Michael Newdow, pro hac vice 

PO Box 233345 

Sacramento, CA 95823 

(916) 427-6669 

Rosanna Fox, NH SBN: 17693 

O’Brien Law Firm P.C. 

One Sundial Avenue, Fifth Floor 

Manchester, NH 03103 

(603) 627-3800 

IN THE UNITED STATES DISTRICT COURT 

FOR THE DISTRICT OF NEW HAMPSHIRE 

Civil Action No. 1:07-cv-356-JM 

THE FREEDOM FROM RELIGION FOUNDATION; 

JAN DOE AND PAT DOE, PARENTS; DOECHILD-1, DOECHILD-2 and 

DOECHILD-3, MINOR CHILDREN; 

 Plaintiffs, 

v. 

THE CONGRESS OF THE UNITED STATES OF AMERICA; 

THE UNITED STATES OF AMERICA; 

THE HANOVER SCHOOL DISTRICT (“HSD”); 

THE DRESDEN SCHOOL DISTRICT (“DSD”); 

SCHOOL ADMINISTRATIVE UNIT 70 (“SAU #70”); 

 Defendants. 

PLAINTIFFS’ MOTION FOR PROTECTIVE ORDER 

Case 1:07-cv-00356-SM Document 8 Filed 01/08/08 Page 1 of 16
Pursuant to case law1

 and Rule 26(a)(1)2 of the Federal Rules of Civil 

Procedure, Plaintiffs move to have the Court enter a protective order that protects 

the true identity of the Plaintiffs (other than the Freedom From Religion 

Foundation (“FFRF”)). Submitted herewith in support of this Motion is a stipulated 

Protective Order agreed to by counsel for each party, and a Memorandum in 

support of this Motion. 

Respectfully submitted, 

 /s/ - Michael Newdow /s/ - Rosanna Fox

Michael Newdow, pro hac vice Rosanna Fox, NH SBN: 17693 

Counsel for Plaintiffs O’Brien Law Firm, P.C. 

PO Box 233345 One Sundial Avenue, #510 

Sacramento CA 95823 Manchester, NH 03103 

Phone: (916) 427-6669 Phone: (603) 627-3800 

E-mail: NewdowLaw@gmail.com E-mail: rosief13@comcast.net

January 8, 2008 

 

1 Doe v. Porter, 370 F.3d 558 (6th Cir. 2004); Doe v. Stegall, 653 F.2d 180 (5th 

Cir. 1981). 

2

 Fed. R. Civ. P. Rule 26(a)(1)(A) states that disclosures must be made “[e]xcept as 

... ordered by the court.” 

Case 1:07-cv-00356-SM Document 8 Filed 01/08/08 Page 2 of 16
1 Michael Newdow, pro hac vice 

2 PO Box 233345 

3 Sacramento, CA 95823 

4 (916) 427-6669 

5 

6 Rosanna Fox, NH SBN: 17693 

7 O’Brien Law Firm P.C. 

8 One Sundial Avenue, Fifth Floor 

9 Manchester, NH 03103 

10 (603) 627-3800 

11 

12 

13 IN THE UNITED STATES DISTRICT COURT 

14 FOR THE DISTRICT OF NEW HAMPSHIRE 

15 

16 Civil Action No. 1:07-cv-356-JM 

17 

18 

19 THE FREEDOM FROM RELIGION FOUNDATION; 

20 JAN DOE AND PAT DOE, PARENTS; DOECHILD-1, DOECHILD-2 and 

21 DOECHILD-3, MINOR CHILDREN; 

22 

23 Plaintiffs, 

24 v. 

25 

26 THE CONGRESS OF THE UNITED STATES OF AMERICA; 

27 THE UNITED STATES OF AMERICA; 

28 THE HANOVER SCHOOL DISTRICT (“HSD”); 

29 THE DRESDEN SCHOOL DISTRICT (“DSD”); 

30 SCHOOL ADMINISTRATIVE UNIT 70 (“SAU #70”); 

31 

32 Defendants. 

33 

34 

35 

36 STIPULATED PROTECTIVE ORDER 

37 

Case 1:07-cv-00356-SM Document 8 Filed 01/08/08 Page 3 of 16
FFRF v. U.S. Congress STIPULATED PROTECTIVE ORDER January 8, 2008 

Page 1 of 4 

1 Plaintiffs THE FREEDOM FROM RELIGION FOUNDATION (“FFRF”), 

2 JAN DOE, PAT DOE, DOECHILD-1, DOECHILD-2 and DOECHILD-3, by and 

3 through their undersigned counsel; Defendants THE CONGRESS OF THE 

4 UNITED STATES OF AMERICA, THE UNITED STATES OF AMERICA, THE 

5 HANOVER SCHOOL DISTRICT (“HSD”), THE DRESDEN SCHOOL 

6 DISTRICT (“DSD”), SCHOOL ADMINISTRATIVE UNIT 70 (“SAU #70”), by 

7 and through their undersigned counsel; and planned Intervenor-Defendant THE 

8 STATE OF NEW HAMPSHIRE, by and through its undersigned counsel; hereby 

9 stipulate as follows: 

10 

11 (1) The true identities of the Plaintiffs, except that of Plaintiff FFRF, will be 

12 protected from disclosure through the discovery process and in pleadings 

13 filed in this case and will be kept confidential. (Hereinafter, “Plaintiffs” 

14 means all Plaintiffs in this action except Plaintiff FFRF.) The identities of 

15 the Plaintiffs and any documents that reveal their identities as Plaintiffs will 

16 be deemed “confidential information” for purposes of this stipulation. 

17 However, this stipulation does not address whether Plaintiffs must be 

18 present in person at depositions, open court hearings or whether their 

19 identities will be required to be disclosed at trial. That issue will be 

20 discussed by the parties at a later date. 

21 

22 (2) In conjunction with the Parties entering into this stipulation, the true 

23 identities of Plaintiffs shall be disclosed to defense counsel (if requested) 

24 for the purpose of obtaining information necessary to defend the case, 

25 including but not limited to, residency status, taxpayer status, 

26 custody/guardianship status or school enrollment status of Plaintiffs. 

27 

28 (3) No Confidential information produced by any party shall be used for any 

29 purpose other than the litigation of this case. 

30 

Case 1:07-cv-00356-SM Document 8 Filed 01/08/08 Page 4 of 16
FFRF v. U.S. Congress STIPULATED PROTECTIVE ORDER January 8, 2008 

Page 2 of 4 

1 (4) There shall be no disclosure of confidential information to anyone other 

2 than the following: 

3 

4 (a) The parties to the case, including their current employees or agents who 

5 have a reasonable need to know the confidential information; 

6 (b) The parties’ attorneys and all attorneys affiliated with the respective 

7 parties, and the attorneys’ staff; 

8 (c) Experts and consultants retained by attorneys for the parties in the 

9 preparation or presentation of the case; 

10 (d) Employees of the insurance companies or claims administrators that 

11 insure any of the Defendants and/or oversee the litigation; 

12 (e) Any persons responsible for storing or maintaining the parties’ case 

13 files at the conclusion of the case; and 

14 (f) The court or any other officer who presides over any proceeding in the 

15 case, and to court reporters as necessary. 

16 

17 

18 (5) In filing documents with the Court, confidential information may be used in 

19 court if the documents are filed under seal. 

20 

21 (6) Disclosure: 

22 

23 (a) A request to a party for authorization to disclose confidential 

24 information, other than as permitted herein, shall identify the 

25 information for which disclosure is sought, shall identify the person or 

26 entity to whom disclosure is proposed, shall state the reasons why 

27 disclosure is necessary or appropriate, and shall be made in writing to 

28 counsel for the other party(s). Counsel for the party(s) shall respond in 

29 writing to the request within a reasonable time. If there is no objection 

30 to the request for disclosure, the identified confidential information may 

31 be disclosed to the person or entity previously identified. If the 

32 designating party denies authorization for disclosure of identified 

33 documents, no such disclosure shall be made unless, after application to 

34 the court, the court so orders. 

35 (b) Any person to whom confidential information is disclosed shall be 

36 advised of the confidential nature of the information and instructed that 

37 the information is to be kept confidential. All individuals should be 

38 advised that unauthorized disclosure of confidential information may 

39 subject them to a potential contempt citation. 

40 

Case 1:07-cv-00356-SM Document 8 Filed 01/08/08 Page 5 of 16
FFRF v. U.S. Congress STIPULATED PROTECTIVE ORDER January 8, 2008 

Page 3 of 4 

1 (7) This Stipulated Protective Order may be modified or terminated by the 

2 court for good cause shown, or by signed stipulation by all of the parties 

3 who agree to this stipulation. 

4 

5 (8) Any party for good cause may apply to the court to obtain further 

6 protection than that provided by the process of filing documents under 

7 seal. 

8 

9 (9) The party designating information as confidential may waive any of the 

10 provisions of this Stipulated Protective Order in writing. 

11 

12 (10) This Stipulated Protective Order shall continue to be binding after the 

13 conclusion of this action. 

14 

15 (11) Nothing contained herein shall preclude any party to the Stipulation from 

16 seeking to secure from the Court greater protection for particular 

17 information or for relief from the Stipulation if such is deemed to be 

18 necessary by the Party. 

19 

20 (12) Nothing in this Stipulated Protective Order shall prevent disclosure of 

21 confidential information as required by law or as compelled by any Court. 

22 

23 

24 DATED: January 8, 2008 

25 

26 /s/ - Michael A. Newdow

27 Attorney for Plaintiffs THE FREEDOM FROM RELIGION FOUNDATION, JAN 

28 DOE, PAT DOE, DOECHILD-1, DOECHILD-2 and DOECHILD-3. 

29 

30 /s/ - Eric B. Beckenhauer

31 Attorney for Defendants THE CONGRESS OF THE UNITED STATES OF 

32 AMERICA and THE UNITED STATES OF AMERICA. 

33 

34 /s/ - David Bradley

35 Attorney for Defendants THE HANOVER SCHOOL DISTRICT, THE DRESDEN 

36 SCHOOL DISTRICT and SCHOOL ADMINISTRATIVE UNIT 70. 

37 

38 /s/ - Nancy J. Smith

39 Attorney for planned Intervenor-Defendant THE STATE OF NEW HAMPSHIRE. 

Case 1:07-cv-00356-SM Document 8 Filed 01/08/08 Page 6 of 16
FFRF v. U.S. Congress STIPULATED PROTECTIVE ORDER January 8, 2008 

Page 4 of 4 

1 ORDER

2 

3 IT IS SO ORDERED: 

4 

5 

6 DATED: ___________________ /s/ - C.J. McAuliffe

7 U.S. District Judge 

8 United States District Court 

9 

10 

11 

Case 1:07-cv-00356-SM Document 8 Filed 01/08/08 Page 7 of 16
1 Michael Newdow, pro hac vice 

2 PO Box 233345 

3 Sacramento, CA 95823 

4 (916) 427-6669 

5 

6 Rosanna Fox, NH SBN: 17693 

7 O’Brien Law Firm P.C. 

8 One Sundial Avenue, Fifth Floor 

9 Manchester, NH 03103 

10 (603) 627-3800 

11 

12 

13 IN THE UNITED STATES DISTRICT COURT 

14 FOR THE DISTRICT OF NEW HAMPSHIRE 

15 

16 Civil Action No. 1:07-cv-356-JM 

17 

18 

19 THE FREEDOM FROM RELIGION FOUNDATION; 

20 JAN DOE AND PAT DOE, PARENTS; DOECHILD-1, DOECHILD-2 and 

21 DOECHILD-3, MINOR CHILDREN; 

22 

23 Plaintiffs, 

24 v. 

25 

26 THE CONGRESS OF THE UNITED STATES OF AMERICA; 

27 THE UNITED STATES OF AMERICA; 

28 THE HANOVER SCHOOL DISTRICT (“HSD”); 

29 THE DRESDEN SCHOOL DISTRICT (“DSD”); 

30 SCHOOL ADMINISTRATIVE UNIT 70 (“SAU #70”); 

31 

32 Defendants. 

33 

34 

35 

36 MEMORANDUM IN SUPPORT OF PLAINTIFFS’ MOTION FOR 

37 PROTECTIVE ORDER 

38 

Case 1:07-cv-00356-SM Document 8 Filed 01/08/08 Page 8 of 16
FFRF v. U.S. Congress MEMORANDUM IN SUPPORT OF PROTECTIVE ORDER January 8, 2008 

Page 1 of 7 

1 Plaintiffs, through counsel, submit this Memorandum in Support of Plaintiffs’ 

2 Motion for Protective Order. 

3 

4 BACKGROUND

5 This lawsuit has been filed with pseudonyms, rather than true names, for all 

6 Plaintiffs except Freedom From Religion Foundation (“FFRF”). As alleged in the 

7 Complaint, these pseudonymous Plaintiffs are all residents and citizens of 

8 Hanover, New Hampshire. This case involves objections to the use of the words, 

9 “under God,” in the Pledge of Allegiance as recited in the public schools. Each of 

10 the pseudonymous Plaintiffs is a minor child enrolled in a public school where the 

11 Pledge is recited, or the parent of such a child. It is believed that disclosure of the 

12 actual and true names of either the children or their parents will subject the minor 

13 children (and their parents) to potential harm. 

14 

15 LAW AND ARGUMENT

16 “Judicial proceedings are supposed to be open ... in order to enable the 

17 proceedings to be monitored by the public. The concealment of a party’s name 

18 impedes public access to the facts of the case, which include the parties’ identity.” 

Doe v. City of Chicago, 360 F.3d 667, 669 (7th 19 Cir. 2004). Nonetheless, “[t]he 

20 presumption that parties’ identities are public information, and the possible 

Case 1:07-cv-00356-SM Document 8 Filed 01/08/08 Page 9 of 16
FFRF v. U.S. Congress MEMORANDUM IN SUPPORT OF PROTECTIVE ORDER January 8, 2008 

Page 2 of 7 

1 prejudice to the opposing party from concealment, can be rebutted by showing that 

2 the harm to the plaintiff ... exceeds the likely harm from concealment. Id. In other 

3 words: 

4 In cases where the plaintiffs have demonstrated a need for anonymity, the 

5 district court should use its powers to manage pretrial proceedings, see Fed. 

6 R. Civ. P. 16(b), and to issue protective orders limiting disclosure of the 

7 party’s name, see Fed. R. Civ. P. 26(c), to preserve the party’s anonymity to 

8 the greatest extent possible without prejudicing the opposing party’s ability 

9 to litigate the case. 

10 

11 Doe v. Advanced Textile Corp., 214 F.3d 1058, 1069 (9th Cir. 2000). 

12 It should initially be noted that the United States Supreme Court has permitted 

13 pseudonymous filings in precisely this type of litigation. Santa Fe Independent 

14 School District v. Doe, 530 U.S. 290 (2000) (parents individually and as “next 

friends” to their children challenged prayers at public high school football games).1 15 

16 This Court has the authority in its discretion to enter a protective order to control 

17 discovery and protect the rights of the parties. Doe v. Porter, 370 F.3d 558, 560-

18 561 (6th Cir. 2004) (upholding lower court’s grant of protective order allowing the 

19 use of pseudonyms in challenge to religious instruction in schools); Doe v. Stegall, 

20 653 F.2d 180 (5th Cir. 1981) (reversing lower court’s denial of protective order 

21 allowing for pseudonyms. The Stegall court noted that “religion is perhaps the 

 

1

 Subsequently, the high Court decided a case involving a pseudonymous filing 

where the justification appears to be nowhere near as compelling as in the instant 

action. In City of San Diego v. Roe, 543 U.S. 77 (2004), a police officer who was 

Case 1:07-cv-00356-SM Document 8 Filed 01/08/08 Page 10 of 16
FFRF v. U.S. Congress MEMORANDUM IN SUPPORT OF PROTECTIVE ORDER January 8, 2008 

Page 3 of 7 

1 quintessentially private matter,” and that the plaintiffs’ disclosures about their 

2 religion “have invited an opprobrium analogous to the infamy associated with 

3 criminal behavior.” Id., at 186). 

4 This Circuit has indicated that pseudonymous filings can be appropriate even 

5 when the plaintiffs are adults. Brown v. Secretary of Health & Human Servs., 46 

F.3d 102, 105 (n.5) (1st 6 Cir. 1995) (where “[t]he district court granted named 

7 plaintiffs leave to use pseudomyms in order to protect their privacy,” apparently 

8 due solely to the plaintiffs having low income, necessitating AFDC benefits.) 

9 When children are involved, the need for protection is obviously greater. In fact, 

10 this was discussed relative to a statutory prohibition in United States v. Three 

Juveniles, 61 F.3d 86 (1st 11 Cir. 1995). 

12 A sister circuit has looked at this matter in some detail. Holding “that a party 

13 may preserve his or her anonymity in judicial proceedings in special circumstances 

14 when the party’s need for anonymity outweighs prejudice to the opposing party 

15 and the public’s interest in knowing the party’s identity,” Advanced Textile, 214 

16 F.3d at 1068, the Ninth Circuit found three factors to be of consequence: 

17 [I]n cases where, as here, pseudonyms are used to shield the anonymous party 

18 from retaliation, the district court should determine the need for anonymity by 

19 evaluating the following factors: (1) the severity of the threatened harm, (2) the 

20 reasonableness of the anonymous party’s fears, and (3) the anonymous party’s 

21 vulnerability to such retaliation. 

 

terminated from his job because of sexually explicit videotapes he had made was 

permitted to file pseudonymously. 

Case 1:07-cv-00356-SM Document 8 Filed 01/08/08 Page 11 of 16
FFRF v. U.S. Congress MEMORANDUM IN SUPPORT OF PROTECTIVE ORDER January 8, 2008 

Page 4 of 7 

1 

2 Id. In the instant case, the evaluation of those factors demonstrates that need. Even 

3 the mildest threatened harm – harassment of children in the public schools – 

4 warrants the requested relief. Additionally – as the attached Exhibits show – the 

5 fears are reasonable, and each of the children (and each adult) is vulnerable to the 

6 harms. 

7 Exhibit A pertains to Joann Bell, a parent who had three children enrolled in a 

8 public school district. Ms. Bell filed a federal lawsuit to stop school-sponsored 

9 prayer meetings. She has written: 

10 After I filed the lawsuit, my family and I received numerous threatening 

11 telephone calls and letters. These threats promised physical harm and even 

12 death to my family members and me as a result of my involvement as a 

13 plaintiff in the lawsuit. Many of the telephone calls told me that our home 

14 would be burned. I could not even perform such simple tasks as shopping 

15 for groceries in the community without being confronted by other persons 

16 about the lawsuit. 

17 

18 Additionally, when she responded to a bomb threat at her children’s school, 

19 “several school employees circled the car. One of the employees grabbed me by 

20 the hair of the head and battered my head against the frame of the car’s door.” 

21 After the family’s home “was burned in a fire of suspicious origin,” the family 

22 moved from the school district “motivated by a grave concern for the safety of our 

23 family.” Exhibit A. 

24 Megan Black – a third grader – was grabbed and yanked by her public school 

25 teacher for not reciting the now-religious Pledge of Allegiance. This was followed 

Case 1:07-cv-00356-SM Document 8 Filed 01/08/08 Page 12 of 16
FFRF v. U.S. Congress MEMORANDUM IN SUPPORT OF PROTECTIVE ORDER January 8, 2008 

Page 5 of 7 

1 by more than two years of taunts and harassment by her fellow students, which did 

2 not end until she changed schools. Exhibit B. 

3 Bailey Wood was pushed up against a building by a classmate who made the 

4 sign of the cross, was called a “monkey” because she believed in evolution, and 

5 was called “stupid” because she didn’t believe in God. This apparently all stemmed 

6 from the fact that her atheism was exposed when she didn’t say the words, “under 

7 God,” in the Pledge. Exhibit C. 

8 “I dreaded the first day of school each and every year,” writes Abigail 

9 Schweter, because her not saying the Pledge as a child resulted in her being 

10 “ostracized” and risked a “confrontation with the teacher.” Exhibit D. 

11 Ellen Janowitz was “frequently ridiculed in front of the class” by her teacher, 

12 because she could not, in good conscience, recite the entire Pledge. At age 15, she 

13 suffered “stares and silence of my fellow students [that] were excruciating [and] 

14 are still painful to recall” twenty years later. Exhibit E. 

15 A book written by Professor Frank Ravitch of the Michigan State University 

College of Law details numerous other cases involving religious outsiders.2 16 For 

17 instance, the Herdahls were a Lutheran family in a Southern Baptist Mississippi 

18 town. When the Herdahl children did not participate in “decidedly Southern 

19 Baptist” public school prayers, they were harassed by “[b]oth teachers and 

Case 1:07-cv-00356-SM Document 8 Filed 01/08/08 Page 13 of 16
FFRF v. U.S. Congress MEMORANDUM IN SUPPORT OF PROTECTIVE ORDER January 8, 2008 

Page 6 of 7 

1 students.” When the family filed suit to stop this clearly unlawful practice, “the 

2 harassment got even worse. Her family received bomb threats. She received a 

death threat, and the name calling and ridicule worsened.”3 3 

4 A second story recounted by Professor Ravitch concerned individuals in 

5 Alabama. The Herrings were “a Jewish family whose children had been subjected 

6 to severe religious discrimination and harassment in school.” The children “were 

7 physically assaulted by classmates because of their religion; swastikas were drawn 

8 on their lockers, bookbags, and jackets; and they were regularly taunted by the 

9 other children.” The mother, in a sworn statement to the Court, stated: 

10 Every day that I send my children to Pike County schools, I wonder if I am 

11 sending them into a war zone. ... The consequences of the school environment 

12 on my children’s psyches are devastating. My children are growing up 

13 believing that America is a caste society and they are untouchables – except for 

the purpose of getting beaten up. One child suffered “serious nightmares.”4 14 

15 

16 “Rachel Bauchman, a Jewish high school student, objected to overtly religious 

17 songs, which were sung at high school graduations by the high school choir of 

18 which she was a member. ... Rachel obtained a court order prohibiting the 

19 graduation songs. However, at the urging of parents and some students, the choir 

20 performed one of the religious songs anyway. ... When Rachel and her mother got 

 2

 Ravitch FS. School Prayer and Discrimination: The Civil Rights of Religious 

Minorities and Dissenters. (Northeastern University Press: Boston, 2001).

3

 Id., at 8-9. 

4

 Id., at 9-11. 

Case 1:07-cv-00356-SM Document 8 Filed 01/08/08 Page 14 of 16
FFRF v. U.S. Congress MEMORANDUM IN SUPPORT OF PROTECTIVE ORDER January 8, 2008 

Page 7 of 7 

1 up to leave – Rachel in tears – parents and students in the audience jeered and spat 

on them.”5 2 

3 The proposed ORDER provides Defendants with adequate means of 

4 ascertaining the residency status, taxpayer status, or school enrollment status of the 

5 Plaintiffs. Discovery, if needed, can also be accomplished under the proposed 

6 ORDER while preserving Defendants’ rights. 

7 

8 CONCLUSION

9 Good cause having been shown, Plaintiffs respectfully request that the Court 

10 preserve the anonymity of the Plaintiffs by entering a protective order. 

11 

12 Respectfully submitted, 

13 

14 /s/ - Michael Newdow /s/ - Rosanna Fox

15 

16 Michael Newdow, pro hac vice Rosanna Fox, NH SBN: 17693 

17 Counsel for Plaintiffs O’Brien Law Firm, P.C. 

18 PO Box 233345 One Sundial Avenue, #510 

19 Sacramento CA 95823 Manchester, NH 03103 

20 

21 Phone: (916) 427-6669 Phone: (603) 627-3800 

22 

23 E-mail: NewdowLaw@gmail.com E-mail: rosief13@comcast.net

24 

25 

26 January 8, 2008

 

5

 Id., at 11-12. 

Case 1:07-cv-00356-SM Document 8 Filed 01/08/08 Page 15 of 16
FFRF v. U.S. Congress Certificate of Service January 8, 2008 

1 IN THE UNITED STATES DISTRICT COURT 

2 FOR THE DISTRICT OF NEW HAMPSHIRE 

3 

4 CERTIFICATE OF SERVICE 

5 

6 Civil Action No. 1:07-cv-356-JM 

7 

8 Freedom From Religion Foundation v. U.S. Congress

9 

10 I HEREBY CERTIFY that a true and correct copies of 

11 

12 (1)PLAINTIFFS’ MOTION FOR PROTECTIVE ORDER 

13 (2)STIPULATED PROTECTIVE ORDER 

14 (3)MEMORANDUM IN SUPPORT OF PLAINTIFFS’ MOTION FOR 

15 PROTECTIVE ORDER 

16 (4)EXHIBITS ACCOMPANYING MEMORANDUM IN SUPPORT OF 

17 PLAINTIFFS’ MOTION FOR PROTECTIVE ORDER 

18 

19 were provided by electronic service to the Clerk of the Court via CM/ECF on this 

8th 20 day of January, 2008. Uncertain at this time as to whether or not the Clerk is 

21 forwarding material to the following email addresses, email notification was also 

22 provided directly to: 

23 

24 United States Defendants: eric.beckenhauer@usdoj.gov 

25 

26 School District Defendants: dbradley@stebbinsbradley.com 

27 

28 State of New Hampshire: Nancy.Smith@doj.nh.gov 

29 

30 

31 January 8, 2008 /s/ Michael Newdow

32 

33 Michael Newdow 

34 PO Box 233345 

35 Sacramento CA 92823 

36 916-427-6669 

37 

38 NewdowLaw@gmail.com

39 

Case 1:07-cv-00356-SM Document 8 Filed 01/08/08 Page 16 of 16