Professional Documents
Culture Documents
3:09-cv-02292 #191
3:09-cv-02292 #191
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
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
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
19
20
21
22
23
24
25
26
27
28
1 I. INTRODUCTION
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
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
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
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
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.
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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
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
28
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.
28
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
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.
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
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
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
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
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
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.
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.
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]
Gibson, Dunn &
8
Crutcher LLP
09-CV-2292 VRW PLAINTIFFS’ AND PLAINTIFF-INTERVENOR’S JOINT OPPOSITION TO
DEFENDANT-INTERVENORS’ MOTION FOR A PROTECTIVE ORDER
Case3:09-cv-02292-VRW Document191 Filed09/18/09 Page13 of 18
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
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
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
23
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
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
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
19 communications.” Motor Fuel Litigation, 2009 U.S. Dist. Lexis 66005, at *45. To the contrary,
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
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
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
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
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
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
4 Even still, to assuage any concerns about the threat of reprisals, in their last meet-and-confer
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
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
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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1
III. CONCLUSION
2
For the foregoing reasons, Plaintiffs and Plaintiff-Intervenor respectfully urge this Court to
3
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
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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
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23
By: /s/
24 Therese M. Stewart
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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.
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EXHIBIT A
Case3:09-cv-02292-JW Document191-1 Filed09/18/09 Page2 of 4
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.
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
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
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.
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.
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EXHIBIT B
Passing Prop 8: smart timing and messaging convinced Ca... http://www.accessmylibrary.com/article/print/1G1-1947...
Case3:09-cv-02292-VRW Document191-2 Filed09/18/09 Page2 of 6
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.
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.
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
Passing Prop 8: smart timing and messaging convinced Ca... http://www.accessmylibrary.com/article/print/1G1-1947...
Case3:09-cv-02292-VRW Document191-2 Filed09/18/09 Page3 of 6
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,
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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 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
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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.
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
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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.
9/15/2009 1:00 PM
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EXHIBIT C
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A p A FE.
AN.
LIE
TABLE OF CONTENTS THE 18TH ANNUAL POLLIE AWARDS 8t CONFERENCE
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 &
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Mark Bunge, Hart The University of Media Jamie Emmons,
Achim Bergmann, Research Associates
SC Strategies. LLC Akron Marcus DellArtino. Emmons &
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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
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.
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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
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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
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York State Senate Campaigns and Associates, Inc.
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Jessica Fawson, Roberts. Getty Communications Bil Mcintyre. Democratic Assembly Associates
Michael Grossman. Renecca Perkins. The Jacob saFcerstein, Sean Sullivan. HSC,
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Case3:09-cv-02292-VRW Document191-3
Fortune Med ia. Inc. Jon Melzer Precision Politics - Jason Ralston, for Reproductive Ken Winneg.
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FieldWorks, LLC Craig Hickox, KTVU- Larry Kamer. Kamer Media Communications Margie Omero, Bart Robnett, Campaign Finance Amos Young Jr..
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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.
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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.
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Committee Superior Campaigns Ventures, Ine George V. Voinovich,
Filed09/18/09 Page4 of 14
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2007 -2008
Case3:09-cv-02292-VRW Document191-3
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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
Case3:09-cv-02292-VRW Document191-3
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
Case3:09-cv-02292-VRW Document191-3
1990 (copy) Governor Mimi Called Him Darlin' Free Home Delivery
Les. Than Full BmbenderCox Automated Call.: Turning North Carolina
Weichert & Bri1z, Inc. National Organization Zatal3 Con51llting Red 10 Blue With Q Zalal3 Con'Lllting
Page: State Silver Rain Lady (Spanish)
Bronze Sile Didn" Use tlie 'T' Silver Lilt Ie Green Silver
50 Blue. LLC
No Deal for Wall Street AT&T Engage Silver Mrs. VEEP Cl:n Teach Word Zalal3 Winning Connection5,
Rainmaker rvledia Groiip Yee on 411- li1l:13 Consulting Con:eiiltill9 Huffman Hit F/lvl Inc. Skelly for Congre:es
Mercury
Paradi5e Valley Silver CPEC. LLC Silver Winnill9 Connec1iOlls.
Silver Silver Siiell Gl:me (Kre'lol) Bronze
HighGrQLlnd, Inc. Broiize Inc.
50 Blue. LLC
Honorable Men1ion To Serve and Rebil1 Gwe tiie Middle CIl:sS Bronze
Too Mucl? AT&T Laimer Bronze Automated Calls:
state Organizatj.;. Zalal3 Consulling Hell Halh No Furv Like a Break
H;:ckney & Hl:ckney Mercury
For State Organiz8lion Bronze l: Republican Scôried \i'Jinning Connectione, Bill Foster Triumphs in
Bronze Bronze Siiell Gl:me (Spmish) Inc. Former Repiiblican
Henry Jones Ie aile of Zatal3 Con51llting
50 Blue. LLC Bronze Slronghold
Switzer Us Pure Nirvana Down Honorable rvlention
Th;:nks. Capt. Ted! AT&T Whatever Honorable Mention The Clin10n Groiip
Hackney & Hackney li1l:13 Consulting Ballot
H;:ckney & Hl:ckney MercLiY Honorable Mention
Bronze Bronze Zalal3 Con'Lllting Automated Call.: Live Calls;
Honorable Mention Honorable Mention Independent State Organization
Honorable Mention
B.st Us. I)f NegativeJ
Phones Expenditure üve C.zlls; Governor
less Than Full For County Govenment Automated Call.: Campaign: Federal:
Contras L(icalOrganization Automated Call.: But Will They See
Page: Lo"a1 Persuasion Candidate Democrat the Ad.? Ivarkell for Governor
Statewide
TRUST Constitutj.;.al Ofic. Stones' Phones 'Winning
Lambert far JlIdge Pro1ec1 Your Second Ozinga and Blagojevich
Skate Board (EngliBli) Automated Calls: National Silver Connections, Inc.
'Weichert & Bri1z, Inc. Amendmen1 Righ15 Siltiil in l: Tree
111e Ca:ale GrOllp 60 Blue. LLC Grassro(lts Philly Down 6allo1 Bronze
Bronze The Ca5ale Groiip Stones' Phones
Silver Silver CPEC. LLC
Bronze Silver
Elizabeth Edwards: No to Silver
rvkCain Health Care Plan
Filed09/18/09 Page10 of 14
S10nes' Phone5
Bronze
16 11
Live Calls: Statewide Mi)sl Inn(lvative Use All This Without a Tax Un Call.: Carrots for CAFE Letter to the Editor Best U.e 01 800 State L.gislalur. Bes U.e of Bilngual/
Constitutionzi Office of Autom med Hike? Membership Winning Executive Te..nology Negmive/Conlr.zst Multilingual/Foreign
Te..nology Zatal3 ConE-Lilting Organization Connections, Inc. CommLlnications, Inc. AI'utaye There
Language
Only i3 Heartbeat AVIJay Bronze Bronz.e Honorable Mention Stop the Cuts' Com pas.s. Mad ia Groii p Gone, Gone
Stone5' Phons5 Neighborhood Voices Montaiu:i Pkinned Stones' Phones Broiize The Jackson Group Yes on Proposition 8 -
Bronze Spoken Hub Autommed C..ii.: Parenthood - Automated Call.: Li.. Calls; City Gold Gold "It's Already Happened"
Gold National Organization Decline to Sign! local/Municipal Government Scliiibert Flint
Winning Plaiie Public Affairs
Biillock for Attorne~( Org.znizmion PersuZlsion Best Use of J im Slatter~dor
Connectiona, Inc. Scout Communications Silver
General Building Franken's Army You Call Thm Hunting? Telephone Town Hall Honorable Mention U.S. Senate-
Silver Warning! DetoLlr Ahead Looking a QLiarterhor5e Call/Forum Call "Merci. Pat Roberts"
Winning Stones' Pliones Zatal3 Coiisulting
Connections. Inc, Yom Union Says No to ConnectCallUSA.com in the Mouth Nortli Woods Mas5achu5ett5 Fam ilie5
Silver Bronze Local/Municipal/
Propo5ition 8 Zatal3 Consulting Advertising The Ne\'Y rvledia Firm
Honorable Mention Broiize Held at Gwipoint Region.zl
\ill/inning Silver Silver Bronz.e
Press 1 for Text, Automated Calls: Connections, Inc. Zatal3 Coneu lliiig
Live Calls: State Press 2 for E-mail State Organizati-on Bronze Automated Call.: Silver Big Rock
Governm ent latalS Coiisiilting Bilngual/ live Calls: National "YoLI're Oiit" - Pryor Best Use of Humor
Multilngual/Fi:reign Organizath;i JohnsonClark for State House
Broiize Clean \i'Jater Rendell Uve Calls: Bilingual/ lovia's Katriiia Associates
Last rvl inute TLinout CPEC. LLC
Language Zatal3 Coneu lliiig Fletcher Rowley Invasion of the Two-
Multilingual/Foreign Silver
Win ning Tliank You, Freshman Riddle. Inc, Faced Lawyers
Wan. Wan Do Tell Ivle Silver Language Bronze
Connecions. Inc. No Loss in Tran5lation Winning Bronze Hackney & Hackney
lV/ho Yoii're Siipporting) CQthi Compton
Bronze Stones' Phones Stones' Phones Connections. Inc. Silver
Live Calls: Statewide Mi FQJiliQ, Vota- Freshman Teleplione for Judge
Honorable rvlention Camp.zign Bronz.e Silver Tovm Hall DOLI blespeak
No on 20D! Paecliall Strategic
Live Calls: Local Winning Zatal3 ConsLilting Communication5 Hackney & Hackney Public Affairs
G-overnm ent Best U.e of Protect South Dakota Connection5, Inc. Live Calls; Federal Let'. Get Em Talking' Honorable Mention Bronz.e Honorable Mention
Telephone Town Hall Famîle:e Silver
Government Executive Fo.. Federal
Wilen a Wiii 18r1't a Win Call/Forum Call Wiiining
Persuasion Communiætions, Inc. Bal/or Gi:vernment
Circiis at City Hall
Stones' PllOliea Connection5, Inc. Public Affaire.
Broiize Persuasion
Bridge Loan for tiie 1 st Strike Creative
Bronze Accouiitability Update Silver Honorable Mention For Statewide
Auto Industry Live Calls: State Campaign Oem ocracy for
Stones' Phone.s Autommed C..ii.: Candidat6
Executive Organizath;i America - "$30 Bill"
Live Calls: Broiize Fed Up Wnh Federal Government Commiinicatioii:e. Inc. Bilingu.zll
Contr.zst/Negmive TC1es Maine Persuasion Invasion of the Norlli Woods
Silver President MultilnguallForeign Advertising
Luv Va But i The Clinton Group We Are America Language Two-Faced la~lers
Gecrgia Familie5 GottaRiln... Bronze Regulate. Don.t Alliance RecrLlitment Hackn~¡ & Hackney Silver
You Gotta Figtitl For GOTV Obama for America:
Ive Siiffering latalS Coiisi,lting Rider HQ,te Suefio Americaiio Gold
Your Right! To Unionize! Winning Butlercow L.dy "Call" - Democratic
Wiiining Honorable rvlention Live Calls: Stones' Phoiies Me:esage Audience &
Connections. Inc Stones' Phones Connections. Inc. Obama Media Team Congressiom:il
County eam paign Bronze Bronze Presentation. Inc. "Doctor Daughter" -
Bronze Bronze Bronze \Na5hington's Campaign Committee
Ballot Silver Allan B. Crow &
Yes on 1-100
San rvlateo Carrots for CAFE Thõink You, Fresliman Associates
Li.. Calls; LOG..I/ Obama for America: Fletcher Rowley
Lummis' Behavior a5 Autommed Call.: Zatal3 Con8ultîng Winning QLle SLlenen en Grande
Unethiæl as Cubiils Winning Municipal "Becau:ee" Riddle. IIlC, Bronze
Statewide Campaign Bronze Connectiona, Inc. Connection:e, Inc, Organizath;i Mes5age ALldience &
Winning Obama rvledia Team Silver
Case3:09-cv-02292-VRW Document191-3
Silver
18 19
For State Obama for U.S. Senate: Front Door Jeff Cloud - Family Cruelly Lincoln Diaz-Balart Repiiblican Na1ional Suei;o Americaiio For County Campaign
Organizath)n America: "Mother" Derr..:u::rat Murpliy Putnam Medil: The Strategy Group for Wild Buncli Consulting "Police" Committee - Message Audience &
Obama Media Team Honorable Mention Media Honorable Mention The Victory Groiip Jolin McCain Bio Presentation. Inc. Mel:sure A lV
Universal Health Care Honorable Mention Hwnbled Honorable rvlention Bronze Strategic Silver Cam paign
Foundation of Mmphy Piitnam Media Perception, Inc. Braincliild Creative
U.S. House: Bes Use of Humor
Coimecticiit - Presidenti.zl Prim.zry; Gold Republiç.n St.ze Legislzdure; Seal Broiize Las Americas Gold
"Ne\'Y Day" Republican Democrat DSCC-IE Minnesotl:: Adel5tein I Li5ton Ivle5sage ALldienre &
North Woods Jolin rvlcCain for Presentatiol1, Inc.
Advertising Kitchen Father "Running Man" Honorable Mention Eieenhower
My Christmas Story Hole President "Tin)( 60" Bronze
Silver Joe Slade Wliile BrabenderCox GMlvlB SeeCliange Media
MH Media and Com pany Scout Communicl:tions Strategic Perception,
Silver Gold Best Use (If Silver
Inc.
Gold Silver Silver Negative/Contrast: "Dos Gotas" -
Voter Fraud - Oliio State Legislature! Honorable Mention Taddeo for Congrees
Repiiblican Party Greg Walden Riglit Here CI1ildr€lii Oregon Zoo
Romney for President- Rocking Chairs Right Now Brighter Future LocaI/Muniç,ipal/ Fletcher Rowley Measiire "CrLlcial. "
Com m un ications David Browne &
"Searched" Regii:-nal Be.t Cable-Only Riddle. Inc, "Heoltliy." "Experts"
Counsel, Inc. Sqiiier Knapp Dunn The Victory Group Dl:vid Browne & Associl:tes
McCartlw Marcus Comm un ications Associatee
Broadcast Honorable Mention Gm-d Communic8tions
Bronze Bronze Silver
Hennings. Ltd. Bronze Broiize Wife Beater Bronze
For Public Agency Tiie Jackson Group Signs
Silver Volcano Ivllim bo JLlm bo B""t Use 01
Gold The Parkside Groiip PersonalityfCelebrity
Mark Warner for BrabenderCox AIITI"e" David Browne & Road Safety
Save Water. Silver
Notliing Can Replace Chiick Norris Senate: Budget rvless Honorable rvlention SeeCliange Media Associates SeeChange Medi8
Approved - Primmy GlvlMB Honorable rvlention Bronze Busl, Guy Bmney Honorable Mention
Ii - 60 Second
Dresner, Wickers & Honorable Mention Tiie Jackson Group Obama for America: Obama Med ia Team
The Eppstein 05e for Congre55 "Fundamentl:ls"'
Group, Inc. Associates. LLC Silver Silver
"Mapquest'. TV Stl:te Legisll:ture: Hey Elk For City Campaign
Bronze Obama Medi8 Team
Silver U.S. Senate: McNally Temple Repiiblican Scott Howell &
Republican Pre~(, South Cm"Olina Bronze Qu ico Canseoo -
A550ciates, Inc. Com pany Density
Best Use of Humor "TESTED": 60 Honorable rvlention Childi5h Ivliidslinger Honorable Mention Senate Democrats Ranger
Obama for America:
Mercury
Chris Mottola Ll:m ar Alexander for SamLlel rvl, Goldstein Allan B. Crow Tiie Strategy Group
"No Maverick" Silver
Consulting, Inc. Senate Carn paigii Productions, Inc. & Associates for Medil:
"Call" - Democratic Stollewide Best Use of Obama Media Team
Congressional Honomble Mention Sirategio Constitutional Bronze NegativefContr ast: Silver Silver
Perreption, Inc. Honorable Mention Strong Schools
C8mpaigii Committee Office: Democrat Pr.sident Mac,,Villiams Kirchner
Allan B. Crow Presidenti.zl General Silver Tough Mountain "Diane's Story" - Obama for America:
Sanders & Partnere
& Aseocia1ee Electh)n: Demf)(:rat Bleæed Judgment Sclineider for Tele'lsi(ln Ad: Mf)re "Embrace"
The Eppstein State Hoiise Th.zn 60 Seç,onds Bronze
Silver Lam ar Alexander for David Browne & Group, Inc. TrulhaiidHope.org PAC Obama rvled ia Team
Coiintry I Love Selll:te "Good 60" A550ciates Fletcher Rowley Bronze
Honorable rvlention Gold Riddle, Inc. Yee Oil A, San Francisco
UHCF - "Governor's Obama Media Team Strategic Gold Barack Obam a - Jolm McCain for
Perception, Inc. Bronze American Stories, - \iVhen Second5 COLlnt
Office" Silver President "Celeb" TV
Lf)(:al/Municipal/ Ol:ma for America: "90 American SOiLition5 WhitehilrstfMosher
North Woods Bronze Motivation Region.zl Percent" Strateg ic
"My C8ncer Swalm"- Obama Media Team Perception. Inc.
Cam paign Strmegy and
Advertising Buster Murphy PLltnam rvledia Obama rvledia Team Media
Bronze McConnell Senate Accountabilitv Colorado Gold Honorable Mention
Obaml: Media Team Silver Blair Jennings Rachel Silver Honorable rvlention
Committee '08- Fletcher Rowley
Bronze Sottile Ad
"Garee" Riddle, Inc. Obama for Amenca:
Case3:09-cv-02292-VRW Document191-3
20 21
For Membership Yee Oil Propos.itioii 8 - Get Something Done For Local/Municipal Best Use of International Let':e Go for the Yes DSGG: Here. There. Best Fundraising Best Viral Campaign
Orgarization "It'. Alr6ady Happen.d" Murphy Putn;:m Media Organizatii:n N.gativ./Ci:ntrast Newlink Political Everywhere Eff"rt
Schubert Flint Honomble Mantioii Euroean Bronze FD Element Joii Miclli:el Durkin for
Arizona Realtors - Public Affairs Reeet Clown Bronz.e 2D10 Tim Ryaii U.S. Senate
Pieces Bronze For State 1m pact Políic.. LLG BrabendetCox Alvaro Colom for Senate Budget & Robert Niery - The
Bes Print/Graphic. Fundraising Plan
The Steveiis & Governm ent Broiize Silver Guatemala: De5tino Phones; Autom med University of Akron
Schriefer Groiip Non-Broadcast Video Persuasion GMlvlB Call. Joeliiia Brickner - Ray Silver
Gold
Progres Comuiial. C. Bli5s InstitLlte of
Toucliscreen Both Ways Barack Andorran Eledions Honorable Mention Applied Politics
lrra Web H its Home 1m pact Políic.. LLG RapidResponee Segarra-Teres RavenstalillO'Coniior Best Use of YouTube
Rich
Silver
Joe SIi:de Wliite Compi:ss Medii: Group Honorable rvlention rvledia. Inc. Intertational Asia-Pacific CPEC. LLC
Joe Slade White and and Company Silver Bronz.e Silver Bronze College Democrat5 of
Company Gold Best Website America: Super
For Publi,ç Ag.nçy Bes Fundraising
Silver Yo:cht Party GaffneyiObamaiBiden Radio Delegates
Bes T.I.'lsion Ad College Democrats
Bes Cable-Only Courage Cam paign RapidRespon5e Tamia Booker - College
Flex Ymir Power "Talia" Anwar i braJlim of New York Democrats of Americi:
Best Use of Humor Broadcast Bronze MediQ.liic. Action The Gambler
Braincliild Creative Eleclioiilvlall John Farrellv - Gold
Silver Honomble Mention Ri:bin Strasberg Medii: Technologies. Inc. Rainmaker Media Groiip Fordham UI;iversity
Colorado SAFE "Ivliig" Fii1iire Shock - TLlrning Dino Ros5i's Bronz.e Silver
Measure A
Bronze Gold Best Use of Social
Squier Knapp Dunn Meseage of Cliange Best Use of
Communic;:tions Bri:incliild Crootive For Membership N.twi:rking
Against Him Org.znizirion BilinguZll1 Best Television Ad I'm Don's Piippet
Bes Website Bill Stacliowski's
Silver Silver The Campaign Groii MultilinguallForeign
Language Rainmaker Media Groiip Cam paigii V'Jabsite Study of Social
Honorable Mention Renewable Fuel5 Reliive Bronz.e John Farrellv -
Yes oii Ohio Issue 6 - Decide Ken Livingstone for Networking, 2008
Association - "Right Mayor Rabin Strasberg rvledia Fordham Uñiver5ity Preeidential Race
Thanks Ol1io Version:2 M;:cWilliams Kirchiier For Nidional Here, Riglit Now" Gracias Jefes de
las Uniones Blu" State Digita Bronz.e Buzz. Sandy for Virginia Bronz.e Brad Tidw,,1I -
Sanders & Partner:e Organization Tl1e Stevens & Silver Delegate - New York Tiilane Univer5ity
The Strategy GroLlp Broiize Schriefer Group Berman and Company
for Media Best Website Spot 00'"") for City Gold
"How Mucl Time Gold Silver
Bronze Bes U.e "I SJA S1rategie5, Inc. Court Judge
Bes Use "I Sholiid Si,,, Do?"' TV Honorable rvlention Brvon McKim -
PersonalityfCelebrity Best Use of Gr assroots Anwarlbrahim.com
A Hou:ee On Fire Nat ional AS50ciat ion of IvlcKim Strategie:e
;'Professor" TV Silver Realtors - Capito Personality/Celebrity Eleclioiilvlall
PrQgre5 ComLlnal. Technologies, Inc. Tel.'lsi(ln Honorable Mention
Hanon McKendry No on Proposi1ion 8 Q.ir Tl1e Stevens & Scliriefer
Hoiiomble Mention Ovm "Vote Prevention" PFCD Andorran Election:e Silver
Alliance for Climate Groi.ip
Segarra-Teres Dram atization Best Radio Ad
Kaufm an Cam paigii Pro1ection Silver 720 Stmtegies/a-
Consultant5 political
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