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John Doe #1 State & Doe v. Reed Claims of Harassment, Intimidation, etc. 1 of 204 Document Review 4/5/2010 Source: ProtectMarriage.com v. Bowen, Ex. 12 Page # in Filing: 1-8 Type of Document: Affidavit Name: John Doe #1 State & Campaign: CA, Prop 8 Incident Date: 10/2008 Location: CA, Declarant's store Search Terms: self-employed Was the individual a donor: Y Is the incident related to donation only: Y Is the incident related to petitions: N Is the incident related to yard signs or bumper stickers only: Y Is the incident related to other campaign activities: N If yes, explain involvement in campaign: Was the incident described in the media: N Is the incident referenced in other sources: N NOTES Economic Retaliation Flyers put on customers' car referencing declarant's support for Prop 8 and donation amount. Store picked twice. Nov. 2008 picketers were "aggressive" standing in front of store door and trying to give flyers to customers saying not to shop there b/c declarant supports Prop 8. Second picket- people blocked doorway of store and tried to get customers to sign petition. Police called but public space so protesters not forced to leave store. Unwanted Communication Three Facebook groups urged boycott of declarant's business. Someone paid for a google sponsor link that urged people to boycott declarant's business and listed her donation to Prop 8. Negative business reviews on yelp.com because declarant supports Prop 8. Other website published negative reviews of store because support Prop 8. Declarant received letter, hundreds of emails and numerous harassing phone calls because of Prop 8 support. Discomfort with Friends/Family over Differing Views Thirty to fourty people have walked into store and expressed displeasure w/ declarant's views on Prop 8. Police Action/Inaction Police called at the second boycott but it was peaceable so protesters were allowed to picket. Doe v. Reed Claims of Harassment, Intimidation, etc. 2 of 204 Document Review 4/5/2010 Additional Claims Someone filled cart w/ groceries and checked out. After clerk scanned all groceries, person said not buying them b/c declarant supports Prop 8. Declarant installed 16 security cameras after incidents to protect integrity and safety of products in store. Doe v. Reed Claims of Harassment, Intimidation, etc. 3 of 204 Document Review 4/5/2010 Source: ProtectMarriage.com v. Bowen, Ex. 12 Page # in Filing: 9-14 Type of Document: Affidavit Name: John Doe #2 State & Campaign: CA, Prop 8 Incident Date: 11/2008 Location: ? Search Terms: Was the individual a donor: Y Is the incident related to donation only: Y Is the incident related to petitions: N Is the incident related to yard signs or bumper stickers only: N Is the incident related to other campaign activities: N If yes, explain involvement in campaign: Was the incident described in the media: ? Is the incident referenced in other sources: ? NOTES Unwanted Communication Flyer with picture and caption "Bigot" distributed in home town & references four-figure donation. Expressions of Religious Bigotry References "_____ Catholic Church." "Christ would not be proud of you." Doe v. Reed Claims of Harassment, Intimidation, etc. 4 of 204 Document Review 4/5/2010 Source: ProtectMarriage.com v. Bowen, Ex. 12 Page # in Filing: 15-25 Type of Document: Affidavit Name: John Doe #3 State & Campaign: CA, Prop 8 Incident Date: Late Nov. 4, 2008 or early Nov. 5, 2008 Location: ? Search Terms: Lutheran, church window Was the individual a donor: N Is the incident related to donation only: N Is the incident related to petitions: N Is the incident related to yard signs or bumper stickers only: N Is the incident related to other campaign activities: Y If yes, explain involvement in campaign: Preached to Lutheran church congregants; yard sign on church property Was the incident described in the media: Y Is the incident referenced in other sources: ? NOTES Vandalism Rock with a "Yes on 8" yard sign thrown through a church window. (Also note, Ex. A actually goes with John Doe #2.) Doe v. Reed Claims of Harassment, Intimidation, etc. 5 of 204 Document Review 4/5/2010 Source: ProtectMarriage.com v. Bowen, Ex. 12 Page # in Filing: 26-44 Type of Document: Affidavit Name: John Doe #4 State & Campaign: CA, Prop 8 Incident Date: Aug. 2008; 11/13-16/2008 Location: Entrance to gated community; business website Search Terms: Was the individual a donor: Y Is the incident related to donation only: N Is the incident related to petitions: N Is the incident related to yard signs or bumper stickers only: N Is the incident related to other campaign activities: Y If yes, explain involvement in campaign: 5 figure donation to the National Organization for Marriage, served in official capacity (perhaps general counsel) for ProtectMarriage.com; wrote articles; gave talks; held a fundraiser at home. Was the incident described in the media: Y, San Diego paper? Is the incident referenced in other sources: ? NOTES Unwanted Communication Lawyer claims 15-20 emails on new client forms (eight attached, incl. "tampon of the year award"). Listed on CaliforniansAgainstHate.org. At least one email referenced donation amount and fact that he had made a short term loan to campaign (not attached as exhibit). It says "I am boycotting your organization [a law office];" another refers to "scumbag personal injury lawyers;" another simply says: "Shame on your company for their lack of respect and intolerance for your gay fellow human beings. Shame," and is signed. Additional Claims About twenty-five protesters held signs outside the entrance to the gated community where declarant lives and was holding a Prop 8 fundraiser in August 2008. Doe v. Reed Claims of Harassment, Intimidation, etc. 6 of 204 Document Review 4/5/2010 Source: ProtectMarriage.com v. Bowen, Ex. 12 Page # in Filing: 45-50 Type of Document: Affidavit Name: John Doe #5 State & Campaign: CA, Prop 8 Incident Date: 11/15/2008 Location: firm website Search Terms: Was the individual a donor: Y Is the incident related to donation only: Y Is the incident related to petitions: N Is the incident related to yard signs or bumper stickers only: N Is the incident related to other campaign activities: N If yes, explain involvement in campaign: Was the incident described in the media: N Is the incident referenced in other sources: N NOTES Unwanted Communication One email at work, subject line: "Disastrous PR Move?" Message: "It will be interesting to see if your firm's donation to support the "Yes"… will prove true the axiom - any PR is good PR. I doubt it." Firm donation only. Doe v. Reed Claims of Harassment, Intimidation, etc. 7 of 204 Document Review 4/5/2010 Source: ProtectMarriage.com v. Bowen, Ex. 12 Page # in Filing: 51-56 Type of Document: Affidavit Name: John Doe #6 State & Campaign: CA, Prop 8 Incident Date: 11/28/2008 Location: Alamo, CA Search Terms: Vietnam Vet postcard Was the individual a donor: Y Is the incident related to donation only: Y Is the incident related to petitions: N Is the incident related to yard signs or bumper stickers only: N Is the incident related to other campaign activities: N If yes, explain involvement in campaign: Was the incident described in the media: N Is the incident referenced in other sources: N NOTES Unwanted Communication Received a Vietnam vets' postcard: "insulted me personally;" "personal attacks." Also listed on CaliforniansAgainstHate.org for five-figure donation. The postcard text is attached as an Exhibit. It is non-threatening and a challenge to think differently about Prop 8. Doe v. Reed Claims of Harassment, Intimidation, etc. 8 of 204 Document Review 4/5/2010 Source: ProtectMarriage.com v. Bowen, Ex. 12 Page # in Filing: 57-63 Type of Document: Affidavit Name: John Doe #7 State & Campaign: CA, Prop 8 Incident Date: pre-Nov. 2008 Location: ? Search Terms: church pastor Was the individual a donor: N Is the incident related to donation only: N Is the incident related to petitions: Y Is the incident related to yard signs or bumper stickers only: N Is the incident related to other campaign activities: N If yes, explain involvement in campaign: Was the incident described in the media: ? Is the incident referenced in other sources: ? NOTES Unwanted Communication Pastor received 1 phone call @ church from a woman who asked if they were a distribution center for petitions (they were) and if he "was going to sign the petition against divorce." He said he wasn't sure he understood, thanked her, and hung up. Vandalism Bumper stickers removed three times from family cars. The first time, someone put up a note asking why support Prop 8: "Please rethink your position…Please vote 'No' on Prop 8." Doe v. Reed Claims of Harassment, Intimidation, etc. 9 of 204 Document Review 4/5/2010 Source: ProtectMarriage.com v. Bowen, Ex. 12 Page # in Filing: 64-73 Type of Document: Affidavit Name: John Doe #8 State & Campaign: CA, Prop 8 Incident Date: post-election Location: home & work Search Terms: election night photo Was the individual a donor: Y Is the incident related to donation only: N Is the incident related to petitions: N Is the incident related to yard signs or bumper stickers only: N Is the incident related to other campaign activities: Y If yes, explain involvement in campaign: African-American who works for a church. Spoke out at rallies, 3 press conferences, and churches in LA, Orange, and San Diego areas Was the incident described in the media: ? Is the incident referenced in other sources: ? NOTES Unwanted Communication Picture taken at election night party appeared in newspapers. Then received "harassing letters and emails" and at least 1 phone call at work.
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