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I am Of Counsel with the law firm of Dorsey & Whitney LLP, counsel to Plaintiff
Sexual Minorities Uganda (Plaintiff) in the above-captioned case and submit this declaration in
support of Plaintiffs Motion for Issuance of a Subpoena Pursuant to 28 U.S.C. 1783(a) (the
Motion). I make this declaration upon personal knowledge, except where indicated.
2.
The Motion seeks an order from the Court issuing a subpoena for the deposition
of Martin Ssempa and for the production of documents from Mr. Ssempa, a key witness in this
action who is currently located in Uganda.
3.
A true and correct copy of Mr. Ssempas Nevada voter registration application,
the telephone. I had no success reaching Mr. Ssempa until January 6, 2015. On that day, I spoke
with Mr. Ssempa briefly by telephone and explained that I represented Plaintiff in the above-
captioned action and mentioned that I wanted to speak regarding the possibility of deposing him.
Mr. Ssempa stated that he was not available to speak at that time, but that I could contact him
again.
5.
On March 20, 2015, I sent a letter to Mr. Ssempa via email (the March 20
Letter). A true and correct copy of the March 20 Letter is attached hereto as Exhibit B.
7.
Ssempas appearing voluntarily for a deposition in New York or in another location in the United
States. I also stated that Plaintiff would cover Mr. Ssempas travel expenses in full if he came to
the United States to be deposed. I further raised the possibility of deposing Mr. Ssempa in a
location outside the United States that would be more convenient to him if he were in Uganda.
8.
9.
Counsel for Defendant Scott Lively has informed me that he will not take any
steps to attempt and arrange for Mr. Ssempa to appear voluntarily for a deposition. A true and
correct copy of my correspondence with counsel is attached hereto as Exhibit C.
10.
On March 27, 2015, Plaintiff attempted to serve a subpoena duces tecum and
subpoena ad testificandum (the Ssempa Subpoenas) on Mr. Ssempa personally at the Nevada
address listed on Exhibit A hereto, i.e., his voter registration application. The individual serving
the Ssempa Subpoenas spoke with a man who stated that he was Mr. Ssempas father-in-law.
That individual stated further that Mr. Ssempa was in Uganda and that he did not know when or
if Mr. Ssempa planned to return to the United States. A true and correct copy of the Affidavit of
Attempted Service of the Ssempa Subpoenas is attached hereto as Exhibit D.
I declare under the penalty of perjury that the foregoing is true and correct.
Executed on April 9, 2015 at New York, New York.
Exhibit A
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JUL 1 1 2m2
KA61 023
FEDERAL LAW REQUIRES CLARK COUNTY TO PROVIDE ELEC"nON MATERIALS IN THREE LANGUAGES
CHECK the language in which you want your election materials printed by checking a box below:
o ENGLISH
FILIPINO (TAGALOG)
SPANISH
Mailing Address-If different from above. (Post Office Box or Mail Service Address)
~~~\
Dv("\rhee
8
o Democratic Party
o Republican PaTty
Ubertarian Party
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12
CORRECT COP'(
City
State
S'i!l!
Zip Code
NV Driver's License or NV ID Card Number (If neither, last 4 digits of your SSN)
TRUE
State
LAS'V-6tt1 J\N
V (Stz1 frJe
tJ~OA10
City
Zip Code
6 _f,';Z~
9
_
11
"I swear or affirm. I am a U.S. citizen. I will be at least 18 years old by the date of
the next election. I will have continuously resided in Nevada at Jeast 30 days in my
county and at least 10 days in my precinct before the next election The present
address listed herein is my sole legal place of residence and I daim no other place
as my legal residence. I am not laboring under any felony conviction or other loss
of civil rights that would make it unlawful for me to vote. I declare under penalty of
pe~ury that the foregoing is true and correct."
~~
..
.DATE REQUIRED.
D.l!0, tf2.
to vote.
(Name Used, Street, Apt. II, City, Slate & Zip Code of Former Residence)
Exhibit B
Exhibit C
Exhibit D