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I dont even know why im on here...i just realized i dont wanna update!! oh well just got back from the skatepark a few minutes ago! i love the skatepark really its fun!! but me and lori realized that skateboarders are MEAN they drive their rich mercedes to the park COOL!! i rode kyles bike down the HUGE hill and got pretty excited!! after that josh phillips was pretty nice to me! i felt glad! i dunno it was fun, i enjoy those kids.....--lets see what else, oh dale cancelled on me=again=not gunna hang out unless he asks...im thru WHAT?! haha chappelle's show...its funny watch it ok this is really short so i might be back tomorrow only time will tell bye..
Ok lets see....this weekend...friday, was going to go to Riders BMX with kyle, colin, josh, and lori..so we get to kyles were all ready we pick up colin and its 400 and i have to be home at 430 and traffic is terrible!! so i asked kyle home late he thought i would be AN HOUR late...so im like screw taht take me home. i get home and i am very angry!! oh well lori said it was not that fun. so i get to church EARLY >:-O i was MMAADDD!! lets see started out everyone was not too excited about being there. they fed us soup and bread...thats it the whole night, that was my only meal of the day! so luckily courtney brought food and shared with me and mel. also my mom made me leave my cell phone at home, but mel brought hers so that was good!! i dunno friday they kept us up till 12 and we were all dead tired so we fell asleep fast, they separated the boys and girls around 1145, we were all in the gym though. saturday they woke us up at a lovely time of 7! GRR! we were again all dead tired, but we get on the bus and drive oh id say 10 feet to sum brick building. we had hardees for breakfast, it was yummy, i ate everyone elses food. hehe!! lets see what else, oh yeah we had seven "flames" to do, man were they BORING!!! we were all like this is gay and it was! lunch was SANDWHICHES YESSSS!! not really, they never let us leave the stupid brick building from 8 am until 4 pm....never got to go outside!!! it was terrible we all felt like we were in jail. at 4 we went back to chruch and had the choice to do confession, i did, and i felt better really. i havent cussed since, yes its hard haha! so the retreat wasnt all bad, cus i mean i got to know everyone in the class a lot better. and i harassed some of them more then others (patrick and aaron oh and the twins) and one kid in my class chews, and he was chewing at church GROOOSSS!!oh well thats about it for my weekend, last night i did get FIFTEEN hours of sleep! it was amazing. ok i have a test to study for byebye!
Hey playas whats shakin?? lets see, in recent days....Dale ditched me again :( i had a feeling he would! I got in a HUGE fight with my parents and i said "screw you" to my dad, and he said "ill pretend i didnt hear that" and so me being the rebel i am said "NO! DONT PRETEND LIKE YOU DIDNT HEAR IT....CUS YOU DID HEAR IT I SAID IT!!" we started new classes!! spanish (ehhh that OK...loris in it), anatomy (hughs hates me already, tiggertab's in it!), english (i hate spencer, kate and tig are in that), BUSINESS (i never thought id like that class...now i do, everyones in that), geography (i dont like it...no ones in it ) hmm anything else?? ohhh yes!! TODAY!! wednesday...the wonderful half day! lets see started out by going with lori...wait wait right be fore that in the hallways, ran into AAKASH (that boy is sooooo hot!) then we left and got caught by a train...BOO! so we turned around then im like oh its gone! no it wasnt!! haha so were sideways in traffic, and tina estranda in her NIIICE 3000 GT lets us in (actually we forced our way in)...trains still there...we see a ton of mustangs turning around, one looks like erin...so we see this mustang TURN AROUND IN SOMEONES YARD yeah tahts erin hahahahh!! then we get on this one road definitly going 80 haha...get to china buffet first heck yah!! everyone was at china buffet, enoguh about htat. after we went out and i had a nice chat with kyle mullen. then he leaves and colin and well just call him 'mark' say "HEY LORI!! CAN U GIVE US A RIDE TO THE SKATEPARK??" lori chants NO! unless they get THREE dollars in gas...within i swear to you 5 minutes they have the three bucks, and we say what no we said FIVE dollars hahaha!! so colin goes in kroger and tells sum lady he car broke down and he needs gas...NIIIICE! so we decide skatepark=hot guys, well do it! boy were we RIGHT!! whew baby. there was one in particular i had my eye on. yah he was hot...."darcy". haha yeah lori asked to ride his bike cus she was gunna ride with me (me on colins) and she said shell give him head if he lets her ride it hes like WELL IN THAT CASE!! haha! so then we decide to go up to him when hes at the monster VAN and act like were really gunna give him head...so yeah that worked for a while...then he was leaving so i decide to walk him out to his car/van. he liked it, he cant lie. he gave me a hug...i herad sum sad stories there...this one kids drinks, and last weekend there were 3 suicide attempts and darcy said his friend friend shot himself becus his mom was gunna send him to military school. so, his freinds spraypianted a cross with the name "bryan christy" in the middle of the park becus if bryan would have skipped school thats were he would be. i really had tears in my eyes when he told that story...ok well in a brightner note sum other hottis there were...biker justin, josh, mark, colin, i forget some of their names!! GRR...oh well this is a MASSIVE entry so im out later hottis! Much LovE!
Hello! today i am in a bad mood...so lets just talk about yesterday...MY BIRHTDAY!! lets see it started out where my dad took me to school and i walked in with erin! then u know regualr school day...kaitlin put a sign on my locker...now that the bdays are on TV tons of ppl said happy bday...except megan. hahah i love when she does that! anyways, lets see after school lori took kaitlin and greg home. we saw eddie, blake AND sumone else..but it was funny! then we rose the roof and sum kid mocked it...it was sooo funny!!! then we dropped greg off cus he was in a bad mood! so then we went to willards neighborhood...and saw kyle mullen riding...we stayed at his house for what was it like 30 minutes..till he had to work at PANERA BREAD!! that was fun...then i went home and talked to jordie forever! then alii randomly stops..throws a ball at james being the LOSER that he is he runs home and cries to his M O M M Y! and the mom says to me "I NEVER THOUGHT THIS LITTLE GIRL WOULD TURN INTO A BULLY!" HAHAHAHHAHAHAHAHHAHAHAHHA!! cool!! haha....then i go to bburg to eat at la jarapido sumthin like that...it was good! and jordie and dan randomly stop by, hes a cutie! but anyways...after taht went to grandparents house to open gifts...and went to KANES house...he wouldnt look me in the face so i tried to make him..yeah hes a lil bit strong! so then we paraded outside were i procede to ask him to wrestle "no becus the neighbors might see" WHO ACTUALLY CARES?? oh well then i went home..so far i have at least $130 in gas paid for hopefully holding me for a years worth! well yesterday was an awesome bday...thanks for all my gifts and happy bday's guys...i love you!!!! im out..
i hate having to redo these!! stupid computer!!! ok...so agian!! GRR...this weekend i dunno jon came home but i didnt really get to see him cus our scehdules didnt work out, i spent the night at loris on saturday, and will and adam came over...taht was ok except the whole banana incident....lets not go there, and the wholre writing on micahel wynnes calander and him gettin really really mad!! what else...oh yeah i found out i cant go to texas for spring break and normally i would be like my life is over...cus i was TOTALLY looking forward to that, but now im just like oh well stuff happens! this positive attitude thing kicks butt!!! but yesh...megan came over that was cool u know! holla megan!! this weekend is huge for me...I TURN 16!!!!! which means in a month GET OFF THE ROADS!!! literally!! but i am having a lotta bashes for me bday...one with the grandparents, one with cousins, one with mom dad brother, and one with HOLLA FRIENDS!!! they sh0uld all be good! but u know what i think im gunna get outta here....but i hate everything about you....WHY DO I LOVE YOU?!
hey!!! haha shawnna i love wendys too!! today was a good daY!! lori actually drove to Dales house today!!! and holly cauger got hit by a car...kat newby=driver. wow u cant get hit by a car honestly!! well i had an awesome lunch!! aakash talked to me! ill give u the convo....Aakash (to lori): hey are u jen?Lori: uhh noAakash (to me): Whats up?Me: uhh nothin (very timid)Aakash: oh well we'll see u later (TOUCHES MY ARM!)Me:(speechless cus that whole encounter)Hey megan is over now so ill come back later...
Hi! well today was a good day...let us see first i got an A on my math test!!! wow i was so excited!! lets see gave out sum valentines...it was fun....tried givin amanda a valentine but she just ripped it up oh well i still gave it to jordan birtch. then tonight went to loris for a little bit...saw nick and megan at wendys...taht made my day. got dissed by kaitlin when she didnt give me a valentine! THANKS! since i personally made her one! COOL COOL!!! lets see friday night fever...we have wonderful friday nights! me lori and erin headed over to the usual wendys but travis wasnt working :( made us so sad. then headed over to pizza buffet too see zach, michael, d.rec etc...then headed to michael franklins, but he was not home. so went to wendys so lori could pee and saw STEPH! shes so nice...after that was penns house..then a car ride with a little game of pa diddle...girls rule!! also i would like to say THE GIRLS WON THE RACE WITH THE BOYS .... WE BEAT THEM NO MATTER WHAT THEY SAY!! thanks byebye!!
i didnt watch taht dang game!! who cares..plus i had forgotten homework to do. well the other night online i talked to this kid from triwest (harassed more like) and hes taking it dead seroius...AND HE CALLED ME TODAY!! ok, im just kidding with him and hes dead seroius...wow people kill me. anyways, today was so boring, and my throat hurt again but not as much as baby dales!! aww makes me sad. oh well, today i had to clean the snow off my car since i hadnt driven her in forver...took like 20 minutes to warm up then drove to walgreens and got gas. later went out agian and ran errands like went to chruch, library, and post office: HOLLA LETTER TO CHRIS! well i dunno much else, this is boring huh...oh well boring is better then me being depressed, ive gotten over taht :) love yall byebye
i dont know when i last updated..a lot has gone on really...i just had a TERRIBLE day, so much happened. it was a horrible night. and i found out sum stuff ryan said, that i mean i took offense to but not too much since i know hes just a horrible person. just proves it. oh well, i wrote chris a letter today in 4th hour...i think he prollly gave me the wrong address. haha oh well. i just realized too..again i realized this, that worse stuff happens to people and i need to just get over it, because if i just worry about the little things then whats gunna happen when something bad happens, yeah someone said sumthin mean about me, but its not like it hasnt happened to other people, u just gotta get over it. and it kinda makes me mad how you know i think im there for a lotta people when they need advice or sumone to tlak to and then when i need sumthin, theyre not there. but oh well...ill continue to help them, and i just wont worry about my problems as much, they could be so much worse, i really am thankful for all i have, and im realizing this too becus of what chris said, it is really starting to set in, but i tell u what, i am REALLY tired, so im gunna go to sleep, ill talk to you people( haha who am i kidding no one reads this) anyways bye.
man..i dunno, im just in such a bad mood today, i dunno why. i called kane and at first it was good, then it just sucked, it seemed like he was being mean and i think thats just him and i need to get over it, i take stuff too personal. oh well, ill try harder. awards banquet at ritter today was a good one, kidna boring oh well. this is gunna be short cus rents are hardcore gettin me to bed on time. i also called ryan...well he called me, and liked to lie and say he had to walk home from the high shcool to danville, i felt so sorry for him, then i find out HE LIED!! OHHHHHHHHHHH GOOD ONE!!!!! not really, i odnt know what tomorrow will bring, well two hour delay and hopefully a better mood, im out.
hello! lets see...friday, lets start there, i was supposed to hang out with ryan, but he decided getting high was more important. im kinda sick of people being obsessed with drugs, i got kinda angry with him for not hanigng out and he didnt know why. i was just like uh yeah ur annoying. he was funny on the phone though cus i was like stop chuckling and he said "i wasnt chuckling, chuckling is for santa." haha. then today i went to church with lori then me her ryan and greg hung out and went to the mall. we had to go to this other parking garage and we could not figure out how to pay!! it was so confusing then we got a lil lost till greg luckily knew where we were. so we had to take the interstate. oh well. headed back to avon, went to taco bell then saw kim at work. then my mom was being stupid and i dont know. yesterday really sucked though, i cried A LOT! and it wasnt just one thing even though everyone thought it was becus of ryan, i mean that was sum of it, but not the main thing, i shouldnt have cared so much becus i dont know him enough to care....too easily attached!! it annoys me how im like that. oh well i wanna take it slow with ryan, i hope that works, oh well if not, we are planning to maybe hang out this friday but "he cant make any promises ... in case sumthin comes up." since "bros before hoes" and i laughed at him saying that and he got mad hahaha it was funny. oh well i am very tired since i did not sleep at all last night!!! so im out.
AUNT FRANCES DIED TODAY!!! she was 96, and its sad because everytime i went to tell someone the story i would laugh, so they wouldnt believe me, and also i told CODY SHEETS!! and he laughed at me! haha just kiddin i love cody sheets. haha. today lori took me home, and ryan was tehre. that was nice, becus we talked u know and as he got out at TOM YARDS!! (love that kid) he gave me a hug haha more of an attack since someone kept chanting HUG HER DO IT!! oh well, i liked it! i talked to shawnna last night about some stuff i had to tell someone, and it just really really helped. she gave me amazing advice, and i like talking to her becus she doesnt make me feel stupid when i tell her stuff, shes really understanding! thanks shawn!! so at school i looked like crap, cus i had like no makeup on and a huge sweatshirt!! SICK!!!!!! but i dont konw...i guess this guy was talking about me, and this lauren girl was like hey how about u shut the f*ck up, ill kick ur ass if u talk about her! i was like aww thanks lauren!! shes cool. so then in the car i still had nothing on and i felt ugly, and i hate feeling like that, so ahah when ryan went in to get his guitar i put a lil bit a makeup on ;) im such a dork i swear!! oh well it was mostly a good day execpt aunt frances :'( but CARL IS COMING IN TOWN TOMRROW!!!! I LOVE THAT BABY!!
hey..im watching this show...my fat obnoxious fiance. haha it is so funny. well today was not the best. i think i have good weekends but not good weekdays. i also think i get worked up over nothing sometimes. like ryan "wanted to get to know me better" and yet i tried talking to him online and he was totally not talking. kaitlin had a few options of what might have been wrong, and she is usually right. so i dont know, i will try not to worry about it, i do wanna talk to ryan more though, get to know him and hang out with him more. then kane was haha hes just stupid. i really need to work on dealing with things, and just not worrying, because USUALLY i worry over nothing, but i feel if i dont worry then i should have. i dont know again im worrying!!! ahhh stop it!! this is bothering me, i just want it to be friday!!! i can tell too this week is gunna go by SOOOO SLOW!! well this sucks im really upset now, so im leaving byebye!
wow! last two days have been great! friday there was a show in brownsburg...some of the bands were really good!! it was like me and lori and greg....then at the show me and lori hung around some of her bburg freinds (the striaght edges) they almost got in a fight :( and i got along well with this nate. he gives good hugs!! he called me yesterday too. also friday i saw kane again. hes so hot! i couldnt stay long cus i got in trouble again. saturday me and lori went to church together THATS RIGHT IM CONVERTING HER!! haha not really. but then we hung out with greg and ryan. i didnt know how that would go with ryan since i thought he hated me. but it went so good! we met dale at best buy then all headed to the mall. i asked ryan to hold my hand haha and he gave me a dirty look. so i kept asking him until finally he goes "oh were u seroius???" and i was like YESSSS!!! and he goes oh yeah thats cool then. hes funny. we werent there long since a stupid cop was like hey u guys 18 if not u gotta go its curfew time IT WAS NINE OCLOCK!! then we dropped dale off to leave and greg me ryan and lori went to our favorite WENDYS!! then after that me picked up jake :-/ me and lori dont like him too much. we all went to ryans after that. he is soo good at guitar! we also rode dirtbikes till some fags called the cops on us, so we had to go in. then it was time to go!! so i was late AGAIN!! and i even called this time and still got in trouble. it was sooo stupid! but yeah so far an amazing weekend!! getting ready to watch the colts game (i think theyre gunna lose) OH HAH ALSO I GOT CHRIS TO SAY HE LOVED ME!! HooKemUT: i love u kristina YES!!!! ok love y'all!
just got home from a ride with dale. he yelled at me. tiffany was in the front seat, and i wanted to hear what was on country station so i leaned up and was gunna touch it but she was fightin me. and dale grabs my arm and says "IM TRYING TO F*CKIN DRIVE!!!" and i was just like wow! becus dale has never yelled at me. and tiffany was like dude dale calm down, and i think he said he was sorry, but i was not listening, i just put my headphones on really loud and laid down in the back. i didnt want to hear him talk, i just wanted to cry really. i mean never in my life has he yelled at me! it hurt really. so then we get to my house, and i just got all my crap and got out didnt say bye or thank you or anything. and i heard them talking to me, but i didnt care i just walked up to my house. i guess i should have said thanks but why should i have?? i just got yelled at. eh hes been real different lately, i dunno, im sad now. bye...
hey. today was uhhh well ok...after school got taco bell with kim and her sis (and lori). school was well ok i guess, megan stole my winter coat today, i was pretty pissed! well right now im talking to april wolcott, she thinks dale hangs out tiffany a lot and thinks hahah nevermind that. this weekend, i hung out with josh, and kate, and (dale) on saturday...THAT TOTALLY SUCKED! (dale) was such a dick, he didnt even say hey to me for 15 minutes, then i had to say hi to him! what a dick! i am so over him. so u know, then i had josh and erik drop me off at marsh and lori picked up and took me to see KANE. (oh with (dale) i kept talkin about other ppl (aka guys) since he was bein such a dick i didnt care) anyways, so at kanes house, we ran into the pizza guy haha, and then i drug lori up there, and we knocked dad answered and i was like is kane there and so unforunatley he was...i soo wanted to run away and i almost did!! but then he came to the door, he was hot! and lori left to go ride around the neighborhood a lil bit so i could talk to kane, and i was jsut in the little entry way, he was surprised to see me. oh well, it was all right i guess, we just talked a lil bit, and then lori came back and i said "can i have a handshake?" haha he gave me one and i was like "uhh can i have a hug?" and he gave me one and "i left" then u know, took josh and rasmey home. i made rams sit on my lap cus i felt bad he was all alone in the back cus he didnt want to sit on the leather (hes veigan). they were really interesting ppl. anyways this is so long, and i think im gunna get goin. later!
im tired...of course i always am...i went to bed around midnight becus i was reading, and then i was about to get offline but chris was on and i wanted to tell him im giong to texy for sb!! im pretty excited about taht...we talked about what wed do if we met...yeah...then i went to bed! today we had a gay convo..and erin wouldnt give me "my" (eriks) watch back! i was getting mad!! oh, i THINK i might hang out with saturday, and i dont know if i want to, since i havent talked to him in like a week. i just dont know! i heard he was sick thats why he didnt answer his phone the other day, and i felt bad cus i got kinda pissed, oh well. sexually harassed dale today with lori erin and kaitlin...dales a man whore really! haha, i think im leaving....gotta go to dads bday, read 4 chapters of to kill a mockingbird, do vocab, research paper, and math :-D!! yay, should be awesome! not, im out. comment y'all!
hey...today was back to school :( i really hate school. english is gay we have to read to kill a mock AND do a research appaer all in jan!!!! my stomach kinda hurt at school though...after i went to kaitlins house, then we got major drama (not with kait)..but its settled so its all good. went to pizza buffet with kaitlin...hot kid there! and sum WIERD! kid too. uhh harassed dale BIG TIME!! he never gets mad its kidna funny. lets see erik doesnt answer my calls...i think im over it really. i was talking to dale baout it (hes so nice) here a lil of what he said...im cuttin it down so it looks like i never talked but i just basically cut out what i said. (the "he" dale's talking about is erik)dale: im sorry dale: but u know what Me: whatdale: doesnt really sound to me like hes worth the effort dale: you will find someoneDale: im sure you will dale:dont worry about him dale: hes not worth it dale: well if he always seems pissed at you dale: just dont worry about him for a while, you know like talk to him occasionally dale: it will kinda piss him off, and make him realize the world doesnt revolve around him dale: i feel kinda like dr. phil me: hahahadale: i like it! dale: i can be like a counselor or some shitdale:i love talkin to you tina thats u know some of it. it really made feel better. i mean i guess i always wanted a guy friend i could talk to and stuff....and i never realized it b4 but i think dales that guy. u know the good guy friend. and im pretty happy cus thats waht i have wanted for a while. and i now realize i dotn need erik...really i dont...i shouldnt have to put up with stuff he does to me--and i think i just might have my brother sell his things on ebay, i mean hey if he wants it he has jsut as fair a shot as anyone. so yeah im done with him and all his crap. well i think im outta here again might be back tomorrow!
I just wanted to say hey to the hotti kane wallsmith. man hes soooo hot!! i just wish i could see him...he makes me drool hes so ah just wow.lets see what else is knew! SHAWNNA MADE ME THIS KICK "A" JOURNAL!! i love it..thanks babe! anything else knew? well erik called me during the pacers game...he was using me to look up scores on the tv..then goes ill call u after the game, yeah he didnt. faggot.---i put my two weeks notice in at work yesterday, now i just need to find a new job, my rents said theyd pay for gas...IF i get involved with school...not a chance im doing any more then i have to at avon!!---dale gave me his old hat! i love taht hat really.---lori got in road rage again! it was fun though, we kidna went out of our way though. oh well...i will be back later..hopefully ill be writing in this more, doubt it though :-/ im out. tahnks again shawn love ya!!
just got back from the pacer game..yeah i touched reggie miller, jermaine oneal, ron artest, and austin crostiere's hand and i got a picture of LARRY BIRD!!! IT WAS amazing. lets see huge updates!1. i met sum triwest kids aka erik and josh2. ramping thru peoples yards is soo fun!!wel ok about the triwest kids...erik is really hot and nice. but then yesterday he was soooooo mean and left me 2 places without telling me, yeah and drove off with me standing right by the car. i was so mad and sad, i thought he was better than that. so i was asking people if i should call him, they said yes and no, so i didnt. but still thank you to everyone that was there for me! lori, wer always have problems at the same time hope urs gets better!! ur the best! thanks for doing that for us. and thanks for tlaking to me in the car! well so today i didnt call erik, and i was in the car on the way home and i saw i had a missed call from erik. so i called him back and he said sorry. :-) so that was nice. and i listened to his message it was sweet, i jsut hope things work out with him, hes awesome. hold on eriks calling bye


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Beautiful location and resort, but a few issues
Our family of 21 stayed here for 6 days in July. The location is perfect - right on the water. Beautiful grounds and good resort amenities. The home is the only one that Chase on the Lake owns and rents and is three doors down from the resort. Marina and staff was excellent. Our issues were only with the condition of the house and the housekeeping. The home is two separate units. One side has only a window air conditioner, and the kitchen (which desperately needs renovation) gets very hot - no ventilation. The larger side is much better with central air and a renovated kitchen. Kitchens were not well appointed with utensils. Only basic things - serving spoons, one spatula, corkscrew and very dull knives (only small ones). Housekeeping was a bit lacking; perhaps because the house is away from the main resort. We had to ask for basics, like making beds, emptying trash, etc. Bedrooms on larger side were small, but very nice. Overall, our stay was enjoyed by all, but I would caution people who want to cook that they may want to bring a lot of their own equipment. I did speak to management about the housekeeping issue, and I sincerely believe that they will address that concern immediately.

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Audio welcoming connectors and new students
For more information about Teachers College and the Adult Learning and Leadership and AEGIS programs you can also access the following links:
Connect ALL is a peer mentoring program designed by students from the Adult Learning and Leadership Program (ALL) and the Adult Education Intensive Guided Study Program (AEGIS) of Teachers College to welcome and guide new students joining our masters and doctorate programs. Current students and alumni will serve as connectors for new students as they learn to navigate the program, TC and the experience of graduate studies.
This web page aspires to provide new students with answers to some of the questions you may have when joining Teachers College and our Connect ALL program. Through it we also hope connectors will be able to access useful resources that will assist them in guiding new students and allow connectors to engage with each other while exploring new ways to support incoming students.
The Goal of Connect ALL is to increase the sense of community in the ALL and AEGIS Programs at Teachers College.
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Perry et al v. Schwarzenegger et al
Filing 816
MOTION to Stay Pending Appeal filed by Martin F. Gutierrez, Dennis Hollingsworth, Mark A. Jansson, Gail J. Knight, ProtectMarriage.com - Yes on 8, A Project of California Renewal. Motion Hearing set for 10/28/2011 09:00 AM in Courtroom 9, 19th Floor, San Francisco before Hon. James Ware. Responses due by 10/7/2011. Replies due by 10/14/2011. (Attachments: # 1 Exhibit 1-26, # 2 Exhibit 27-29, # 3 Exhibit 30-36, # 4 Proposed Order Proposed Order)(Cooper, Charles) (Filed on 9/23/2011)
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 COOPER AND KIRK, PLLC Charles J. Cooper (DC Bar No. 248070)* firstname.lastname@example.com David H. Thompson (DC Bar No. 450503)* email@example.com Howard C. Nielson, Jr. (DC Bar No. 473018)* firstname.lastname@example.com Nicole J. Moss (DC Bar No. 472424)* firstname.lastname@example.com Peter A. Patterson (OH Bar No. 0080840)* email@example.com 1523 New Hampshire Ave. N.W., Washington, D.C. 20036 Telephone: (202) 220-9600, Facsimile: (202) 220-9601 LAW OFFICES OF ANDREW P. PUGNO Andrew P. Pugno (CA Bar No. 206587) email@example.com 101 Parkshore Drive, Suite 100, Folsom, California 95630 Telephone: (916) 608-3065, Facsimile: (916) 608-3066 ALLIANCE DEFENSE FUND Brian W. Raum (NY Bar No. 2856102)* firstname.lastname@example.com James A. Campbell (OH Bar No. 0081501)* email@example.com 15100 North 90th Street, Scottsdale, Arizona 85260 Telephone: (480) 444-0020, Facsimile: (480) 444-0028 ATTORNEYS FOR DEFENDANT-INTERVENORS DENNIS HOLLINGSWORTH, GAIL J. KNIGHT, MARTIN F. GUTIERREZ, MARK A. JANSSON, and PROTECTMARRIAGE.COM – YES ON 8, A PROJECT OF CALIFORNIA RENEWAL * Admitted pro hac vice 18 UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA 19 20 21 KRISTIN M. PERRY, SANDRA B. STIER, PAUL CASE NO. 09-CV-2292 JW T. KATAMI, and JEFFREY J. ZARRILLO, Plaintiffs, 22 23 CITY AND COUNTY OF SAN FRANCISCO, 24 25 26 27 28 Plaintiff-Intervenor, v. DEFENDANT-INTERVENORS DENNIS HOLLINGSWORTH, GAIL J. KNIGHT, MARTIN F. GUTIERREZ, MARK A. JANSSON, AND PROTECTMARRIAGE.COM'S MOTION FOR STAY PENDING APPEAL Chief Judge James Ware EDMUND G. BROWN, JR., in his official capacity Date: as Governor of California; KAMALA D. HARRIS, Time: Location: in his official capacity as Attorney General of California; MARK B. HORTON, in his official October 28, 2011 9 a.m. Courtroom 9, 19th Floor DEFENDANT-INTERVENORS' MOTION FOR STAY PENDING APPEAL CASE NO. 09-CV-2292 VRW 1 2 3 4 5 6 capacity as Director of the California Department of Public Health and State Registrar of Vital Statistics; LINETTE SCOTT, in her official capacity as Deputy Director of Health Information & Strategic Planning for the California Department of Public Health; PATRICK O'CONNELL, in his official capacity as Clerk-Recorder for the County of Alameda; and DEAN C. LOGAN, in his official capacity as Registrar-Recorder/County Clerk for the County of Los Angeles, 7 Defendants, 8 and 9 PROPOSITION 8 OFFICIAL PROPONENTS DENNIS HOLLINGSWORTH, GAIL J. KNIGHT, MARTIN F. GUTIERREZ, HAKSHING WILLIAM TAM, and MARK A. JANSSON; and PROTECTMARRIAGE.COM – YES ON 8, A PROJECT OF CALIFORNIA RENEWAL, 10 11 12 13 Defendant-Intervenors. 14 15 Additional Counsel for Defendant-Intervenors 16 17 18 19 ALLIANCE DEFENSE FUND Timothy Chandler (CA Bar No. 234325) firstname.lastname@example.com 101 Parkshore Drive, Suite 100, Folsom, California 95630 Telephone: (916) 932-2850, Facsimile: (916) 932-2851 22 Jordan W. Lorence (DC Bar No. 385022)* email@example.com Austin R. Nimocks (TX Bar No. 24002695)* email@example.com 801 G Street NW, Suite 509, Washington, D.C. 20001 Telephone: (202) 393-8690, Facsimile: (202) 347-3622 23 * Admitted pro hac vice 20 21 24 25 26 27 28 DEFENDANT-INTERVENORS' MOTION FOR STAY PENDING APPEAL CASE NO. 09-CV-2292 VRW 1 TO THE PARTIES AND THEIR ATTORNEYS OF RECORD: PLEASE TAKE 2 NOTICE that, on October 28, 2011, or as soon as the matter may be heard, before the Honorable 3 James Ware, United States District Court, Northern District of California, 450 Golden Gate 4 Avenue, San Francisco, California, Defendant-Intervenors Hollingsworth, Knight, Gutierrez, 5 Jansson, and ProtectMarriage.com (―Proponents‖) will move the Court for a stay pending appeal.1 6 The issue to be decided is: Are Proponents entitled to a stay pending appeal? 7 ―In 1996, the Judicial Conference of the United States adopted a policy opposing the public 8 broadcast of [trial] court proceedings.‖ Hollingsworth v. Perry, 130 S. Ct. 705, 711 (2010); see also 9 Ex. 2 at 54. This policy was rooted in ―decades of experience and study‖ showing the potentially 10 negative impact of broadcasting on trial proceedings. Ex. 3 at 1; see also Hollingsworth, 130 S. Ct. 11 at 711-12; Ex. 4 at 46-47. In July 2009 the Judicial Conference forcefully reiterated to Congress its 12 conclusion that the ―negative [e]ffects of cameras in trial court proceedings far outweigh any 13 potential benefits.‖ Ex. 3 at 1. 14 Also in 1996, the Ninth Circuit Judicial Council ―voted to adopt the policy of the Judicial 15 Conference of the United States regarding the use of cameras in the courts.‖ Ex. 5. The Council's 16 policy thus provided: ―The taking of photographs and radio and television coverage of court 17 proceedings in the United States district courts is prohibited.‖ Id. ―[T]his policy [was] . . . binding 18 on all courts within the Ninth Circuit.‖ Id. Accordingly, this Court adopted Local Rule 77-3, which 19 prohibits the ―taking of photographs, public broadcasting or televising, or recording for those 20 purposes in the courtroom or its environs, in connection with any judicial proceeding.‖ 21 Hollingsworth, 130 S. Ct. at 710-11 (quoting Rule 77-3); see also id. at 707 (Rule 77-3 ―forbid[s] 22 the broadcasting of trials outside the courthouse in which a trial takes place‖); Ex. 6. 23 24 Despite these authorities and the Supreme Court's decision in this very case enforcing them, this Court ordered that video recordings of the trial proceedings in this case be unsealed and made 25 1 26 27 28 Although we have noticed this motion for the next available date on this Court's calendar that is at least 35 days from today, see Civ. L.R. 7-2(a), we are also filing a motion asking the Court to expedite its consideration of our stay motion. Specifically, we request that the Court rule on our stay motion before it is mooted by operation of the Court's order unsealing the video-recording on September 30, 2011. 1 DEFENDANT-INTERVENORS' MOTION FOR STAY PENDING APPEAL CASE NO. 09-CV-2292 VRW 1 available to the public. Ex. 1 at 13. And it did so even though these recordings owed their very 2 existence to the Court's solemn assurance, in open court, that they would not be used for ―purposes 3 of public broadcasting or televising.‖ Ex. 7 at 754:21-23. Not only was this assurance necessary to 4 comply with Rule 77-3 and the policies of the Judicial Conference and this Court's Judicial 5 Council, but it came on the heels of an emergency Supreme Court decision specifically enforcing 6 Rule 77-3 after then-Chief Judge Walker had ordered the trial to be broadcast. The Court's decision thus goes beyond simply violating a binding rule, disregarding 7 8 longstanding judicial policies, and directly defying the Supreme Court's ruling in this very case 9 (though any of these errors would alone be fatal). Rather, by setting at naught the solemn 10 commitments made by a federal judge on which litigants and witnesses relied to their detriment, the 11 decision threatens deep and lasting harm to the integrity and credibility of the federal judiciary. As 12 explained more fully below, the ruling unsealing the video-recordings should be stayed pending 13 appeal. 14 STATEMENT OF FACTS 15 Two same-sex couples filed this suit claiming that Proposition 8, which provides that 16 ―[o]nly marriage between a man and a woman is valid or recognized in California,‖ Cal. Const. art. 17 I, § 7.5, violates the Federal Constitution. The case was assigned to the Honorable Vaughn R. 18 Walker, who at the time was Chief Judge of this Court. Correctly anticipating that the state officials 19 named as defendants would refuse to defend Proposition 8, the official proponents of the measure 20 and their official campaign committee (collectively ―Proponents‖) successfully moved to intervene. 21 As the case proceeded, Chief Judge Walker expressed a strong desire to publicly broadcast 22 the forthcoming trial, notwithstanding Proponents' repeated warning that several of their witnesses 23 would decline to testify. See, e.g., Ex. 26 at 7. On January 6, 2010, (five days before the start of 24 trial) he ordered that it be broadcast daily via the internet. Hollingsworth, 130 S. Ct. at 707; Ex. 8 at 25 16-17. Chief Judge Walker's determined effort to broadcast the trial, and the procedural 26 irregularities it occasioned, are recounted in detail in the Supreme Court's decision staying Chief 27 Judge Walker's order and prohibiting the public broadcast of the trial. See Hollingsworth, 130 S. 28 Ct. at 708-09, 711-12, 714-15. It suffices to repeat the Supreme Court's conclusion: ―The District 2 DEFENDANT-INTERVENORS' MOTION FOR STAY PENDING APPEAL CASE NO. 09-CV-2292 VRW 1 Court here attempted to revise its rules in haste, contrary to federal statutes and the policy of the 2 Judicial Conference of the United States,‖ solely ―to allow broadcasting of this high-profile trial 3 without any considered standards or guidelines in place.‖ Id. at 713; see also id. (Chief Judge 4 Walker's order ―complied neither with existing rules or policies nor the required procedures for 5 amending them‖). 6 Despite the Supreme Court's ruling, Chief Judge Walker insisted on video-recording the 7 trial over Proponents' objection. See Ex. 8 at 16:12-18; Ex. 9 at 1; Ex. 7 at 753:22-754:6. In 8 rejecting Proponents' objection, Chief Judge Walker stated that Rule 77-3 ―permits . . . recording 9 for purposes of use in chambers,‖ and that the recordings ―would be quite helpful to [him] in 10 preparing the findings of fact.‖ Id. at 754:15-19. He assured Proponents that ―that's the purpose for 11 which the recording is going to be made going forward. But it's not going to be for purposes of 12 public broadcasting or televising.‖ Id. at 754:21-23 (emphasis added). 13 On May 31, Chief Judge Walker sua sponte invited the parties ―to use portions of the trial 14 recording during closing arguments‖ and made ―a copy of the video . . . available to the part[ies].‖ 15 Ex. 11. The parties were instructed to ―maintain as strictly confidential any copy of the video 16 pursuant to paragraph 7.3 of the protective order,‖ id., which restricts ―highly confidential‖ material 17 to the parties' outside counsel and experts and to the district court and its personnel. Ex. 12 at 8. 18 Plaintiffs and Plaintiff-intervenor City and County of San Francisco requested and were given 19 copies of the recording of the trial proceedings, see Ex. 13, portions of which were played during 20 closing argument, see Ex. 14. Separately, Chief Judge Walker denied a request by a media coalition 21 to broadcast closing argument outside the courthouse. See Ex. 16. 22 Proponents moved for the return of all videos to the Court after closing argument, but Chief 23 Judge Walker denied the motion and ―DIRECTED‖ the Court Clerk to ―file the trial recording 24 under seal as part of the record‖ and allowed Plaintiffs (and San Francisco) to ―retain their copies 25 of the trial recording pursuant to the terms of the protective order.‖ Ex. 17 at 4. Elsewhere in the 26 same order, Chief Judge Walker stated that ―the potential for public broadcast‖ of the trial 27 proceedings ―had been eliminated.‖ Id. at 35-36. 28 Meanwhile, Proponents petitioned the Supreme Court for review and vacatur of the Ninth 3 DEFENDANT-INTERVENORS' MOTION FOR STAY PENDING APPEAL CASE NO. 09-CV-2292 VRW 1 Circuit's ruling, issued before the Supreme Court's stay, denying their mandamus petition seeking 2 to prohibit broadcast of the trial. Proponents argued that, in light of Chief Judge Walker's 3 ―unequivocal[] assur[ances] that [his] continued recording of the trial proceedings was not for the 4 purpose of public dissemination, but rather solely for [this] court's use in chambers,‖ the Ninth 5 Circuit's mandamus ruling should be vacated as moot. Ex. 18 at 11-13. The Supreme Court granted 6 the petition and vacated the Ninth Circuit's ruling. See Ex. 19. 7 Despite Rule 77-3, the policies of the Judicial Conference and the Ninth Circuit's Judicial 8 Council, the Supreme Court's prior decision in this case, the sealing order, and his own solemn 9 commitment in open court, on February 18, 2011, Chief Judge Walker began to broadcast portions 10 of the video recordings of the trial in connection with his teaching and public speaking. See Ex. 20 11 at 1-2. After learning of Chief Judge Walker's activities, Proponents promptly moved this Court to 12 order the return of all copies of the trial recordings. The Court denied this motion, Ex. 21 at 4, and 13 subsequently granted Plaintiffs' cross-motion to unseal the recordings, Ex. 1 at 13. At Proponents' 14 request, see Ex. 23 at 54:14-18, the Court granted a temporary stay of its ruling that will expire on 15 September 30, 2011, Ex. 1 at 14. 2 The Court did not, however, rule on Proponents' request for a 16 stay pending appeal. Ex. 23 at 54:14-18. Proponents noticed an appeal on September 22, 2011. 17 This Court retains jurisdiction to stay its own order while an appeal is pending. See In re 18 Padilla, 222 F.3d 1184, 1190 (9th Cir. 2000) (―[A] district court has jurisdiction to take actions that 19 preserve the status quo during the pendency of an appeal.‖). 20 21 22 ARGUMENT Four factors guide this Court's consideration of Proponents' emergency petition for a stay pending appeal: (1) Proponents' likelihood of success on the merits, (2) the possibility of 23 24 25 26 27 28 2 Former Chief Judge Walker voluntarily lodged his copy of the recordings with this Court pending resolution of Proponents' motion and Plaintiffs' cross-motion. See Ex. 22. In its order granting Plaintiffs' cross-motion to unseal, this Court ordered that Chief Judge Walker's tapes be returned to him and, ―in light of the Court's disposition of the Motion to Unseal,‖ denied ―as moot‖ Proponents ―request for an order directing Judge Walker to comply with the Protective Order sealing the recording of the trial.‖ Ex. 1 at 1314 & n.24. Given that its denial of this request appears to rest on its disposition of the motion to unseal, Proponents' understand that this portion of the Court's ruling is subject to the temporary stay and would be subject to any stay pending appeal, as well. 4 DEFENDANT-INTERVENORS' MOTION FOR STAY PENDING APPEAL CASE NO. 09-CV-2292 VRW 1 irreparable harm absent a stay; (3) the possibility of substantial injury to other parties if a stay is 2 issued; and (4) the public interest. See Golden Gate Rest. Ass'n v. San Francisco, 512 F.3d 1112, 3 1115 (9th Cir. 2008)). These factors all point to the same conclusion: This Court should ―suspend[] 4 judicial alteration of the status quo‖ by staying its unsealing order pending appeal. Nken v. Holder, 5 129 S. Ct. 1749, 1758 (2009). 6 I. Proponents' appeal is likely to succeed. 7 A. The unsealing order contravenes Rule 77-3, the policies of the Judicial 8 Conference and the Ninth Circuit Judicial Council, and the Supreme 9 Court's previous decision in this case. 10 As this Court implicitly recognized in grounding its ruling in the public's common law right 11 of access to judicial records, unsealing the video-recordings will intentionally and inevitably lead to 12 their public broadcast outside ― ‗the confines of the courthouse.' ‖ Hollingsworth, 130 S. Ct. at 711 13 (quoting Rule 77-3). The order unsealing the recordings thus is contrary to Rule 77-3, as well as the 14 longstanding policies of the Judicial Conference and the Ninth Circuit Judicial Council. It is also 15 contrary to the Supreme Court's prior ruling in this case. 16 17 18 19 20 21 22 1. Rule 77-3, which ―has the force of law,‖ Hollingsworth, 130 S. Ct. at 711, provides in relevant part as follows: Unless allowed by a Judge or a Magistrate Judge with respect to his or her own chambers or assigned courtroom for ceremonial purposes or for participation in a pilot or other project authorized by the Judicial Council of the Ninth Circuit or the Judicial Conference of the United States, the taking of photographs, public broadcasting or televising, or recording for those purposes in the courtroom or its environs, in connection with any judicial proceeding, is prohibited. Electronic transmittal of courtroom proceedings and presentation of evidence within the confines of the courthouse is permitted, if authorized by the Judge or Magistrate Judge. 23 24 25 26 27 28 Ex. 6. As the Supreme Court recognized, this rule prohibits not only ―public broadcasting or televising‖ of trial proceedings, but also ―recording for those purposes.‖ Id. at 710-11 (quoting Rule 77-3).3 Accordingly, Chief Judge Walker's decision to record the trial proceedings over 3 The version of Rule 77-3 in force at the time of the Supreme Court's decision in Hollingsworth did not contain an exception for public broadcast in connection with a pilot program (though the district court had attempted unlawfully to amend the rule to create (Continued) 5 DEFENDANT-INTERVENORS' MOTION FOR STAY PENDING APPEAL CASE NO. 09-CV-2292 VRW 1 Proponents' objection was lawful only on his representation that the recordings would not be 2 publicly broadcast beyond ―the confines of the courthouse.‖4 3 Furthermore, although the Court suggested that ―Rule 77-3 speaks only to the creation of 4 digital recordings of judicial proceedings for particular purposes or uses,‖ Ex. 1 at 10, the Rule's 5 separate prohibition against ―public broadcasting or televising‖ of trial proceedings outside ―the 6 confines of the court house,‖ Ex. 6, applies by its plain terms regardless of when the public 7 dissemination occurs. Indeed, the Rule's reference to ―recording for these purposes‖ can only be 8 understood as extending the prohibition against ―public broadcasting or televising‖ to subsequent 9 broadcasts of recorded proceedings. Accordingly, regardless of whether the act of recording a 10 particular trial itself is contrary to Rule 77-3, the subsequent public dissemination of trial recordings 11 clearly runs afoul of the distinct ―prohibit[ion against] the streaming of transmissions, or other 12 broadcasting or televising, beyond the ‗confines of the courthouse.' ‖ Hollingsworth, 130 S. Ct. at 13 711 (quoting Rule 77-3). Thus, contrary to the Court's suggestion that ―[n]othing in the language of 14 Rule 77-3 governs whether digital recordings may be placed into the record,‖ Ex. 1 at 10, Chief 15 Judge Walker's decision to place the trial recordings in the record would have violated this Rule but 16 for his order sealing the recordings and thereby preventing their public dissemination. And lifting 17 the seal to permit public broadcasting of the trial proceedings will likewise violate the Rule. Indeed, 18 any other reading of Rule 77-3 would render it a nullity, for it would give judges determined to 19 broadcast trial proceedings publicly a blueprint for doing so. That cannot be the law. 20 21 22 23 24 25 26 27 28 2. By permitting public broadcast of the trial in this case, the Court's order is also contrary (Cont'd) such an exception). See Hollingsworth, 130 S. Ct. at 712. As discussed below, the public broadcast of the trial proceedings in this case is plainly not authorized in connection with any pilot program. 4 Chief Judge Walker's decision to permit Plaintiffs to play portions of these videorecordings during closing arguments may have violated his assurance that the recordings would be ―simply for use in chambers,‖ Ex. 7 at 754:24-755:4. The closing arguments themselves were not publicly broadcast outside the courthouse, however, and parties were required ―to maintain as strictly confidential‖ their copies of the recordings ―pursuant to . . . the protective order.‖ Ex. 11 at 2. Accordingly, the use of the video-recordings in connection with closing arguments did not violate Rule 77-3's prohibition on public broadcast outside the confines of the courthouse. Nor did it violate Judge Walker's assurance, made with reference to this rule, that the recordings would not be used ―for purposes of public broadcast or televising.‖ Ex. 7 at 754:21-23. 6 DEFENDANT-INTERVENORS' MOTION FOR STAY PENDING APPEAL CASE NO. 09-CV-2292 VRW 1 to the express policy of the Judicial Conference, which is ―at the very least entitled to respectful 2 consideration,‖ Hollingsworth, 130 S. Ct. at 711-12, and of the Ninth Circuit's Judicial Council, 3 which is ―binding on all courts within the Ninth Circuit,‖ Ex. 5. This Court's disregard of these 4 policies is plainly a serious matter. See In re Complaint Against Dist. Judge Joe Billy McDade, No. 5 07-09-90083 (7th Cir. Sept. 28, 2009) (Easterbrook, C.J.); In re Sony BMG Music Entm't, 564 F.3d 6 1 (1st Cir. 2009). 7 Noting the Ninth Circuit's announcement, on December 17, 2009, of a pilot program ―to 8 allow the use of cameras in certain district court proceedings,‖ this Court suggested that ―at the time 9 the digital recording was made, it was the policy of the Ninth Circuit that the recording of civil non- 10 jury district court proceedings was permissible.‖ Ex. 1 at 11-12. The Judicial Council, however, is 11 authorized to make or amend ―[a]ny general order relating to practice and procedure . . . only after 12 giving appropriate public notice and an opportunity for comment,‖ 28 U.S.C. § 332(d)(1), and, as 13 the Supreme Court pointed out, the December 2009 program ―was not adopted after notice and 14 comment procedures,‖ Hollingsworth, 130 S. Ct. at 712 (citing 28 U.S.C. § 332(d)(1)). Further, this 15 case was formally withdrawn from the purported pilot program promptly after the Supreme Court's 16 decision in this case. See Ex. 10; Ex. 24.5 17 3. This court's decision to unseal its recordings is also contrary to the Supreme Court's 18 prior ruling in this case. While the Supreme Court did hold that this Court's attempt to amend Rule 19 77-3 was procedurally invalid, see Ex. 1 at 9, it also held that the Court's broadcast order violated 20 the substance of that Rule (as well as Judicial Conference policy). See, e.g., Hollingsworth, 130 S. 21 Ct. at 713 (holding that Chief Judge Walker's broadcast order ―complied neither with existing rules 22 or policies nor the required procedures for amending them‖ (emphasis added)). Further, as 23 discussed more fully below, the Supreme Court credited Proponents' witnesses' well-substantiated 24 fears of harassment and intimidation, see id. at 713-14, and accordingly made clear that even if the 25 26 27 28 5 Although the Judicial Conference recently adopted a pilot program permitting, in certain narrow circumstances, the broadcast of civil trial proceedings, see Ex. 1 at 11 n.20, it likewise provides no support for public broadcast given that (1) it did not exist at the time of the trial in this case, and (2) participation in the new program requires the consent of all parties, Ex. 25 at 11. 7 DEFENDANT-INTERVENORS' MOTION FOR STAY PENDING APPEAL CASE NO. 09-CV-2292 VRW 1 Ninth Circuit's Judicial Council had successfully implemented a pilot program allowing public 2 broadcast of trial proceedings, and even if Rule 77-3 had been successfully amended to permit 3 participation in that program, this ―high-profile, divisive‖ case, ―involv[ing] issues subject to 4 intense debate in our society,‖ was ―not a good one for a pilot program.‖ Hollingsworth, 130 S. Ct. 5 at 714. 6 7 B. The common law right of access to judicial records does not support the district court's ruling. 8 This Court rested its ruling solely on the common-law right ―to inspect and copy public 9 records and documents, including judicial records and documents.‖ Ex. 1 at 6. As demonstrated 10 below, however, this common-law right has no application to the video recordings at issue here. 11 Even if it did apply, moreover, this qualified right would not support public access in this case, for 12 the harms that would result from public broadcast far outweigh any potential benefits. 13 1. The common-law right of access is just that—a judge-made, common-law rule. It ―is not 14 absolute, and is not entitled to the same level of protection accorded a constitutional right.‖ San 15 Jose Mercury News, Inc., v. U.S. Dist. Ct. for the N.D. Cal., 187 F.3d 1096, 1102 (9th Cir. 1999). 16 Like every common-law rule, it may be displaced by statute or other positive enactment. See Ctr. 17 for Nat'l Sec. Studies v. U.S. DOJ, 331 F.3d 918, 937 (D.C. Cir. 2003); see generally Heck v. 18 Humphrey, 512 U.S. 477, 501 (1994). For example, the common-law right of access is supplanted 19 by Fed. R. Crim. P. 6(e), governing recording and disclosure of grand jury proceedings. See U.S. v. 20 McDougal, 559 F.3d 837, 840 (8th Cir. 2009); In re Motions of Dow Jones & Co., 142 F.3d 496, 21 504 (D.C. Cir. 1998). It is likewise displaced by Fed. R. Civ. P. 5.2, which does not permit 22 documents containing minors' to be unsealed unless those names are redacted. See Rule 5.2(d). In 23 short, where they are applicable, ―[r]ules, not the common law, now govern.‖ In re Motions of Dow 24 Jones & Co., 142 F.3d at 504. 25 As demonstrated above, Rule 77-3 would have prohibited the creation of the video- 26 recordings at issue here but for Chief Judge Walker's unequivocal representation that they would 27 not be publicly broadcast outside the courthouse. The Rule likewise would have barred the 28 placement of these recordings in the record but for Chief Judge Walker's sealing order. The Court's 8 DEFENDANT-INTERVENORS' MOTION FOR STAY PENDING APPEAL CASE NO. 09-CV-2292 VRW 1 decision allowing the common-law right of access to trump a binding rule of the Court, see Ex. 1 at 2 10, is contrary to the well-established relationship between common-law and positive enactments. 3 2. In addition, the video recordings at issue here are simply not the type of judicial record 4 to which the common-law right of access applies. As even Plaintiffs have conceded, see Ex. 23 at 5 12-13, the recordings are not themselves evidence or even argument; rather they are wholly 6 derivative of the evidence offered, and the arguments made, in open court during the trial in this 7 case. Further, the court reporter's transcript, not the video recordings, is the official record of the 8 trial proceedings.6 And as the Plaintiffs likewise conceded, the public was free to attend the trial in 9 this case and continues to have access to the official trial transcript, which is ―widely available on 10 the internet.‖ See Plaintiffs-Appellees' Opposition to Appellants' Motion Regarding Trial 11 Recordings and Plaintiffs-Appellees' Motion to Unseal at 3, Perry v. Brown, No. 10-16696 (9th Cir. 12 Apr. 15, 2011). None of the authorities cited by this Court or the parties hold—or even suggest— 13 that the common-law right of access requires more. 14 Indeed, in U.S. v. McDougal, 103 F.3d 651, 656-57 (8th Cir. 1996), the Eighth Circuit held 15 that a videotape of President Clinton's deposition testimony (which was played in court in lieu of 16 live testimony) was ―not a judicial record to which the common-law right of public access 17 attaches.‖ As the Court explained, ―the videotape at issue … is merely an electronic recording of 18 witness testimony. Although the public had a right to hear and observe the testimony at the time and 19 in the manner it was delivered to the jury in the courtroom . . . there was, and is, no additional 20 common law right to obtain, for purposes of copying, the electronic recording of that testimony.‖ 21 Id.; see also id. (distinguishing recordings of ―the primary conduct of witnesses or parties‖); cf. In 22 re Sony BMG Music Entm't, 564 F.3d 1, 8-9 (1st Cir. 2009) (―the venerable right of members of the 23 public to attend federal court proceedings is far removed from an imagined entitlement to view 24 court proceedings remotely on a computer screen‖). In this case the video recordings are one step 25 even further removed than in McDougal from the type of record to which the common-law right of 26 27 28 6 Cf. Ex. 35 (―digital recordings emanating from the pilot [project] . . . are not the official record of the proceedings, and should not be used as exhibits or part of any court filing.‖); supra n.4. 9 DEFENDANT-INTERVENORS' MOTION FOR STAY PENDING APPEAL CASE NO. 09-CV-2292 VRW 1 access applies, for (with the exception of a few brief snippets played during closing arguments), the 2 recordings simply depict the trial proceedings and were not themselves played at trial. 3 3. Even where the common-law right of access does apply, it ―does not mandate disclosure 4 in all cases.‖ San Jose Mercury News, Inc., 187 F.3d at 1102. It merely creates a presumption in 5 favor of access that ―can be overcome by sufficiently important countervailing interests.‖ Id. Here, 6 as recognized by the Supreme Court, public broadcast of the trial proceedings would subject 7 Proponents' witnesses to a well-substantiated risk of harassment and would prejudice any further 8 trial proceedings that may prove necessary in this case. See Hollingsworth, 130 S. Ct. at 713. In 9 addition, public broadcast of the trial in violation of Chief Judge Walker's solemn assurances (and 10 contrary to the Supreme Court's stay, the local rules, and well-settled judicial policy) threatens 11 grave damage to the integrity of the judicial process itself. These threatened injuries are discussed 12 more fully below. Further, this is not a case where the public seeks access to evidence or 13 proceedings hidden from public view: the trial in this case was open to the public, widely reported, 14 and memorialized in an official public transcript. Thus, balanced against the serious risks to 15 Proponents, their witnesses, and the integrity of the judicial process posed by the public broadcast 16 of the video-recording, any applicable common-law right of access must surely yield. 17 18 19 II. Proponents will suffer irreparable harm absent a stay. A. Unsealing the record now will moot Proponents' appeal. Absent a stay pending appeal, the video-recording of the trial will be unsealed and its 20 widespread dissemination will be immediate. Once that happens, Proponents' appeal will be moot. 21 They will ―not be able to obtain adequate relief through an appeal,‖ for ―[t]he trial will have already 22 been broadcast.‖ Hollingsworth, 130 S. Ct. at 713. Mootness is by definition an irreparable harm to 23 a party seeking appellate review. See Artukovic v. Rison, 784 F.2d 1354, 1356 (9th Cir. 1986). This 24 Court should issue a stay pending appeal to preserve Proponents' ability to seek effective appellate 25 review of the unsealing order. 26 27 28 B. Unsealing the record will lead to harassment of Proponents' witnesses. Based on ―decades of experience and study,‖ the Judicial Conference has repeatedly found that the public broadcast of trial proceedings ―can intimidate litigants [and] witnesses,‖ ―create 10 DEFENDANT-INTERVENORS' MOTION FOR STAY PENDING APPEAL CASE NO. 09-CV-2292 VRW 1 privacy concerns,‖ and ―increase[] security and safety issues.‖ E.g., Ex. 3 at 1 -3; see also 2 Hollingsworth, 130 S. Ct. at 712-13. ―Threats against judges, lawyers, and other participants could 3 increases even beyond the current disturbing level.‖ Ex. 3 at 3. Significantly, these findings are 4 based on the Judicial Conference's study of ordinary, run-of-the-mine cases. ―[I]n ‗truly high- 5 profile cases' one can ‗[j]ust imagine what the findings would be.' ‖ Hollingsworth, 130 S. Ct. at 6 714. 7 As Proponents repeatedly advised Chief Judge Walker before the trial in this ―high-profile, 8 divisive‖ case, id., several of Proponents' expert witnesses voiced ―concerns for their own 9 security,‖ id. at 714, and made clear ―that they [would] not testify if the trial [were] broadcast,‖ id. 10 at 713. Chief Judge Walker appeared indifferent to this fact and to its obvious implications for the 11 fundamental fairness of the trial itself, for he never even mentioned this consideration as bearing on 12 his decision to broadcast—and when that was stayed, to video-record—the trial.7 The Supreme 13 Court however, was acutely concerned that Proponents' witnesses had ―substantiated their concerns 14 by citing incidents of past harassment.‖ Id. at 713. Indeed, the record reflects repeated harassment 15 of Prop 8 supporters. See Ex. 27; Ex. 28 at ¶¶ 10-12; Ex. 29 at ¶¶ 6-8, 12-15; Ex. 30 ; Ex. 31at ¶¶ 5- 16 6; Ex. 32 at ¶ 8; see also Thomas M. Messner, The Price of Prop 8, available at www.heritage.org/ 17 Research/Family/bg2328.cfm; www.youtube.com/watch?v=hcKJEHrvwDI. For example, ―donors 18 to groups supporting Proposition 8 ‗have received death threats and envelopes containing a 19 powdery white substance,' ‖ and ―numerous instances of vandalism and physical violence have 20 been reported against those who have been identified as Proposition 8 supporters.‖ Hollingsworth, 21 130 S. Ct. at 707. Even Plaintiffs' lead counsel has acknowledged ―widespread economic reprisals‖ 22 against supporters of Proposition 8. Ex. 36 at 28-29 (cited in Hollingsworth, 130 S. Ct. at 707). 23 There can thus be little doubt that unsealing the trial recording for public broadcast would expose 24 Proponents' witnesses to a serious and well-substantiated risk of harassment or worse. 25 26 27 28 7 Despite Chief Judge Walker's subsequent assurance that the video-recordings would not be publicly broadcast, all but two of Proponents' experts ultimately did not testify. As counsel for Proponents advised Chief Judge Walker early in the trial, the witnesses ―were extremely concerned about their personal safety, and did not want to appear with any recording of any sort, whatsoever.‖ Ex. 33 at 1094:18-23; see Ex. 26 at 7. 11 DEFENDANT-INTERVENORS' MOTION FOR STAY PENDING APPEAL CASE NO. 09-CV-2292 VRW 1 2 C. Unsealing the record could prejudice future trial proceedings. Given that Proponents are currently appealing both the judgment invalidating Proposition 8 3 and the subsequent denial of our motion to vacate that judgment, it is likely that this case will be 4 retried in the future. As noted above, supra note 7, only two of Proponents' six scheduled expert 5 witnesses were willing to rely on Chief Judge Walker's unequivocal assurances that the trial 6 recordings were solely for his judicial use in chambers, and to testify at trial. One of those witnesses 7 soon regretted his decision to take Chief Judge Walker at his word, as he watched excerpts of his 8 testimony displayed on national television by Chief Judge Walker himself. See Judge Walker on 9 Cameras in the Courtroom, C-SPAN, http://www.c-spanvideo.org/program/298109-3. If the video- 10 recording of the trial is now unsealed and made public, these witnesses and others would almost 11 certainly refuse to participate in any further trial proceedings in this case, or in any other case 12 raising such highly divisive issues. See Hollingsworth, 130 S. Ct. at 713 (―[W]itnesses subject to 13 harassment as a result of broadcast of their testimony might be less likely to cooperate in any future 14 proceedings.‖) Unsealing the recordings would thus surely prejudice any future trial proceedings 15 and thus cause ―irreparable harm.‖ Id. at 712. 16 III. A stay will not subject Plaintiffs to substantial harm. 17 Here, as before, ―[t]he balance of equities favors‖ a stay, for ―[w]hile applicants have 18 demonstrated the threat of harm they face if the trial is broadcast, [Plaintiffs] have not alleged any 19 harm if the trial is not broadcast.‖ Hollingsworth, 130 S. Ct. at 713. And they certainly have 20 identified no harm that they will suffer during the pendency of this appeal if a stay is entered. 21 IV. The public interest is served by staying the district court's order. 22 As the Court recognized, see Ex. 23 at 24-25, nothing less than the integrity and reputation 23 of the judiciary is at stake in this case. Chief Judge Walker solemnly and unambiguously 24 represented in open court that the recording of the trial would not be used ―for purposes of public 25 broadcasting or televising.‖ Ex. 7 at 754:21-23. He assured the parties that only ―some further order 26 of the Supreme Court or the Court of Appeals‖ could permit transmission beyond the courthouse. 27 Ex. 34. Proponents took him at his word (as did their witnesses who took the stand) and thus took 28 no action to enforce the Supreme Court's stay or otherwise prevent the recording of the trial. 12 DEFENDANT-INTERVENORS' MOTION FOR STAY PENDING APPEAL CASE NO. 09-CV-2292 VRW 1 Indeed, in express reliance on Chief Judge Walker's promise, see Ex. 18 at 11-12, Proponents 2 forwent their opportunity, invited by the Supreme Court itself, to seek further review from that 3 Court of Chief Judge Walker's broadcast order. And in deciding not to appeal the subsequent order 4 placing the recording in the record under seal, Proponents relied on Chief Judge Walker's 5 unequivocal determination—made in the very same opinion placing the recording in the record— 6 that ―the potential for public broadcast‖ of witness testimony ―had been eliminated,‖ Ex. 17 at 35- 7 36. Despite all of this, Chief Judge Walker himself later reneged on his commitment, violated his 8 seal, and ignored Local Rule 77-3 and judicial conference policy by broadcasting excerpts of the 9 trial recording. 10 Although the Court has suggested that it is not bound by the former presiding judge's 11 commitments, its ruling may persuade future litigants and witnesses that judicial promises are 12 unworthy of confidence, and cause grave and lasting injury to the integrity and credibility of the 13 federal judiciary. 14 As discussed above, any countervailing public interest in access to the video-recording of 15 the public trial in this case is small. And any public interest in immediate, pre-appeal access is 16 surely negligible. The public interest, like the other equities, thus weighs heavily in favor of a stay. 17 CONCLUSION 18 For the foregoing reasons, this Court should stay its unsealing order pending appeal. 19 20 21 22 23 Dated: September 23, 2011 COOPER AND KIRK, PLLC ATTORNEYS FOR DEFENDANT-INTERVENORS DENNIS HOLLINGSWORTH, GAIL J. KNIGHT, MARTIN F. GUTIERREZ, MARK A. JANSSON, AND PROTECTMARRIAGE.COM – YES ON 8, A PROJECT OF CALIFORNIA RENEWAL 24 By: 25 /s/Charles J. Cooper Charles J. Cooper 26 27 28 13 DEFENDANT-INTERVENORS' MOTION FOR STAY PENDING APPEAL CASE NO. 09-CV-2292 VRW


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Mandarin Oriental Manila 1 Hotel, Makati City
Reviews - Mandarin Oriental Manila 1 Hotel
Read 307 additional reviews of Mandarin Oriental Manila 1 Hotel at TripAdvisor.
Want to see more hotels? View all hotels in Makati City
Historical Traveller Reviews of Mandarin Oriental Manila 1 Hotel
Ok but in no rush backfrom aoife_37
Loved the restaurants - service and food were fantastic in all. Paseo Uno's buffets are truly extensive for both breakfast and dinner. The Spa was really good value compared to European rates. Oriental indulgence package. was wonderful. SPorts favilities are good - gym, decent pool for laps, even yoga classes.
Fresh mango in room every day
Free internet service for long stay
Manila's humidity and pollutions means that you'd be better off at the hotels which are near/in Glorietta and Greenbelt shopping areas. Hotel taxis are 200 pesos to them, Street taxis are 100pesos.
Rooms are tired and not particularly exciting. The first room I had had a lot of details that required fixing. ( lights etc )
Concierge desk slow to get back on enquiries and really have to be hassled to get a response out of them.
Quality, Safe, 5 star choice hotelfrom pacifichub
My husband and I, 13 year daughter and 13th month baby.
Stayed in a Superior room. You could go with a deluxe, but you might pay more, I asked house keeping if rooms were bigger - they said no only furnishings.
Restaurants are all of high quality, room size is standard on the larger side, bathroom is large. We paid extra for the extra bed for our daughter. Staff was all great. Pool was also very nice, large, had towels, staff and well layed out. Hotel only had 1 shop. The shopping malls were a block away. A stretch for a hot day. The hotel had beauty salan with Swarshoff (sp) germany hair products. A little pricy, but well worth it - to treat yourself - to a clean sanitized hair salon. The business center is real nice, 26 peso a minute, or $10 an hour. Advice if you bring your computer/laptop its $20 a day to use in your room - overall its costly. Business Center is well layed out too, drinks are complimentary. $1.00 per printed page and they have a mini -conference room.
We booked thru Philippine Airlines local office on Guam and buffet breakfast was included at the Paseo Uno - great spread, egg station with samon, asian soup station, fresh breads, waffle/pancake station, carving station. A full spread, salads, fruits, hot foods, and breakfast dishes. Staff was all very nice, one of the chefs, even got me samon - since they didnt have it on one of the breakfast days - since they new I enjoyed it - even though our package included breakfast - I couldnt resist not tipping these workers.
Hotel taxis were 200-500 peso after we did that a couple of times, conceirge didnt mind calling us metered taxis. Every time we took a taxi and arrived back at the hotel staff allways was there to assist us with our packages, stroller, open our door, I wish I had my pesos more accessible to tip all the wonderful staff. Check out was stressful, our minibar was not inventoried and I insisting on paying what we consumed for fear of later charges to my credit card. This is one area hotel should have more control over so hotel patrons dont take advantage. The do have non-smoking floors. Everything very clean - didnt see any soil or wear and tear in the rooms. Dinning in the room, could be costly - a hamber cost $9 US - but it was huge enough for two people. Raw oysters where $1 US each - best deal I've ever seen. Dinner came with free hot dinner rolls. A full spread of linen and dinning ware - first class dining in room service.
We ask for a disposible razor, got it, iron w/board, got it. I didnt want to spend big bucks in the spa for a massage that would have cost close to $100 - so I spoke with the conceige they had a lady come to our room, I paid $5 for 1 hour massage, and another $5 for a 45 minute facial massage, my daughter also received a facial for $5. Conceirge was always helpful in giving me makiti maps and maps of manila. They were also the one to assist us in upgrading our vehicle to the airport. Which was $20.00. We would definitely stay here again.
Excellent hotel, excellent servicefrom Yank-In-Sing
Pool was also quite well cared for and very large, a nice oasis in the middle of Manila. Great for swimming laps, and when I came out of the pool I was pleasantly surprised to see a staff member had put out a glass of ice water for me.
The room itself was not the largest I've ever stayed in, but exceedingly comfortable with a big marble bathroom, mini-bar, and safe. I'm not sure why a previous reviewer called the rooms "tired," they seemed to be in very good shape to me.
The hotel is walking distance from Glorietta Mall, and even as a female walking alone I felt safe. The hotel taxis are pricey (for Manila), if you catch one on the street they are much cheaper.
Perfect!from cheers69
Good but a little tiredfrom DCRatcliff
Best place to stay in Manilafrom KTee:P
The rooms are a little dated now - but the beds are incredibly comfortable, the food is excellent, the spa is great, the location is perfect, the service is far and above the best I have ever experienced.
I wouldn't stay anywhere else in Manila - and in most of Asia's main cities I would stay in the Shangri-la.
pros and cons of MOfrom JackBarr
However, like most 4* and above Filipino hotels the service is great and at breakfasts you are spoiled for choice. The Chinese restaurant is tremendous value and the Cigar Lounge is terrific for whisky and a Perdomo.
Value for money -yes, if you get a good rate of US$80-100.
Excellent valuefrom Gulf-Neil
You can get a room here for about US$100 & its well worth the money. The staff are excellent, rooms clean & tidy, facilities good quality. You can stay here at what i think is a reasonalble price without the usual worries of if the rooms will be ready, if the carpet will be clean, if the bed will smell etc, etc.
The breakfast, pool & spa are superb.
Its true that that restaurants & other paid services are a little expensive compared to lower class hotels.
The hotel is right next to several banks & is a 10 minutes walk to a huge, high class, shopping mall.
I'm not suprised its tripadvisors #1 hotel in Manila. Overall, I think this is a great choice of hotel & reasonably priced.
Just the bestfrom FreqFly
I stayed at the mandarin oriental for ten days and I could not fault it.
Every staff member from the Concierge down could not do enough for you.
The Hotel not only provided an embarkation card on departure but pre-filled the details provided at check in. They even taped sporting events while I was at work. And best of all most staff used my name when addressing me.
A great place to stay!
Nice but elements of Fawlty Towersfrom GeoffM
As this is an expensive hotel to stay at, note that everything extra is expensive too. Add 1/3 of the price quoted to get the final tax-plus-service-charge-inclusive total. Walk to the street to hail a 75 peso taxi instead of the 500 peso "official" taxis.
On the flip side, the staff kept phoning to check that the bags had arrived, and the minibar restocked. Breakfast was good - varied and plentiful. Room facilities were good with a large room and comfortable beds.
Top Local Tips for Makati City
Shop safely Shop only at malls and major shopping areas and always be safe and conscience of your surroundings.
How the Makati triangle came about! Makati City, the commercial and business centre, is built on the site of a Japanese airfield which was constructed by them during WW2 on drained paddy fields, south what was then the main city. There were three runways, intersecting in an equilateral triangle, at the centre of which was the control tower. After the war a prominent Philippino family appears to have bought bought the defunct airfield, complete with runways and tower, and started laying it out as a new city development. The runways became the main avenues, and remain so today, the control tower and associated buildings were retained and are now a library and art gallery, and the triangular area within the three ex-runways is now a municipal park. The area is now studded with towering office blocks and hotels. This must be one of the most inspired real-estate deals in history!
acessability Very close to shopping and business areas
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Other names for Mandarin Oriental Manila 1 Hotel
- mandarin oriental makati
- mandarin oriental hotel manila
- mandarin makati
- mandarin hotel manila
- mandarin hotel makati
- makati mandarin oriental
- makati mandarin
- Address: Makati Ave - Makati City - 1226 - Philippines
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Hotels Near Mandarin Oriental Manila 1 Hotel
- Fraser Place Serviced Residences Forbes Tower Hotel Manila, Philippines Distance: 0.2 km / 0.1 mi
- The Peninsula Manila Hotel Makati City, Philippines Distance: 0.6 km / 0.4 mi
- Oxford Suites Makati Hotel Makati City, Philippines Distance: 0.6 km / 0.4 mi
- Citadel Inn Makati Hotel Makati City, Philippines Distance: 0.6 km / 0.4 mi
- Best Western Astor Hotel Makati Makati City, Philippines Distance: 0.7 km / 0.4 mi
- Ascott Makati Hotel Makati City, Philippines Distance: 0.9 km / 0.6 mi
- InterContinental Hotel Makati City, Philippines Distance: 1 km / 0.6 mi
- Best Western Hotel La Corona Manila, Philippines Distance: 5.5 km / 3.4 mi
- Century Park Hotel Manila, Philippines Distance: 3.9 km / 2.4 mi
- Heritage Hotel Manila Manila, Philippines Distance: 4.4 km / 2.7 mi
- The Linden Suites Hotel Pasig, Philippines Distance: 4.3 km / 2.7 mi
- Lotus Garden Hotel Manila Manila, Philippines Distance: 5.4 km / 3.3 mi
- Holiday Inn Galleria Hotel Manila, Philippines Distance: 4.9 km / 3 mi
- Manila Diamond Hotel Manila, Philippines Distance: 5.1 km / 3.1 mi


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Baring Asset Management has appointed Faisal Ali as an investment manager on the emerging markets debt division.
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Ali has previously worked for Observatory Capital as a portfolio manager in the emerging markets team.
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With three men coming forward accusing Bernie Fine of sexual abuse, victim advocates say it may prompt others not associated with the case to come forward with their own stories of abuse. Our Iris St. Meran spoke with the people who take those calls about the challenge of reporting abuse.
SYRACUSE, N.Y. -- Overcoming the fear of admitting you've been abused is hard for most people, but can be even harder for male victims.
"Because they have the socialization that they're supposed to be strong, supposed to be tough, supposed to be hard. It becomes a challenge for them whenever they're victimized," said Vera House Men's Outreach Coordinator Chauncey Brown.
In the past 10 days, three men have come forward accusing the now former SU associate basketball coach Bernie Fine of sexual abuse. The Vera House Executive Director says these developments could prompt others, even those outside of this case, to come forward.
Vera House Executive Director Randi Bregman said, "The more people hear these stories and realize the truth behind them, the more comfortable they are sharing their story. But when they hear either publicly or privately that people don't believe them, blame them, doubt them, of course that keeps people from coming forward."
Bregman says since this broke, Vera House has had some calls, but not an influx. Things could change she says based on how this story continues to unfold.
In order for others to feel like they can come forward there needs to be a "safe" environment, Bregman says that environment begins at home and parents should have a conversation, albeit difficult, about abuse.
"Everybody's comfortable teaching kids, if a stranger approaches you, here's all the things you should know and do. Stranger danger," Bregman said. "But we have to get comfortable having conversations about the people that children know and trust sometimes aren't trustworthy."
Brown says more men, who he calls bystanders, need to come forward and report any abuse they observe.
"A lot of times you'll think well, 'someone else is handling it, someone else is seeing it,' but if everybody thinks that way nothing ever gets done," said Brown.
The Vera House says one in three girls and one in six boys are abused. They have a 24 hour crisis and abuse line if anyone has questions or concerns that number is (315) 468-3260.
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