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DECL. OF MARISA MORET IN SUPP. OF
THIRD PARTY CALIFORNIANS AGAINST
ELIMINATING BASIC RIGHTS' OPP. TO MOT.
TO COMPEL - NO. 09-cv-2292 VRW
Case3:09-cv-02292-VRW Document593 Filed02/12/10 Page2 of 5
3 1. I am the Managing Attorney of the San Francisco City Attorney's Office. I have
4 personal knowledge of the facts set forth in this declaration, and, if called asa witness, could and
7 (Doc. #585) requiring that third party subpoena recipient Californians Against Eliminating Basic
8 Rights submit a declaration justifying the inclusion in its core group of the individuals identified in the
11 Rights ("CAEBR"). CAEBR (formerly known as Californians Against Discrimination) was formed in
12 July 2008 to educate the public about discrimination, and to oppose Proposition 8. It was engaged
14 potential donors and CAEBR Chair City Attorney Dennis Herrera, and a small number offundraising
15 events. Although it originally intended to use its funds for puhlic messaging, CAEBR ultimately
16 contributed the bulk of the funds it received to the umbrella No on 8 organization, Equality for All, No
17 on 8. Attached as Exhibit A are true and correct copies of excerpts of CAEBR' s campaign finance
18 statements filed with the Secretary of State, which demonstrate that CAEBR made contributions to
19 Equality for All, No on 8, in the amounts of$100,000 on October 1,2008, $525,000 on October 21,
8 e. Griffin Schake, the primary campaign consultants for CAEBR, who were
11 activities are:
18 Strategy;
22 Schake.
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DECL. OF MARISA MORET IN SUPP. OF 2
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THIRD PARTY CALIFORNIANS AGAINST
ELIMINATING BASIC RIGHTS' OPP. TO MOT.
TO COMPEL - NO. 09-cv-2292 VRW
Case3:09-cv-02292-VRW Document593 Filed02/12/10 Page4 of 5
3 was provided with internal draft messaging and strategy material for the
8 Strategy; and
21 Johansen & Purcell provided legal advice regarding aspects ofCAEBR'scampaign strategy and other
22 matters, and campaign treasurer Daralyn Reed provided advice regarding campaign financing and
23 reporting obligations, no communications between these individuals and other members of the con;:
24 group were made that contain, refer or relate to any arguments for or against Proposition 8.
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DECL. OF MARISA MORET IN SUPP. OF 3
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THIRD PARTY CALIFORNIANS AGAINST
ELIMINATING BASIC RIGHTS' OPP. TO MOT.
TO COMPEL - NO. 09-cv-2292 VRW
Case3:09-cv-02292-VRW Document593 Filed02/12/10 Page5 of 5
1 I declare under penalty of perjury that the foregoing is true and correct. I have frrsthand
2 knowledge oftbe same, and ifcalled upon to do so I could and would testify competently thereto.
3 Executed this 11::- day ofFebruary, 2010, in San Francisco, California.
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MARISA MORET
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(00103392-4)
..
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09-cv-2292 VRW
EXHIBIT A
1. Type of Recipient Committee: All Committees - Complete Parts 1,2,3, and 4. 2. Type of Statement:
o Officeholder, Candidate Controlled Committee • Ballot Measure Committee • Pre-election Statement D Quarterly Statement
o State Candidate Election Committee • Primary Formed o Semi-annual Statement D Special Odd-Year Report
o Recall 0 Controlled o Termination Statement o Supplemental Preelection
(Also Complete Part 5.) 0 Sponsored • Amendment (Explain below) Statement - Attach Form 495
o General Purpose Committee (Also Complete Part 6.)
o Sponsored D PrimarY Formed Candidate/ Correct Sched A, E, F; Summary page
o Small Contributor Committee Officeliolder Committee
o Political Party/Central Committee (Also Complete Part 7.)
I.D.NUMBER
3. Committee Information 1307787 Treasurer(s)
COMMITTEE NAME (OR CANDIDATE'S NAME IF NO COMMITTEE NAME OF TREASURER
Californians Against Eliminating Basic Rights, No on Prop. 8 Daralyn E. Reed
CITY STATE ZIP CODE AREA CODEIPHONE CITY STATE ZIP CODE AREA CODEIPHONE
Yreka CA 96097 530 842-1365
San Leandro CA 94577 ( ) -
NAME OF ASSISTANT TREASURER, IF ANY
MAILING ADDRESS (IF DIFFERENT) NO. AND STREET OR P.O. BOX
MAILING ADDRESS
CITY STATE ZIP CODE AREA CODE/PHONE
Beverly Hills CA 90213
OPTIONAL: FAXIE-MAIL ADDRESS CITY STATE ZIP CODE AREA CODE/PHONE
4. Verification
I have used all reasonable diligence in preparing and reviewing this statement and to the best of my knowledge the information contained herein and in the attached schedules
is true and complete. I certify under penalty of perjury under the laws of the State of California that the foregoing is true and correct.
Executed on 0210112009 ByDaralyn E. Reed
--:--------";o"sI;-;::G:7NA;:;TU:;-;R;::;E=-:o~F:-:;T:;:;:REA=S:;-;;UR;::;E:;;R:-;:O;;:;R-;;:A;:::SS::;;IS;::;T~AN:-;:;T:-:;TR=EA;-;:S:;-;UR;::;E::;:R:------------
DATE
Executed on By
DATE SIGNATURE OF CONTROLLING OFFICEHOLDER, CANDIDATE, STATE MEASURE PROPONENT OR RESPONSIBLE OFFICER OF SPONSOR
Executed on By
DATE SIGNATURE OF CONTROLLING OFFICEHOLDER, CANDIDATE, STATE MEASURE PROPONENT
Executed on By FPPC Form 460 (June/01)
DATE SIGNATURE OF CONTROLLING OFFICEHOLDER, CANDIDATE, STATE MEASURE PROPONENT FPPC Toll-Free Helpline: 866/ASK-FPPC
State ot California
1370702-1
Case3:09-cv-02292-JW Document593-1 Filed02/12/10 Page3 of 9
RESIDENTIAUBUSINESS ADDRESS (NO. AND STREET) CITY STATE ZIP Identify the controlling officeholder, candidate, or state measure proponent, if any.
NAME OF OFFICEHOLDER, CANDIDATE, OR PROPONENT
1370702-1
Case3:09-cv-02292-JW Document593-1 Filed02/12/10 Page4 of 9
SUMMARY PAGE
Campaign Disclosure Statement Type or print in ink.
Summary Page
Amounts may be rounded
to whole dollars.
from
Statement covers period
1% 112008
CALIFORNIA
FORM
460
through 1011812008 Page _3_ _ of ::;28"--__
SEE INSTRUCTIONS ON REVERSE
NAME OF FILER 1.0. NUMBER
Californians Against Eliminating Basic Rights, No on Prop. 8 1307787
-----------------------------------------1
17. LOAN GUARANTEES RECEiVED........................... Schedule B, Part 2 $0.00
the first report being filed
for this calendar year, only
carry over the amounts
1370702-1
Case3:09-cv-02292-JW Document593-1 Filed02/12/10 Page5 of 9
Schedule D SCHEDULED
Summary of Expenditures Type or print in ink.
Supporting/Opposing Other
Amounts may be rounded
to whole dollars.
from
Statement covers period
1010112008
CALIFORNIA
FORM
460
Candidates, Measures and Committees
SEE INSTRUCTIONS ON REVERSE through 10/18/2008 Page _17__ of28
NAME OF FILER 1.0. NUMBER
Californians Against Eliminating Basic Rights, No on Prop. 8 1307787
DATE
NAME OF CANDIDATE. OFFICE. AND DISTRICT. OR
MEASURE NUMBER OR LETTER AND JURISDICTION.
TYPE OF PAYMENT
DESCRIPTION
(IF REQUIRED)
AMOUNT THIS
PERIOD
ICUMULATIVE TO DATE
CALENDAR YEAR
PER ELECTION
TO DATE
OR COMMITTEE (JAN.1 • DEC. 31) (IF REQUIRED)
I I 0 Independent
Expenditure
• Support o Oppose
Monetary
O Contribution
o Contribution
Nonmonetary
I I 0 Independent
o Support o Oppose
Expenditure
Monetary
O Contribution
o Contribution
Nonmonetary
I I 0 Independent
o Support 0 Oppose
Expenditure
: • 1111111
Schedule D Summary
1. Contributions and independent expenditures made this period of $100 or more. (Include all Schedule 0 sUbtotals.) $100.000.00
2. Unitemized contributions and independent expenditures made this period of under $1 00 ""$0""'.0""0 _
3. Total contributions and independent expenditures made this period. (Add Lines 1 and 2. Do not enter on the Summary Page.) .. TOTAL $100,000.00
1370702·]
Case3:09-cv-02292-JW Document593-1 Filed02/12/10 Page6 of 9
COVER PAGE
Recipient Committee
Campaign Statement
Type or print in ink. Date Stamp
CALIFORNIA
2001/02 460
(Government Code Sections 84200-84216.5) FORM
1. Type of Recipient Committee: All Committees - Complete Parts 1,2,3, and 4. 2. Type of Statement:
D Officeholder, Candidate Controlled Committee· • Ballot Measure Committee D Pre-election Statement D Quarterly Statement
o State Candidate Election Committee • Primary Formed • Semi-annual Statement D Special Odd-Year Report
o Recall 0 Controlled D Termination Statement D Supplemental Preelection
(Also Complete Part 5.) 0 Sponsored
D Amendment (Explain below) Statement - Attach Form 495
D General Purpose Committee (Also Complete Part 6.)
o Sponsored D Primary Formed Candidate/
o Small Contributor Committee Officetiolder Committee
o Political Party/Central Committee (Also Complete Part 7.)
I.D.NUMBER
3. Committee Information 1307787 Treasurer(s)
COMMITTEE NAME (OR CANDIDATE'S NAME IF NO COMMITTEE NAME OF TREASURER
Californians Against Eliminating Basic Rights, No on Prop. 8 Daralyn E. Reed
CITY STATE ZIP CODE AREA CODE/PHONE CITY STATE ZIP CODE AREA CODEIPHONE
Yreka CA 96097 530 842-1365
San Leandro CA 94577 ( ) -
NAME OF ASSISTANT TREASURER, IF ANY
MAILING ADDRESS (IF DIFFERENT) NO. AND STREET OR P.O. BOX
MAILING ADDRESS
CITY STATE ZIP CODE AREA CODE/PHONE
Beverly Hills CA 90213
OPTIONAL: FAXIE-MAIL ADDRESS CITY STATE ZIP CODE AREA CODE/PHONE
4. Verification
I have used all reasonable diligence in preparing and reviewing this statement and to the best of my knowledge the information contained herein and in the attached schedules
is true and complete. I certify under penalty of perjury under the laws of the State of California that the foregoing is true and correct.
Executed on 02/0112009 ByDaralyn E. Reed
-....::....--------=sI""G:":'NA"'TU""'R""E::-:O::-::F"'T""REA=s;-;;UR;:-;E:;:;R,-;:O""R-:-A~SS:::-:IS:::;T""'AN""T"'TR=EA"'S'"'UR""E""R:------------
DATE
Executed on By
DATE SIGNATURE OF CONTROLLING OFFICEHOLDER, CANDIDATE, STATE MEASURE PROPONENT OR RESPONSIBLE OFFICER OF SPONSOR
Executed on By
DATE SIGNATURE OF CONTROLLING OFFICEHOLDER, CANDIDATE, STATE MEASURE PROPONENT
Executed on By
FPPC Form 460 (June/01)
DATE SIGNATURE OF CONTROLLING OFFICEHOLDER, CANDIDATE, STATE MEASURE PROPONENT FPPC Toll-Free Helpline: 866/ASK-FPPC
State 0t
California
1398933-0
Case3:09-cv-02292-JW Document593-1 Filed02/12/10 Page7 of 9
OFFICE SOUGHT OR HELD (INCLUDE LOCATION AND DISTRICT NUMBER IF APPLICABLE) BALLOT NO. OR LETTER
8
I JURISDICTION
Statewide - 11108
I D
•
SUPPORT
OPPOSE
RESIDENTIAUBUSINESS ADDRESS (NO. AND STREET) CITY STATE ZIP Identify the controlling officeholder, candidate, or state measure proponent, if any.
NAME OF OFFICEHOLDER, CANDIDATE, OR PROPONENT
I.D.NUMBER
COMMITTEE NAME
7. Primarily Formed Committee List names of officeholder(s) or candidate(s) Ffor
which this committee is primarily formed.
1398933-0
Case3:09-cv-02292-JW Document593-1 Filed02/12/10 Page8 of 9
Summary Page
Amounts may be rounded
to whole dollars.
from
Statement covers period
10/19/2008
CALIFORNIA
FORM
460
through 12/3112008 Page _3_ _ of "-.35"--_ _
SEE INSTRUCTIONS ON REVERSE
NAME OF FILER I.D. NUMBER
Californians Against Eliminating Basic Rights, No on Prop. 8 1307787
16. ENDING CASH BALANCE Add Lines 12 + 13 + 14, then subtract Line 15 $45,724.13
- . . .. $0.00
$0.00
FPPC Form 460 (June/01)
FPPC Toll-Free Helpline: 866/ASK·FPPC
1398933-0
Case3:09-cv-02292-JW Document593-1 Filed02/12/10 Page9 of 9
Schedule 0 SCHEDULED
Summary of Expenditures Type or print in ink.
Supporting/Opposing Other
Amounts may be rounded
to whole dollars.
Statement covers period
CALIFORNIA
FORM
460
from 10119/2008
Candidates, Measures and Committees
SEE INSTRUCTIONS ON REVERSE through 12131/2008 20_ _ of_
Page_ 35_ _
NAME OF FILER tD.NUMBER
Californians Against Eliminating Basic Rights, No on Prop. 8 1307787
DATE
NAME OF CANDIDATE, OFFICE, AND DISTRICT, OR
MEASURE NUMBER OR LETTER AND JURISDICTION,
TYPE OF PAYMENT
DESCRIPTION
(IF REQUIRED)
AMOUNT THIS
PERIOD
ICUMULATIVE TO DATE
CALENDAR YEAR
PER ELECTION
TO DATE
OR COMMITTEE (JAN.1 • DEC. 31) (IF REQUIRED)
I I 0 Indepe~dent
Expenditure
• Support o Oppose
10/27/2008 Equality for All, No on 8 $30,000.00 $661,500.00
Equality for All- No on Prop 8 Monetary
• Contribution
Jurisdiction: Statewide
D Nonmonetary
Contribution
I I 0 Indepe~dent
• Support o Oppose
Expenditure
I I 0 Indepe~dent
Expenditure
• Support 0 Oppose
:. ',. I" I
Schedule 0 Summary
1. Contributions and independent expenditures made this period of $100 or more. (Include all Schedule D subtotals.) $561500.00
2. Unitemized contributions and independent expenditures made this period of under $100 ~$O~.o~o~ _
3. Total contributions and independent expenditures made this period. (Add Lines 1 and 2. Do not enter on the Summary Page.) .......... TOTAL $561.500.00
139S933-O