Case3:10-cv-00257-JSW Document107 Filed05/09/11 Page1 of 2

1 JAMES R. McGUIRE (CA SBN 189275)

JMcGuire@mofo.com
2 GREGORY P. DRESSER (CA SBN 136532)
GDresser@mofo.com
3 RITA F. LIN (CA SBN 236220)
RLin@mofo.com
4 AARON D. JONES (CA SBN 248246)
AJones@mofo.com
5 MORRISON & FOERSTER LLP
425 Market Street
6 San Francisco, California 94105-2482
Telephone: 415.268.7000
7 Facsimile: 415.268.7522
8 JON W. DAVIDSON (CA SBN 89301)
JDavidson@lambdalegal.org
9 TARA L. BORELLI (CA SBN 216961)
TBorelli@lambdalegal.org
10 LAMBDA LEGAL DEFENSE AND EDUCATION FUND, INC.
3325 Wilshire Boulevard, Suite 1300
11 Los Angeles, California 90010-1729
Telephone: 213.382.7600
12 Facsimile: 213.351.6050
13 Attorneys for Plaintiff
KAREN GOLINSKI
14

15 UNITED STATES DISTRICT COURT

16 NORTHERN DISTRICT OF CALIFORNIA

17 SAN FRANCISCO DIVISION

18

19 KAREN GOLINSKI, Case No. 3:10-cv-0257-JSW

20 Plaintiff, DECLARATION OF JAMES R.
McGUIRE IN SUPPORT OF
21 v. PLAINTIFF KAREN GOLINSKI’S
OPPOSITION TO DEFENDANTS’
22 UNITED STATES OFFICE OF PERSONNEL MOTION TO ENLARGE TIME TO
MANAGEMENT, and JOHN BERRY, Director RESPOND PLAINTIFF’S SECOND
23 of the United States Office of Personnel AMENDED COMPLAINT
Management, in his official capacity,
24
Defendants.
25

26

27

28

McGUIRE DEC ISO OPP TO DEFS’ MTN FOR ENLARGEMENT OF TIME TO RSP TO SAC
CASE NO. 3:10-cv-0257-JSW
sf-2991366
 Case3:10-cv-00257-JSW Document107 Filed05/09/11 Page2 of 2

1 I, JAMES R. McGUIRE, hereby declare and state as follows:

2 1. I am a partner of the law firm of Morrison & Foerster LLP, which is co-counsel of
3 record for plaintiff Karen Golinski. I am licensed to practice law in the State of California and
4 am admitted to practice before this Court. I make this declaration of my own personal
5 knowledge, and, if called as a witness, could and would testify competently to the matters stated
6 herein.
7 2. On May 2, 2011, Chris Hall of the Department of Justice called me to discuss
8 further the extension of time he had been negotiating with Rita Lin (who was now on vacation).
9 During that call, Mr.Hall reiterated in very general terms the reasons that BLAG “needed”
10 additional time to respond to the complaint and asked if Ms. Golinski would reconsider the
11 request for a lengthy extension. I responded that we had already considered the various issues he
12 described, and that we continued to believe that the additional 30-days beyond the 20 already
13 provided by the Court were sufficient. At the close of our call, Mr. Hall asked if our client would
14 consider providing an additional 45 days. Mr. Hall stated the he did not know if BLAG would
15 “agree” to accept 45 days. I agreed to see if Ms. Golinski would consent to 45 days.
16 3. On May 3, 2011, Mr. Hall and I exchanged e-mails regarding his request for a 45-
17 day extension. Those e-mails are attached hereto as Exhibits A and B.
18 4. Also on May 3, 2011, I exchanged a series of e-mails with Kerry Kircher, General
19 Counsel, Office of the General Counsel, U.S. House of Representatives regarding both BLAG’s
20 motion to intervene and the timeline during which it would file a motion to dismiss. Mr. Kircher
21 ultimately rejected Ms. Golinski’s offer of an additional 30 days to respond because of “all the
22 other DOMA balls we’re juggling at the moment.” These e-mails are attached hereto as
23 Exhibits C-F.
24 I declare under penalty of perjury under the laws of the United States of America that the
25 foregoing is true and correct.
26 Executed this 9th day of May, 2011, at San Francisco, California.
27
/s/ James R. McGuire
28 JAMES R. McGUIRE
McGUIRE DEC ISO OPP TO DEFS’ MTN FOR ENLARGEMENT OF TIME TO RSP TO SAC 1
CASE NO. 3:10-cv-0257-JSW
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