Multnomah County Response To Summary Judgment 6:13-CV-01834-MC Geiger v. Kitzhaber Oregon Gay Marriage Lawsuit

Page 1 DEFENDANT RANDY WALRUFF`S RESPONSE TO MOTIONS FOR SUMMARY
JUDGMENT FILED IN THE GEIGER AND RUMMELL CASES

Multnomah County Attorney
501 S.E. Hawthorne Blvd., Rm. 500
Portland, Oregon 97214-3587
(503) 988-3138

UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF OREGON

Eugene Division

DEANNA L. GEIGER and 1ANINE M.
NELSON, ROBERT DUEHMIG and
WILLIAM GRIESAR,

PlaintiII,

v.

1OHN KITZHABER, in his oIIicial capacity as
Governor oI Oregon, ELLEN ROSENBLUM,
in her oIIicial capacity as Attorney General oI
Oregon, 1ENNIFER WOODWARD, in her
oIIicial capacity as State Registrar, Center oI
Health Statistics, Oregon Health Authority, and
RANDY WALRUFF, in his oIIicial capacity as
Multnomah County Assessor,

DeIendants.
Civil Nos.

6:13-CV-01834-MC (Lead Case)
6:13-cv-02256-MC (Trailing Case)

DEFENDANT RANDY WALRUFF`S
RESPONSE TO MOTIONS FOR
SUMMARY JUDGMENT FILED IN
THE GEIGER AND RUMMELL
CASES

JENNY M. MADKOUR, COUNTY ATTORNEY
FOR MULTNOMAH COUNTY, OREGON
Jenny M. Madkour, OSB No. 98298
County Attorney
Katharine von Ter Stegge, OSB No. 032300
501 S.E. Hawthorne Blvd., Suite 500
Telephone: (503) 988-3138
Facsimile: (503) 988-3377
E-mail: jenny.m.madkourmultco.us
katevtsmultco.us
OI Attorneys Ior DeIendant Randy WalruII
Case 6:l3-cv-0l834-MC Document 59 Filed 03/04/l4 Page l of 5 Page lD#: 557

(503) 988-3138
Multnomah County supports equality and inclusion Ior all minorities and opposes illegal
discrimination oI any kind. (Declaration oI Marissa Madrigal 10). The Geiger and Rummell
lawsuits seek to secure the rights oI all Oregonians to wed, regardless oI sexual orientation.
Multnomah County joins the PlaintiIIs oI both cases in asking this Court to careIully consider the
constitutionality oI Oregon laws prohibiting same-sex marriage and then strike them down.
For many years Multnomah County has taken the position that state laws excluding same-
sex couples Irom marrying are discriminatory and unconstitutional. For this reason, Multnomah
County issued more than 3000 marriage licenses to same-sex couples in 2004 beIore opponents
raised legal challenges and passed a statewide reIerendum that made issuing marriage licenses to
same-sex couples plainly illegal under Oregon law. (Madrigal Declaration 12-14).
The County is proud to have stood Iirm on this core civil rights issue a decade ago when
backing marriage rights Ior all was neither easy nor politically saIe. Fortunately, in only one
short decade, public opinion has shiIted dramatically in our state and in our country in support oI
marriage equality. While Multnomah County may not issue marriage licenses to same-sex
couples under current Oregon law, the County agrees with the PlaintiIIs` assertion that the United
States Constitution guarantees same-sex couples the right to marry. The County also urges this
Court to resolve the conIlict between Iederal and state law by joining other Iederal courts in
recognizing this most Iundamental right.
Multnomah County now Iinds itselI in the unavoidable position oI being subject to suit
Ior currently Iailing to issue marriage licenses to same-sex couples, despite its commitment to
issuing marriage licenses to same sex-couples. None oI Oregon`s 36 counties issue marriage
licenses to same-sex couples because the Oregon Supreme Court`s ruling in Li et al. v State and
Case 6:l3-cv-0l834-MC Document 59 Filed 03/04/l4 Page 2 of 5 Page lD#: 558

(503) 988-3138
the prohibition on same-sex marriage contained in Article 15 5a oI the Oregon Constitution are
still Oregon law.
In her Answer in the Rummell case, Oregon Attorney General Ellen Rosenblum stated
that she will not deIend these suits, but will continue to enIorce the ban on same sex-marriage in
Oregon. (State DeIendants` Answer and AIIirmative DeIenses to the Rummell Amended
Complaint 28). Recently Attorney General Eric Holder has stated that State Attorneys General
are not obligated to deIend lawsuits challenging same-sex marriage bans, but has remained silent
on whether they should continue to enIorce the ban. (Declaration oI Katharine von Ter Stegge
2, Exhibit A).
Multnomah County will begin issuing marriage licenses to same-sex couples as soon as it
receives clear direction Irom the courts, the voters, the Legislature, or the Attorney General oI
Oregon that it is legal to do so.
POSITION
Like the PlaintiIIs in these lawsuits, Multnomah County recognizes that the marriage laws
currently in eIIect in the State oI Oregon conIlict with Ireedoms secured to all Americans by the
United States Constitution.
Multnomah County agrees with the Iollowing assertions and legal analysis set Iorth in
PlaintiIIs` Motions Ior Summary Judgment:
Article 15 5a oI the Oregon Constitution prohibits same-sex couples Irom
marrying lawIully in Oregon.

Oregon Domestic Partnerships do not extend protections to same-sex couples
equal to those extended to opposite-sex couples who may marry under current
Oregon law.


(503) 988-3138
Denying same-sex couples the right to marry is harmIul to same-sex couples and
their children.

Same-sex couples are no less capable oI entering into long-term committed
relationships and successIully parenting children than opposite-sex couples.

Under the reasoning set Iorth in SmithKline Beecham Corp. v. Abbott
Laboratories, 740 F.3d 471 (9th Cir. January 21, 2014), this Court should use a
heightened scrutiny standard oI review in deciding whether or not Oregon laws
prohibiting same-sex marriage violate the Equal Protection guarantees oI the

Oregon`s exclusionary marriage laws will Iail to pass this heightened standard oI
review because they are motivated chieIly by Iear, misunderstanding, and a desire
to exclude; as such, they violate the Equal Protection Clause.

Marriage is a Iundamental right guaranteed by the Due Process Clause oI the
United States Constitution; restrictions on marriage are similarly subject to a
heightened level oI scrutiny under the Due Process Clause as set Iorth in Witt v.
Dept of the Air Force, 527 F.3d 806 (9th Cir. 2008).

Oregon`s exclusionary marriage laws will likewise Iail to pass this heightened
standard oI review; because they are motivated chieIly by Iear, misunderstanding,
and a desire to exclude, they violate the Equal Protection Clause.

Oregon`s exclusionary marriage laws cannot even pass a rational basis review iI
this Court employs a lesser standard oI review in considering the constitutionality
oI the laws.

As individuals who are impacted by the existence oI Oregon`s discriminatory
same-same ban, PlaintiIIs have standing to bring this suit.

CONCLUSION
The law should not be used to draw needless and hurtIul classiIications between equally
capable, equally valuable members oI our society. Current Oregon law discriminates against
same-sex couples seeking to marry. The guarantees oI the United States Constitution, however,
extend to all Oregonians, regardless oI whom they choose to love and with whom they choose to
make a liIe. Oregon`s exclusionary marriage laws should be struck down because they violate

(503) 988-3138
both the Equal Protection and Due Process Clauses oI the United States Constitution. II this
Court makes such a declaration, Multnomah County will swiItly begin issuing marriage licenses
to same-sex couples.
DATED this 4th day oI March, 2014.
RespectIully submitted,

/s/ Katharine von Ter Stegge

County Attorney
OI Attorneys Ior DeIendant WalruII
Case 6:l3-cv-0l834-MC Document 59 Filed 03/04/l4 Page 5 of 5 Page lD#: 56l

Page 1 DECLARATION OF MARISSA MADRIGAL IN SUPPORT OF DEFENDANT
RANDY WALRUFF`S RESPONSE TO MOTIONS FOR SUMMARY JUDGMENT
FILED IN THE AND CASES

(503) 988-3138


Eugene Division

WILLIAM GRIESAR,

PlaintiII,

v.


DeIendants.
Civil Nos.

6:13-cv-01834-MC (Lead Case)

DECLARATION OF MARISSA
MADRIGAL IN SUPPORT OF
THE AND
CASES

County Attorney
Telephone: (503) 988-3138
Facsimile: (503) 988-3377
katevtsmultco.us


(503) 988-3138
I, Marissa Madrigal, do declare and state as Iollows:
1. I am the Chair oI the Multnomah County Board oI Commissioners.
2. In my capacity as County Chair, I am the ChieI Executive OIIicer and Personnel
OIIicer Ior the County in accordance with the County Charter. I oversee County operations
including the Multnomah County Department oI Assessment and Taxation ('DART), which is
supervised by Randy WalruII, the County Assessor and a named DeIendant in this lawsuit.
3. Mr. WalruII is responsible Ior ensuring that the County`s marriage license
program complies with the law.
4. The County does not currently issue marriage licenses to same-sex couples
because state law bars that action. II same-sex couples apply Ior marriage licenses at the
Multnomah Building, their applications will unIortunately be rejected.
5. It is heartbreaking Ior me personally, Ior many County employees, and Ior many
residents oI this County, that Multnomah County cannot issue marriage licenses to same-sex
couples. I know Irom my own experience as a marriage license recipient in Multnomah County
that marriage has conIerred important legal and social beneIits on myselI, my husband and our
two children.
6. I believe there is no lawIul reason to deny same-sex couples the beneIits,
legitimacy and security that marriage provides. Multnomah County has no second-class citizens.
The law should not be used to draw needless and hurtIul classiIications between equally capable,
equally valuable members oI our County and larger society.
/// /// ///
/// /// ///


(503) 988-3138
7. I believe that denying same-sex couples the right to marry is harmIul to same-sex
couples and their children. I believe that same-sex couples are also no less capable oI entering
into long-term committed relationships and successIully parenting children than opposite-sex
couples.
8. When I took my oath oI oIIice as Multnomah County Chair, I swore to uphold
both the United States Constitution and the Constitution oI the State oI Oregon. With regard to
same-sex marriage as a civil right, it appears the United States and Oregon Constitutions conIlict.
I cannot uphold one without violating the other. This is an untenable position. I ask the Court to
resolve this conIlict oI law as quickly as possible.
9. As County Chair, I believe that state laws excluding same-sex couples Irom
marrying are discriminatory and unconstitutional. In my role as County Chair, I will swiItly
authorize the issuance oI marriage licenses to same-sex couples when Multnomah County
receives clear direction Irom the courts, the electorate, the Legislature, or the Attorney General
that it is legal to do so.
10. Multnomah County supports equality and inclusion Ior all minorities and opposes
discrimination oI any kind. Multnomah County has a diverse and devoted workIorce, some oI
whom are sexual minorities. Toward that end, Multnomah County proudly hosts an employee
resource group that Iocuses on ensuring equity and inclusion Ior lesbian, gay, bisexual,
transgender and queer county employees and on providing a place Ior those employees to support
each other`s proIessional growth. Multnomah County also provides critical services to County
residents, some oI whom are sexual minorities. Among the many milestones demonstrating
Multnomah County`s attention to sexual minorities is its Health Department`s regular

FILED IN THE GEIGER AND RUMMELL CASES

(503) 988-3138
recognition nationally as a 'Leader in LGBT Healthcare Equality. II we are to treat all
employees and clients with respect and dignity, we must continue to stand Ior marriage equality
and against any law that cripples that right.
11. Current state law boxes Multnomah County in the unavoidable position oI being
subject to suit Ior currently Iailing to issue marriage licenses to same-sex couples, despite its long
history oI supporting marriage equality and issuing marriage licenses a decade ago to same sex-
couples.
12. On March 3, 2004, Multnomah County began issuing marriage licenses to same-
sex couples on the advice oI the Multnomah County Attorney. Multnomah County ultimately
issued more than 3000 licenses to same-sex couples in 2004. Multnomah County`s stand Ior
marriage equality was Iiercely criticized and opposed by some Oregonians.
13. Multnomah County - together with nine same-sex couples, Basic Rights Oregon,
and the American Civil Liberties Union - subsequently sued the State oI Oregon Ior declaratory
and injunctive relieI, arguing that certain state statutes describing marriage as between a husband
and a wiIe violated Article I 20 oI the Oregon Constitution prohibiting discrimination on the
basis oI sexual orientation or gender (Li et al. v. State). Prevailing in that case would have
allowed Multnomah County to continue perIorming its constitutional duty and employing its best
independent judgment to issue marriage licenses to same-sex couples. Multnomah County and
the other plaintiIIs prevailed at the trial court level, but the deIendants appealed the judgment.
14. In November 2004, voters passed Measure 36, amending the Oregon Constitution
to deIine marriage as between one man and one woman. That amendment is set Iorth in Article
15 5a oI the Oregon Constitution. In December 2004, the Supreme Court oI Oregon heard


(503) 988-3138
argument in Li et al. v. State, ultimately deciding in 2004 that Multnomah County lacked
authority to issue the marriage licenses.
15. Only aIter being directed to stop by the Supreme Court and the electorate, did
Multnomah County stop issuing marriage licenses to same-sex couples.
I HEREBY DECLARE THAT THE ABOVE STATEMENT IS TRUE TO THE BEST
OF MY KNOWLEDGE AND BELIEF, AND THAT I UNDERSTAND IT IS MADE FOR USE
AS EVIDENCE IN COURT AND IS SUBJECT TO PENALTY FOR PERJURY.

/s/ Marissa Madrigal

Marissa Madrigal

JUDGMENT FILED IN THE AND CASES

(503) 988-3138


Eugene Division

WILLIAM GRIESAR,

PlaintiII,

v.


DeIendants.
Civil Nos.

6:13-CV-01834-MC (Lead Case)

THE AND
CASES

County Attorney
Telephone: (503) 988-3138
Facsimile: (503) 988-3377
katevtsmultco.us

(503) 988-3138
Multnomah County supports equality and inclusion Ior all minorities and opposes illegal
discrimination oI any kind. (Declaration oI Marissa Madrigal 10). The Geiger and Rummell
lawsuits seek to secure the rights oI all Oregonians to wed, regardless oI sexual orientation.
Multnomah County joins the PlaintiIIs oI both cases in asking this Court to careIully consider the
constitutionality oI Oregon laws prohibiting same-sex marriage and then strike them down.
For many years Multnomah County has taken the position that state laws excluding same-
sex couples Irom marrying are discriminatory and unconstitutional. For this reason, Multnomah
County issued more than 3000 marriage licenses to same-sex couples in 2004 beIore opponents
raised legal challenges and passed a statewide reIerendum that made issuing marriage licenses to
same-sex couples plainly illegal under Oregon law. (Madrigal Declaration 12-14).
The County is proud to have stood Iirm on this core civil rights issue a decade ago when
backing marriage rights Ior all was neither easy nor politically saIe. Fortunately, in only one
short decade, public opinion has shiIted dramatically in our state and in our country in support oI
marriage equality. While Multnomah County may not issue marriage licenses to same-sex
couples under current Oregon law, the County agrees with the PlaintiIIs` assertion that the United
States Constitution guarantees same-sex couples the right to marry. The County also urges this
Court to resolve the conIlict between Iederal and state law by joining other Iederal courts in
recognizing this most Iundamental right.
Multnomah County now Iinds itselI in the unavoidable position oI being subject to suit
Ior currently Iailing to issue marriage licenses to same-sex couples, despite its commitment to
issuing marriage licenses to same sex-couples. None oI Oregon`s 36 counties issue marriage
licenses to same-sex couples because the Oregon Supreme Court`s ruling in Li et al. v State and

(503) 988-3138
the prohibition on same-sex marriage contained in Article 15 5a oI the Oregon Constitution are
still Oregon law.
In her Answer in the Rummell case, Oregon Attorney General Ellen Rosenblum stated
that she will not deIend these suits, but will continue to enIorce the ban on same sex-marriage in
Oregon. (State DeIendants` Answer and AIIirmative DeIenses to the Rummell Amended
Complaint 28). Recently Attorney General Eric Holder has stated that State Attorneys General
are not obligated to deIend lawsuits challenging same-sex marriage bans, but has remained silent
on whether they should continue to enIorce the ban. (Declaration oI Katharine von Ter Stegge
2, Exhibit A).
Multnomah County will begin issuing marriage licenses to same-sex couples as soon as it
receives clear direction Irom the courts, the voters, the Legislature, or the Attorney General oI
Oregon that it is legal to do so.

Like the PlaintiIIs in these lawsuits, Multnomah County recognizes that the marriage laws
currently in eIIect in the State oI Oregon conIlict with Ireedoms secured to all Americans by the
Multnomah County agrees with the Iollowing assertions and legal analysis set Iorth in
PlaintiIIs` Motions Ior Summary Judgment:
Article 15 5a oI the Oregon Constitution prohibits same-sex couples Irom
marrying lawIully in Oregon.

Oregon Domestic Partnerships do not extend protections to same-sex couples
equal to those extended to opposite-sex couples who may marry under current
Oregon law.


(503) 988-3138
Denying same-sex couples the right to marry is harmIul to same-sex couples and
their children.

Same-sex couples are no less capable oI entering into long-term committed
relationships and successIully parenting children than opposite-sex couples.

Under the reasoning set Iorth in SmithKline Beecham Corp. v. Abbott
Laboratories, 740 F.3d 471 (9th Cir. January 21, 2014), this Court should use a
heightened scrutiny standard oI review in deciding whether or not Oregon laws
prohibiting same-sex marriage violate the Equal Protection guarantees oI the

Oregon`s exclusionary marriage laws will Iail to pass this heightened standard oI
review because they are motivated chieIly by Iear, misunderstanding, and a desire
to exclude; as such, they violate the Equal Protection Clause.

Marriage is a Iundamental right guaranteed by the Due Process Clause oI the
United States Constitution; restrictions on marriage are similarly subject to a
heightened level oI scrutiny under the Due Process Clause as set Iorth in Witt v.
Dept of the Air Force, 527 F.3d 806 (9th Cir. 2008).

Oregon`s exclusionary marriage laws will likewise Iail to pass this heightened
standard oI review; because they are motivated chieIly by Iear, misunderstanding,
and a desire to exclude, they violate the Equal Protection Clause.

Oregon`s exclusionary marriage laws cannot even pass a rational basis review iI
this Court employs a lesser standard oI review in considering the constitutionality
oI the laws.

As individuals who are impacted by the existence oI Oregon`s discriminatory
same-same ban, PlaintiIIs have standing to bring this suit.

The law should not be used to draw needless and hurtIul classiIications between equally
capable, equally valuable members oI our society. Current Oregon law discriminates against
same-sex couples seeking to marry. The guarantees oI the United States Constitution, however,
extend to all Oregonians, regardless oI whom they choose to love and with whom they choose to
make a liIe. Oregon`s exclusionary marriage laws should be struck down because they violate
JUDGMENT FILED IN THE AND CASES

(503) 988-3138
both the Equal Protection and Due Process Clauses oI the United States Constitution. II this
Court makes such a declaration, Multnomah County will swiItly begin issuing marriage licenses
to same-sex couples.
DATED this 4th day oI March, 2014.
RespectIully submitted,

/s/ Katharine von Ter Stegge

County Attorney
OI Attorneys Ior DeIendant WalruII
Case 6:l3-cv-0l834-MC Document 59 Filed 03/04/l4 Page 5 of 5 Page lD#: 56l


(503) 988-3138


Eugene Division

WILLIAM GRIESAR,

PlaintiII,

v.


DeIendants.
Civil Nos.

6:13-cv-01834-MC (Lead Case)

DECLARATION OF MARISSA
MADRIGAL IN SUPPORT OF
THE AND
CASES

County Attorney
Telephone: (503) 988-3138
Facsimile: (503) 988-3377
katevtsmultco.us


(503) 988-3138
I, Marissa Madrigal, do declare and state as Iollows:
1. I am the Chair oI the Multnomah County Board oI Commissioners.
2. In my capacity as County Chair, I am the ChieI Executive OIIicer and Personnel
OIIicer Ior the County in accordance with the County Charter. I oversee County operations
including the Multnomah County Department oI Assessment and Taxation ('DART), which is
supervised by Randy WalruII, the County Assessor and a named DeIendant in this lawsuit.
3. Mr. WalruII is responsible Ior ensuring that the County`s marriage license
program complies with the law.
4. The County does not currently issue marriage licenses to same-sex couples
because state law bars that action. II same-sex couples apply Ior marriage licenses at the
Multnomah Building, their applications will unIortunately be rejected.
5. It is heartbreaking Ior me personally, Ior many County employees, and Ior many
residents oI this County, that Multnomah County cannot issue marriage licenses to same-sex
couples. I know Irom my own experience as a marriage license recipient in Multnomah County
that marriage has conIerred important legal and social beneIits on myselI, my husband and our
two children.
6. I believe there is no lawIul reason to deny same-sex couples the beneIits,
legitimacy and security that marriage provides. Multnomah County has no second-class citizens.
The law should not be used to draw needless and hurtIul classiIications between equally capable,
equally valuable members oI our County and larger society.
/// /// ///
/// /// ///


(503) 988-3138
7. I believe that denying same-sex couples the right to marry is harmIul to same-sex
couples and their children. I believe that same-sex couples are also no less capable oI entering
into long-term committed relationships and successIully parenting children than opposite-sex
couples.
8. When I took my oath oI oIIice as Multnomah County Chair, I swore to uphold
both the United States Constitution and the Constitution oI the State oI Oregon. With regard to
same-sex marriage as a civil right, it appears the United States and Oregon Constitutions conIlict.
I cannot uphold one without violating the other. This is an untenable position. I ask the Court to
resolve this conIlict oI law as quickly as possible.
9. As County Chair, I believe that state laws excluding same-sex couples Irom
marrying are discriminatory and unconstitutional. In my role as County Chair, I will swiItly
authorize the issuance oI marriage licenses to same-sex couples when Multnomah County
receives clear direction Irom the courts, the electorate, the Legislature, or the Attorney General
that it is legal to do so.
10. Multnomah County supports equality and inclusion Ior all minorities and opposes
discrimination oI any kind. Multnomah County has a diverse and devoted workIorce, some oI
whom are sexual minorities. Toward that end, Multnomah County proudly hosts an employee
resource group that Iocuses on ensuring equity and inclusion Ior lesbian, gay, bisexual,
transgender and queer county employees and on providing a place Ior those employees to support
each other`s proIessional growth. Multnomah County also provides critical services to County
residents, some oI whom are sexual minorities. Among the many milestones demonstrating
Multnomah County`s attention to sexual minorities is its Health Department`s regular


(503) 988-3138
recognition nationally as a 'Leader in LGBT Healthcare Equality. II we are to treat all
employees and clients with respect and dignity, we must continue to stand Ior marriage equality
and against any law that cripples that right.
11. Current state law boxes Multnomah County in the unavoidable position oI being
subject to suit Ior currently Iailing to issue marriage licenses to same-sex couples, despite its long
history oI supporting marriage equality and issuing marriage licenses a decade ago to same sex-
couples.
12. On March 3, 2004, Multnomah County began issuing marriage licenses to same-
sex couples on the advice oI the Multnomah County Attorney. Multnomah County ultimately
issued more than 3000 licenses to same-sex couples in 2004. Multnomah County`s stand Ior
marriage equality was Iiercely criticized and opposed by some Oregonians.
13. Multnomah County - together with nine same-sex couples, Basic Rights Oregon,
and the American Civil Liberties Union - subsequently sued the State oI Oregon Ior declaratory
and injunctive relieI, arguing that certain state statutes describing marriage as between a husband
and a wiIe violated Article I 20 oI the Oregon Constitution prohibiting discrimination on the
basis oI sexual orientation or gender (Li et al. v. State). Prevailing in that case would have
allowed Multnomah County to continue perIorming its constitutional duty and employing its best
independent judgment to issue marriage licenses to same-sex couples. Multnomah County and
the other plaintiIIs prevailed at the trial court level, but the deIendants appealed the judgment.
14. In November 2004, voters passed Measure 36, amending the Oregon Constitution
to deIine marriage as between one man and one woman. That amendment is set Iorth in Article
15 5a oI the Oregon Constitution. In December 2004, the Supreme Court oI Oregon heard


(503) 988-3138
argument in Li et al. v. State, ultimately deciding in 2004 that Multnomah County lacked
authority to issue the marriage licenses.
15. Only aIter being directed to stop by the Supreme Court and the electorate, did
Multnomah County stop issuing marriage licenses to same-sex couples.
I HEREBY DECLARE THAT THE ABOVE STATEMENT IS TRUE TO THE BEST
OF MY KNOWLEDGE AND BELIEF, AND THAT I UNDERSTAND IT IS MADE FOR USE
AS EVIDENCE IN COURT AND IS SUBJECT TO PENALTY FOR PERJURY.

/s/ Marissa Madrigal

Marissa Madrigal


Multnomah County Response To Summary Judgment 6:13-CV-01834-MC Geiger v. Kitzhaber Oregon Gay Marriage Lawsuit

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Page 1 DEFENDANT RANDY WALRUFF`S RESPONSE TO MOTIONS FOR SUMMARY

JUDGMENT FILED IN THE GEIGER AND RUMMELL CASES

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