson, Dunn &

11 Brock v. Local 375,

16 City of Los Angeles v. County of Kern,

19 Del Campo v. Kennedy,

24 Gibson v. Florida Legislative Investigation Committee,

Gibson, Dunn &

7 Pers. Adm’r of Mass. v. Feeney,

18 Fed. R. Evid. 801(d)............................................................................................................................... 5

Gibson, Dunn &

2 Defendant-Intervenors—the official proponents of Proposition 8 and intervenors in this

6 of specific information where confidentiality is appropriate, Defendant-Intervenors instead stake out

9 protective order, lack merit.

17 discovery of admissible evidence.

18 Defendant-Intervenors’ attempt to portray themselves as like any other “California voter or

24 discovery of virtually all of their documents cannot be supported. Defendant-Intervenors’ attempts to

Gibson, Dunn &

14 identified in its June 30, 2009 Order. Doc #76 at 7-9.

27 representations that Defendant-Intervenors now make to the Court.

Gibson, Dunn &

1 In an effort to reach compromise, Plaintiffs negotiated in good faith with Defendant-

5 1. Defendant-Intervenors Misconstrue Relevance Standards and Conflate

Gibson, Dunn &

1 Furthermore, Defendant-Intervenors focus myopically on a single issue—voter intent—while

9 to the discovery of admissible evidence and is thus discoverable.1

10 2. Plaintiffs’ Discovery Is Reasonably Calculated to Lead to the Discovery of

Gibson, Dunn &

7 Defendant-Intervenors’ current characterizations of the positions they espouse in this case.

8 3. Plaintiffs’ Discovery Is Reasonably Calculated to Lead to the Discovery of

18 disputes that likely need to be resolved at trial. Doc #76 at 9.

Gibson, Dunn &

8 by a discriminatory purpose. Id. at 596-98.

20 Defendant-Intervenors’ “motivations for supporting Prop. 8” is relevant and appropriate.

Gibson, Dunn &

1 4. Defendant-Intervenors’ Position Is Internally Inconsistent and Designed

Gibson, Dunn &

1 B. Defendant-Intervenors’ Claim to a Sweeping First Amendment Privilege Against

15 opposite sex marriage”). It is therefore Defendant-Intervenors’ own litigating positions that

16 necessitate the discovery sought by Plaintiffs.

19 Defendant-Intervenors cite, Plaintiffs’ discovery requests do not seek ProtectMarriage.com’s

22 008, http://cal-access.sos.ca.gov/Campaign/Measures/Detail.aspx?id=1302602&session=2007 (last

24 [Footnote continued from previous page]

Gibson, Dunn &

4 enacting it.” City of Los Angeles, 462 F. Supp. 2d at 1114.

14 66005 (D. Kan. May 28, 2009)).

17 case from In re Motor Fuel Temperature Sales Practices Litigation.

18 First, Defendant-Intervenors’ claim of privilege is not remotely limited to “confidential

20 Defendant-Intervenors’ claim of privilege sweeps in all documents responsive to Plaintiffs’ request

Gibson, Dunn &

4 on 8” campaign as the recipient of multiple 2009 Pollie Awards).

8 could chill Defendant-Intervenors’ speech.

12 Temperature Sales Practices Litigation.

13 Defendant-Intervenors have produced declarations that describe “many instances of

Gibson, Dunn &

3 chilling effect caused by additional disclosure cannot be presumed.”).

5 on September 10, Plaintiffs offered to entertain any reasonable confidentiality agreement or

13 party to litigation in federal court.

19 from Defendant-Intervenors. And to the extent that Defendant-Intervenors have a well-founded,

Gibson, Dunn &

11 BOIES, SCHILLER & FLEXNER LLP