United States District Court Northern District of California

Case3:09-cv-02292-VRW Document473 Filed01/15/10 Page1 of 5
1 COOPER AND KIRK, PLLC

Charles J. Cooper (DC Bar No. 248070)*
2 ccooper@cooperkirk.com
David H. Thompson (DC Bar No. 450503)*
3 dthompson@cooperkirk.com
Howard C. Nielson, Jr. (DC Bar No. 473018)*
4 hnielson@cooperkirk.com
Nicole J. Moss (DC Bar No. 472424)*
5 nmoss@cooperkirk.com
Peter A. Patterson (Ohio Bar No. 0080840)*
6 ppatterson@cooperkirk.com
1523 New Hampshire Ave. N.W., Washington, D.C. 20036
7 Telephone: (202) 220-9600, Facsimile: (202) 220-9601
8 LAW OFFICES OF ANDREW P. PUGNO

Andrew P. Pugno (CA Bar No. 206587)
9 andrew@pugnolaw.com
101 Parkshore Drive, Suite 100, Folsom, California 95630
11 ALLIANCE DEFENSE FUND

Brian W. Raum (NY Bar No. 2856102)*
12 braum@telladf.org
James A. Campbell (OH Bar No. 0081501)*
13 jcampbell@telladf.org
15100 North 90th Street, Scottsdale, Arizona 85260
15 ATTORNEYS FOR DEFENDANT-INTERVENORS DENNIS HOLLINGSWORTH,

GAIL J. KNIGHT, MARTIN F. GUTIERREZ, MARK A. JANSSON, and
16 PROTECTMARRIAGE.COM – YES ON 8, A
PROJECT OF CALIFORNIA RENEWAL
17
* Admitted pro hac vice
18
UNITED STATES DISTRICT COURT
19 NORTHERN DISTRICT OF CALIFORNIA
20 KRISTIN M. PERRY, SANDRA B. STIER,

PAUL T. KATAMI, and JEFFREY J.
21 ZARRILLO, CASE NO. 09-CV-2292 VRW
22 DEFENDANT-INTERVENORS
Plaintiffs, DENNIS HOLLINGSWORTH, GAIL
23 KNIGHT, MARTIN GUTIERREZ,
v. MARK JANSSON, AND
24 PROTECTMARRIAGE.COM’S
ARNOLD SCHWARZENEGGER, in his official MOTION TO SHORTEN TIME FOR
25 capacity as Governor of California; EDMUND RESPONSE TO AND HEARING OF
MOTION TO COMPEL
26 G. BROWN, JR., in his official capacity as
Attorney General of California; MARK B. Trial Date: January 11, 2010
27 HORTON, in his official capacity as Director of Judge: Chief Judge Vaughn R. Walker
the California Department of Public Health and Location: Courtroom 6, 17th Floor
28 State Registrar of Vital Statistics; LINETTE
DEFENDANT-INTERVENORS’ ADMINISTRATIVE MOTION TO SHORTEN TIME

CASE NO. 09-CV-2292 VRW
1 SCOTT, in her official capacity as Deputy

Director of Health Information & Strategic
2 Planning for the California Department of Public
Health; PATRICK O’CONNELL, in his official
3
capacity as Clerk-Recorder for the County of
4 Alameda; and DEAN C. LOGAN, in his official
capacity as Registrar-Recorder/County Clerk for
5 the County of Los Angeles,
6 Defendants,
7 and
8 PROPOSITION 8 OFFICIAL PROPONENTS
DENNIS HOLLINGSWORTH, GAIL J.
9 KNIGHT, MARTIN F. GUTIERREZ, HAK-
SHING WILLIAM TAM, and MARK A.
10 JANSSON; and PROTECTMARRIAGE.COM –
YES ON 8, A PROJECT OF CALIFORNIA
11 RENEWAL,
12 Defendant-Intervenors.
13
14 Additional Counsel for Defendant-Intervenors

15
ALLIANCE DEFENSE FUND
16 Timothy Chandler (CA Bar No. 234325)
tchandler@telladf.org
17 101 Parkshore Drive, Suite 100, Folsom, California 95630
Telephone: (916) 932-2850, Facsimile: (916) 932-2851
18
Jordan W. Lorence (DC Bar No. 385022)*
19 jlorence@telladf.org
Austin R. Nimocks (TX Bar No. 24002695)*
20 animocks@telladf.org
801 G Street NW, Suite 509, Washington, D.C. 20001
22 * Admitted pro hac vice
23
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1 TO THE PARTIES AND THEIR ATTORNEYS OF RECORD:

2 PLEASE TAKE NOTICE that pursuant to Local Rule 6-3 Defendant Intervenors Dennis
3
Hollingsworth, Gail J. Knight, Martin F. Gutierrez, Mark A. Jansson, and ProtectMarriage.com
4
(“Proponents”) will and hereby do move this Court for an Order shortening the time within which the
5
Court may hear Proponents Motion to Compel Compliance with Nonparty Document Subpoenas.
6
7 Proponents have moved for an order compelling production of documents by non-parties
8 Californians Against Eliminating Basic Rights (“CAEBR”), Equality California, and No on Proposition
9 8, Campaign for Marriage Equality, A Project of the American Civil Liberties Union of Northern
10 California (“ACLU”) (collectively, “the No on 8 groups”). Proponents have so moved because they
11
wish to have these documents available for use at trial, which has already commenced.
12
This motion is based upon this Notice of Motion; the following Memorandum of Points and
13
Authorities; the concurrently filed declaration of Jesse Panuccio in support; the complete files in these
14
15 actions; the concurrently filed Motion to Compel; argument of counsel; and such other and further
16 matters as this Court may consider.
17 MEMORANDUM AND POINTS OF AUTHORITIES

18
The parties have engaged in a long dispute over the permissible scope of discovery in this action.
19
Plaintiffs propounded sweeping document requests on Proponents, seeking nearly every document in
20
Proponents’ possession. Proponents objected on burden, relevance, and First Amendment grounds, but
21
made clear that—in order to build a complete record in this case—to whatever extent they are required
22
23 to produce such documents, they would seek similar documents from the No on 8 groups. See, e.g.,
24 Doc # 187 at 3-4. To that end, Proponents served Rule 45 document subpoenas on the No on 8 groups.
25 On January 6, the Court conducted the latest in a series of hearings regarding the scope of permissible
26
discovery. Following that hearing, the Court ruled on the permissible scope of discovery and the
27
bounds of the First Amendment privilege in this case. See Doc # 372. Proponents apprised the No on
28
1
1 8 groups of this new ruling and its implications for the scope of documents now discoverable in this
2 case. The No on 8 groups have objected and are refusing to produce documents that are relevant and
3
nonprivileged under this Court’s January 8 order. Because trial has already commenced, Proponents
4
require immediate production of these documents so that they may review them and potentially enter
5
them into evidence. Accordingly, counsel for the No on 8 groups were notified by email on the
6
7 morning of January 15 of Proponents’ intention to seek relief in the form of this motion to shorten
8 time. See Decl. of Jesse Panuccio in Supp. of Defendant-Intervenors’ Mot. to Shorten Time.
9 I. Substantial Prejudice Will Occur If Proponents Are Not Permitted to Obtain, Review,
and Potentially Introduce Documents In the Possession of the No on 8 Groups.
10
11 Federal Rule of Civil Procedure 6(e) allows the Court to order a motion to be heard on an
12 accelerated basis “for good cause.” Fed. R. Civ. P. 6(c)(1)(C). Moreover, N.D. Cal. Civ. L.R. 6-
13 3(a)(3) provides that a court may shorten time if “substantial harm or prejudice … would occur if the
14 Court did not change the time ….”
15
Proponents have kept the No on 8 groups continually apprised of both this Court’s and the Ninth
16
Circuit’s rulings regarding the permissible scope of discovery in this case. The Court’s most recent
17
ruling was not announced until January 8, just a few days before the start of trial. Doc # 372.
18
19 Proponents stand ready to review production from the No on 8 groups as soon as it comes in, so as to
20 be able to introduce the documents into evidence to build the “complete record,” Doc # 76 at 5, of “the
21 mix of information before and available to the voters,” Doc # 214 at 14. Allowing the normal timeline
22
for response and hearing on this motion would not allow this matter to be resolved while the trial is still
23
ongoing and thus would preclude the Court’s ability to review a “complete record” and prejudice
24
Proponents’ ability to plan and present their case. It is imperative that Proponents receive a
25
determination as to whether the No on 8 groups must comply with the subpoenas. Accordingly,
26
27 Proponents respectfully request that the Court order the No on 8 groups to file a response, if any, to the
28 motion to compel by 5 p.m. on January 18, 2010, and that the Court hear the motion as soon as is
2
1 practicable given the trial schedule.

2 CONCLUSION
3
For the foregoing reasons, Proponents respectfully request that the Court grant this motion to
4
shorten time.
5
6 Dated: January 15, 2009

COOPER AND KIRK, PLLC
7 ATTORNEYS FOR DEFENDANTS-INTERVENORS
8 DENNIS HOLLINGSWORTH, GAIL J. KNIGHT,
MARTIN F. GUTIERREZ, MARK A. JANSSON, AND
9 PROTECTMARRIAGE.COM – YES ON 8, A PROJECT
OF CALIFORNIA RENEWAL
10
By: /s/ Charles J. Cooper
11 Charles J. Cooper
12
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Case3:09-cv-02292-JW Document473-1 Filed01/15/10 Page1 of 8
1 COOPER AND KIRK, PLLC

Charles J. Cooper (DC Bar No. 248070)*
2 ccooper@cooperkirk.com
David H. Thompson (DC Bar No. 450503)*
3 dthompson@cooperkirk.com
Howard C. Nielson, Jr. (DC Bar No. 473018)*
4 hnielson@cooperkirk.com
Nicole J. Moss (DC Bar No. 472424)*
5 nmoss@cooperkirk.com
Peter A. Patterson (Ohio Bar No. 0080840)*
6 ppatterson@cooperkirk.com
1523 New Hampshire Ave. N.W., Washington, D.C. 20036
8 LAW OFFICES OF ANDREW P. PUGNO

Andrew P. Pugno (CA Bar No. 206587)
9 andrew@pugnolaw.com
101 Parkshore Drive, Suite 100, Folsom, California 95630
11 ALLIANCE DEFENSE FUND

Brian W. Raum (NY Bar No. 2856102)*
12 braum@telladf.org
James A. Campbell (OH Bar No. 0081501)*
13 jcampbell@telladf.org
15100 North 90th Street, Scottsdale, Arizona 85260
15 ATTORNEYS FOR DEFENDANT-INTERVENORS DENNIS HOLLINGSWORTH,

GAIL J. KNIGHT, MARTIN F. GUTIERREZ, MARK A. JANSSON, and
16 PROTECTMARRIAGE.COM – YES ON 8, A
PROJECT OF CALIFORNIA RENEWAL
17
* Admitted pro hac vice
18
UNITED STATES DISTRICT COURT
19 NORTHERN DISTRICT OF CALIFORNIA
20 KRISTIN M. PERRY, SANDRA B. STIER,

PAUL T. KATAMI, and JEFFREY J.
21 ZARRILLO, CASE NO. 09-CV-2292 VRW
22 DECLARATION OF JESSE
Plaintiffs, PANUCCIO IN SUPPORT OF
23 DEFENDANT-INTERVENORS’
v. MOTION TO SHORTEN TIME FOR
24 MOTION TO COMPEL
ARNOLD SCHWARZENEGGER, in his official
25 capacity as Governor of California; EDMUND Trial Date: January 11, 2010
Judge: Chief Judge Vaughn R. Walker
26 G. BROWN, JR., in his official capacity as Location: Courtroom 6, 17th Floor
Attorney General of California; MARK B.
27 HORTON, in his official capacity as Director of
the California Department of Public Health and
28 State Registrar of Vital Statistics; LINETTE
DECLARATION OF JESSE PANUCCIO IN SUPPORT OF MOTION TO SHORTEN TIME

1 SCOTT, in her official capacity as Deputy

Director of Health Information & Strategic
2 Planning for the California Department of Public
Health; PATRICK O’CONNELL, in his official
3
capacity as Clerk-Recorder for the County of
4 Alameda; and DEAN C. LOGAN, in his official
capacity as Registrar-Recorder/County Clerk for
5 the County of Los Angeles,
6 Defendants,
7 and
8 PROPOSITION 8 OFFICIAL PROPONENTS
DENNIS HOLLINGSWORTH, GAIL J.
9 KNIGHT, MARTIN F. GUTIERREZ, HAK-
SHING WILLIAM TAM, and MARK A.
10 JANSSON; and PROTECTMARRIAGE.COM –
YES ON 8, A PROJECT OF CALIFORNIA
11 RENEWAL,
12 Defendant-Intervenors.
13
14 Additional Counsel for Defendant-Intervenors

15
ALLIANCE DEFENSE FUND
16 Timothy Chandler (CA Bar No. 234325)
tchandler@telladf.org
17 101 Parkshore Drive, Suite 100, Folsom, California 95630
Telephone: (916) 932-2850, Facsimile: (916) 932-2851
18
Jordan W. Lorence (DC Bar No. 385022)*
19 jlorence@telladf.org
Austin R. Nimocks (TX Bar No. 24002695)*
20 animocks@telladf.org
801 G Street NW, Suite 509, Washington, D.C. 20001
22 * Admitted pro hac vice
23
24
25
26
27
28

1 I, Jesse Panuccio, declare as follows:

2 1. I am an attorney licensed to practice law in the State of Florida and the District of
3
Columbia and am admitted pro hac vice in this case. I am an associate at the law firm of Cooper &
4
Kirk, PLLC, counsel of record for Defendant-Intervenors Dennis Hollingsworth, Gail Knight,
5
Martin Gutierrez, Mark Jansson, and ProtectMarriage.com. I make this declaration in support of
6
7 Defendant-Intervenors’ Motion to Shorten Time. I have personal knowledge of the facts stated
8 herein and could testify and would testify competently thereto if called upon to do so.
9 2. Proponents have concurrently filed a motion to compel production of documents

10 pursuant to non-party document subpoenas issued under Fed. R. Civ. P. 45 to Californians Against
11
Eliminating Basic Rights (“CAEBR”), Equality California, and No on Proposition 8, Campaign for
12
Marriage Equality, A Project of the American Civil Liberties Union of Northern California
13
(“ACLU”) (collectively, “the No on 8 groups”).
14
15 3. Proponents believe it would be in all parties interest to resolve this matter as soon as
16 possible given the ongoing trial and Proponents’ desire to introduce into evidence some of the
17 documents in the No on 8 group’s possession and have filed the Motion to Shorten Time for that
18 reason.
19
4. On the morning of January 15, 2010, I sent emails to counsel for the No on 8 groups,
20
requesting that counsel stipulate that they would respond to the motion to compel by 5 p.m. on
21
January 18 and consent to a hearing as soon as is practicable for the Court.
22
23 5. Counsel for ACLU did not consent and requested that the ACLU’s response email be
24 included as a submission to the Court. That email is attached as Exhibit A. Counsel for Equality
25 California did not consent. Counsel for CAEBR did not respond before the motion was filed.
26
6. I am aware of three previous time modifications in this case. A stipulation was granted
27
to extend time for the Administration Defendants to serve and file their Answer to the Complaint in
28
1
1 Intervention. Doc # 170. The parties also entered into a joint stipulation to extend pretrial filing
2 deadlines. Doc # 266. The Court also granted Plaintiffs’ motion to shorten time for response to an
3
administrative motion to seal documents. Doc # 438.
4
7. I do not believe that the requested time modification would have any effect on the
5
schedule for this case. Indeed, given that trial has already commenced and the No on 8 groups have
6
7 produced few, if any, documents to date, Proponents would be prejudiced if the requested time
8 modification is not granted.
9
I declare under penalty of perjury that the foregoing is true and correct. Executed this 19th day of
10
11 January, 2010.
12
13 By: /s/ Jesse Panuccio

14 Jesse Panuccio
15
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2
EXHIBIT A
Page 1 of 3
Jesse Panuccio
From: Bomse, Stephen [sbomse@orrick.com]

Sent: Friday, January 15, 2010 4:49 PM
To: Jesse Panuccio
Cc: Elizabeth Gill
Subject: RE: Perry v. Schwarzenegger, No. 09-2292 (N.D. Cal.)
Dear Mr. Panuccio:
This responds to your e-mail letter below. We have set out the position of the ACLU
previously in some detail and see no benefit to repeating it here. You should not infer
from our failure to respond to particular points in your most recent letter as agreement to
them to any extent.That includes your assertion that our January 14 reply on behalf of
the ACLU acknowledges that the ACLU is withholding responsive documents. We have
stated merely that we do not intend to take any further action to respond to your clients'
subpoena, including determining whether "responsive" documents do or do not exist.
With respect to timing, as our letter of the 14th made clear, in the event there are to be
further proceedings with respect to your subpoena, the ACLU would expect to have
adequate time to fully and fairly respond. Unlike your firm and your clients, neither we
nor the ACLU has scheduled its time in expectation of being required to devote further
attention to this issue. Thus, for example, I was participating in a conference when your
e-mail this morning arrived and I am going to be in Taiwan as of January 20 and will not
return until at least the 24th.
Furthermore, if there is urgency here it is not as the result of any action or inaction on
ACLU's part. It is, instead, created entirely by your own strategic litigation decisions and
it is both unfair and unreasonable to visit any consequences of your prior inaction on our
client, or its counsel for that matter. For all of these reasons, we are not willing to
stipulate to any order shortening time, let alone to the kind of extreme order
(contemplating a response on Monday, a national holiday) you apparently intend to
propose.
In the event you persist in your intentions as stated in your most recent e-mail, we
expect that you will include both this e-mail and my letter of January 14 as part of your
submission to the Court.
Steve Bomse
From: Jesse Panuccio [mailto:jpanuccio@cooperkirk.com]

Sent: Friday, January 15, 2010 9:06 AM
To: Bomse, Stephen
Subject: Perry v. Schwarzenegger, No. 09-2292 (N.D. Cal.)
Mr. Stephen V. Bomse, Esq.
1/15/2010
Page 2 of 3
The Orrick Building

405 Howard Street
San Francisco, CA 94105-2669
January 15, 2010
BY EMAIL
Re: Perry v. Schwarzenegger, No. C-09-2292 VRW (N.D. Cal.)
Dear Mr. Bomse:
I write in follow up to Jim Campbell’s letter of January 12, 2010, and in response to your letter of January 14. The
Court in Perry has stated its intention to build a “complete record” in this case, Doc # 76 at 5, and has held that
part of this complete record is “the mix of information before and available to the voters.” Doc # 214 at 14. The
Court has further defined this “mix of information” as consisting of “any document “that contain[s], refer[s] or relate
[s] to arguments for or against Proposition 8.” Doc # 372 at 5. The subpoena that has been served on No on
Proposition 8, Campaign for Marriage Equality, A Project of the American Civil Liberties Union of Northern
California (“ACLU”)—issued out of the Northern District of California, the Court that issued the above orders—
seeks just such documents. See, e.g., Requests No. 1, 6, and 8.
Your correspondence to date indicates that the ACLU is withholding such documents. Because trial is already
underway and the need to build a “complete record” of “the mix of information before and available to the voters”
is pressing, Defendant-Intervenors have no choice at this juncture but to file a motion to compel compliance with
the subpoena. Concurrent with that motion, Defendant-Intervenors plan to file an administrative motion to shorten
time for response to, and hearing on, the motion to compel. Defendant-Intervenors will propose that any
response be filed by 5 p.m. on January 18, 2010, and that the Court hear the motion as soon as possible given
the dictates of the trial schedule.
With respect to timeliness of this motion, Local Rule 26-2 states that a “[d]iscovery cut off” applies “[u]nless
otherwise ordered” and that “[d]iscovery requests that call for responses … after the applicable discovery cut-off
are not enforceable, except by order of the Court for good cause shown.” N.D. Cal. Civ. L.R. 26-2. Here,
although the Court originally set a discovery cut-off of November 30, 2009, see Doc # 160 at 2, the Court just
recently ruled on the scope of the First Amendment privilege and relevant discovery. See Doc # 372. Moreover,
the Court has already permitted motions to compel beyond the date established by L.R. 26-2, and it was just such
a motion that resulted in the January 8 order. See Doc # 325 at 8 (seeking order compelling discovery and dated
Dec. 28, 2009); Hr’g of Jan. 6, 2010, Tr. at 7 (noting that Doc # 325 seeks a “compelling” order); id. at 69 (noting
that Plaintiffs “filed … what amounts to the motion to compel … on the 28th”).
Pursuant to N.D. Cal. Civ. L.R. 6-3(a)(2), a party moving to shorten time must seek a stipulation to the time
change. If you stipulate to the time change, please let me know. Additionally, if the ACLU has reconsidered its
position and will begin an immediate rolling production, please let me know. If you believe further meet-and-
confer will resolve this dispute, I am available today at 202-220-9642--but, again, I note that Defendant-
Intervenors must move forward promptly on your prior representations that no additional documents will be
produced.
Sincerely,
Jesse Panuccio
----------------------------
Jesse Panuccio
Cooper & Kirk, PLLC
1523 New Hampshire Ave., N.W.
Washington, D.C. 20036
Phone: (202) 220-9600
Fax: (202) 220-9601
www.cooperkirk.com
1/15/2010
Page 3 of 3
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Case3:09-cv-02292-VRW Document473 Filed01/15/10 Page1 of 5

1 COOPER AND KIRK, PLLC

8 LAW OFFICES OF ANDREW P. PUGNO

11 ALLIANCE DEFENSE FUND

15 ATTORNEYS FOR DEFENDANT-INTERVENORS DENNIS HOLLINGSWORTH,

20 KRISTIN M. PERRY, SANDRA B. STIER,

DEFENDANT-INTERVENORS’ ADMINISTRATIVE MOTION TO SHORTEN TIME

1 SCOTT, in her official capacity as Deputy

14 Additional Counsel for Defendant-Intervenors

DEFENDANT-INTERVENORS’ ADMINISTRATIVE MOTION TO SHORTEN TIME

1 TO THE PARTIES AND THEIR ATTORNEYS OF RECORD:

7 Proponents have moved for an order compelling production of documents by non-parties

16 matters as this Court may consider.

17 MEMORANDUM AND POINTS OF AUTHORITIES

1 practicable given the trial schedule.

6 Dated: January 15, 2009

1 COOPER AND KIRK, PLLC

8 LAW OFFICES OF ANDREW P. PUGNO

11 ALLIANCE DEFENSE FUND

15 ATTORNEYS FOR DEFENDANT-INTERVENORS DENNIS HOLLINGSWORTH,

20 KRISTIN M. PERRY, SANDRA B. STIER,

DECLARATION OF JESSE PANUCCIO IN SUPPORT OF MOTION TO SHORTEN TIME

1 SCOTT, in her official capacity as Deputy

14 Additional Counsel for Defendant-Intervenors

DECLARATION OF JESSE PANUCCIO IN SUPPORT OF MOTION TO SHORTEN TIME

1 I, Jesse Panuccio, declare as follows:

9 2. Proponents have concurrently filed a motion to compel production of documents

8 modification is not granted.

13 By: /s/ Jesse Panuccio

From: Bomse, Stephen [sbomse@orrick.com]

Dear Mr. Panuccio:

From: Jesse Panuccio [mailto:jpanuccio@cooperkirk.com]

Mr. Stephen V. Bomse, Esq.

The Orrick Building

January 15, 2010

Re: Perry v. Schwarzenegger, No. C-09-2292 VRW (N.D. Cal.)

Dear Mr. Bomse:

IRS Circular 230 disclosure:

NOTICE TO RECIPIENT: THIS E-MAIL IS MEANT FOR ONLY THE

For more information about Orrick, please visit

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