Trial DB_v2

Nathanson, Paul (Vol. 01) - 11/12/2009 1 CLIP (RUNNING 00:15:29.063)

Starting with 029:03

NATHANSON-002 21 SEGMENTS (RUNNING 00:15:29.063)

1. PAGE 29:03 TO 29:19 (RUNNING 00:00:49.722)

03 165Q-Do you know what position the American

04 Anthropological Association takes, if any, with
05 respect to the issue of gay marriage?
06 A- They support it. They support it.
07 166Q-Do you know what the position, if any, of the
08 American Psycho-Analytic Association is with respect
09 to gay marriage?
10 A- They support it.
11 167Q-Do you know what the position of the American
12 Psychological Association is, if any, with respect
13 to gay marriage?
14 A- They support it.
15 168Q-Do you know what the position is of the American
16 Psychiatric Association...
17 A- They support it.
18 169Q-... with respect to gay marriage, if any?
19 A- They support it.
2. PAGE 31:23 TO 32:05 (RUNNING 00:00:26.382)

23 185Q-Are you familiar with the American Academy of

24 Paediatrics?
25 A- No. No, I'm sorry, I am. And they also support it.
00032:01 186Q-They also support what?
02 A- Gay marriage.
03 187Q-Do you know any of the reasons why the American
04 Academy of Paediatrics supports gay marriage?
05 A- They see no problem for children.
3. PAGE 38:19 TO 39:09 (RUNNING 00:00:43.653)

19 232Q-Now, using opinion in the sense that you do as a

20 researcher, do you have an opinion as to whether
21 permitting gay people to marry increases the
22 stability in commitment of their relationship?
23 A- It increases.
24 233Q-It increases the stability in commitment of their
25 relationship?
00039:01 A- That's right.
02 234Q-As a researcher, using the term "opinion" the way
03 you defined it, do you have an opinion as to whether
04 permitting gay people to marry increases their
05 happiness and sense of security and well-being?
06 Mr. PETER A. PATTERSON:
07 Objection, this is beyond the scope of his
08 expert report.
09 A- I think it does.
4. PAGE 40:21 TO 41:03 (RUNNING 00:00:25.666)

21 242Q-Let's try to break that down into two parts. First,

22 you recognize that gay couples are today raising
23 children, correct?
24 A- Yes.
25 243Q-And you believe that enabling those gay couples to
00041:01 marry would enhance their ability to be good parents PX2547

CONFIDENTIAL page 1
 Trial DB_v2

Nathanson, Paul (Vol. 01) - 11/12/2009 1 CLIP (RUNNING 00:15:29.063)

Starting with 029:03

NATHANSON-002 21 SEGMENTS (RUNNING 00:15:29.063)

1. PAGE 29:03 TO 29:19 (RUNNING 00:00:49.722)

03 165Q-Do you know what position the American

04 Anthropological Association takes, if any, with
05 respect to the issue of gay marriage?
06 A- They support it. They support it.
07 166Q-Do you know what the position, if any, of the
08 American Psycho-Analytic Association is with respect
09 to gay marriage?
10 A- They support it.
11 167Q-Do you know what the position of the American
12 Psychological Association is, if any, with respect
13 to gay marriage?
14 A- They support it.
15 168Q-Do you know what the position is of the American
16 Psychiatric Association...
17 A- They support it.
18 169Q-... with respect to gay marriage, if any?
19 A- They support it.
2. PAGE 31:23 TO 32:05 (RUNNING 00:00:26.382)

23 185Q-Are you familiar with the American Academy of

24 Paediatrics?
25 A- No. No, I'm sorry, I am. And they also support it.
00032:01 186Q-They also support what?
02 A- Gay marriage.
03 187Q-Do you know any of the reasons why the American
04 Academy of Paediatrics supports gay marriage?
05 A- They see no problem for children.
3. PAGE 38:19 TO 39:09 (RUNNING 00:00:43.653)

19 232Q-Now, using opinion in the sense that you do as a

20 researcher, do you have an opinion as to whether
21 permitting gay people to marry increases the
22 stability in commitment of their relationship?
23 A- It increases.
24 233Q-It increases the stability in commitment of their
25 relationship?
00039:01 A- That's right.
02 234Q-As a researcher, using the term "opinion" the way
03 you defined it, do you have an opinion as to whether
04 permitting gay people to marry increases their
05 happiness and sense of security and well-being?
06 Mr. PETER A. PATTERSON:
07 Objection, this is beyond the scope of his
08 expert report.
09 A- I think it does.
4. PAGE 40:21 TO 41:03 (RUNNING 00:00:25.666)

21 242Q-Let's try to break that down into two parts. First,

22 you recognize that gay couples are today raising
23 children, correct?
24 A- Yes.
25 243Q-And you believe that enabling those gay couples to
00041:01 marry would enhance their ability to be good parents

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02 to the children they're raising, correct?

03 A- Yes.
5. PAGE 49:05 TO 49:19 (RUNNING 00:00:44.525)

05 293Q-Yes. Are you aware of any peer-reviewed studies

06 published as to whether permitting gay people to
07 marry affects the rearing of children?
08 A- Yes.
09 294Q-And what peer-reviewed studies of that type are you
10 aware of?
11 A- Sociological and psychological ones.
12 295Q-And those are sociological and psychological studies
13 published by the various associations we've
14 identified?
15 A- Yes.
16 296Q-And what do those peer-reviewed studies conclude, to
17 your understanding?
18 A- They don't detect problems and they don't predict
19 problems.
6. PAGE 73:16 TO 74:10 (RUNNING 00:00:55.614)

16 447Q-And when you say "disorder", do you mean that the

17 Catholic Church no longer believes homosexual
18 activity, in your opinion...
19 A- M'hm.
20 448Q-... to be gravely immoral?
21 A- They do.
22 449Q-They do believe it's gravely immoral?
23 A- Yes.
24 450Q-Today?
25 A- Yes.
00074:01 451Q-And do they say that?
02 A- I don't know what words they use, but they certainly
03 have made it clear that it is prohibited, which
04 means that it is immoral and outside of the order of
05 God.
06 452Q-And a sin.
07 A- Yes.
08 453Q-And that's what the Catholic Church teaches its
09 adherents, correct?
10 A- That's correct.
7. PAGE 74:23 TO 75:21 (RUNNING 00:01:12.354)

23 455Q-All right. Let me start with the biggest Protestant

24 Church in the United States.
25 A- M'hm.
00075:01 456Q-And that that you describe is what?
02 A- Southern Baptist Convention.
03 457Q-And how does the Southern Baptist Convention
04 describe homosexual behaviour?
05 A- Sinful.
06 458Q-They describe it as evil?
07 A- Uh... some probably do.
08 459Q-Well, does the Southern Baptist Convention itself
09 describe homosexual behaviour as evil?
10 A- I haven't seen statements with that word, but
11 there's no... I would be inclined to say that some
12 do.
13 460Q-Does the Southern Baptist Convention describe
14 homosexual behaviour as a perversion?
15 A- Yes.
16 461Q-As an abomination?
17 A- Yes.
18 462Q-As deviant behaviour?
19 A- Yes.

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20 463Q-As a manifestation of a depraved nature?

21 A- Yes.
8. PAGE 76:08 TO 76:13 (RUNNING 00:00:33.826)

08 466Q-Does the teachings of the Southern Baptist

09 Convention, as you understand it, with respect to
10 gay people, represent what you described earlier as
11 hostility...
12 A- Yes.
13 467Q-... to gay people? Do you... let me ask you to look
9. PAGE 77:02 TO 77:02 (RUNNING 00:00:08.480)

02 468Q-And let me ask you to turn to page 17. And you say,
10. PAGE 77:03 TO 77:13 (RUNNING 00:00:42.146)

03 in paragraph 50, that a few religious people do say,

04 now and then, that "God hate gay people".
05 A- Yes.
06 469Q-You see that? And that's something that you put in
07 quotes.
08 A- Yes.
09 470Q-Where does that quote come from?
10 A- That comes from a picture in the newspaper of some
11 protestors out of... it was in California, but it
12 was about gay marriage, and they were carrying a
13 placard which said "God hate gay people".
11. PAGE 77:14 TO 77:14 (RUNNING 00:00:09.872)

14 471Q-Do you have an opinion as to what the proportion was

12. PAGE 77:15 TO 77:25 (RUNNING 00:00:54.504)

15 of the people in California that voted on

16 Proposition 8 who were motivated primarily by
17 religious reasons?
18 A- I'd say about half.
19 472Q-And of the people who were motivated by religious
20 reasons primarily and voted on Proposition 8, what
21 proportion of those people voted in favour of
22 Proposition 8 in your opinion, if you have one?
23 Mr. PETER A. PATTERSON:
24 Objection. Calls for speculation.
25 A- I don't know.
13. PAGE 81:17 TO 81:25 (RUNNING 00:00:27.475)

17 492Q-... would you agree that, up until the last fifty

18 (50) years, both religion and societies have been
19 very hostile to homosexuals?
20 A- Yes.
21 493Q-And that this hostility has caused homosexuals to be
22 discriminated against, is that correct?
23 A- Yes.
24 494Q-And indeed placed them in physical danger, correct?
25 A- Yes.
14. PAGE 82:09 TO 82:23 (RUNNING 00:00:49.767)

09 497Q-Are you aware of any studies or analyses as to how

10 societies' hostility to homosexuals and
11 homosexuality affected the psychology of
12 homosexuals?
13 Mr. PETER A. PATTERSON:
14 Objection, this is outside the scope of his
15 report.
16 A- I'm aware that there have been, in fact, studies.

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17 Mr. DAVID BOIES:

18 498Q-And have those studies reached uniform conclusions?
19 A- Yes.
20 499Q-And what are the uniform conclusions that those
21 studies have reached?
22 A- That being the target of hatred or hostility is a
23 bad thing, it has bad effects on people.
15. PAGE 85:08 TO 85:13 (RUNNING 00:00:29.950)

08 510Q-Now, do you have an opinion as to, taking the Roman

09 Catholic Church first, what proportion of Roman
10 Catholics accept the church's teaching that
11 homosexual activity is a disorder and greatly
12 immoral?
13 A- Not more than half.
16. PAGE 94:23 TO 95:11 (RUNNING 00:01:10.311)

23 570Q-Right. Now, you used the term "hate" or "hatred" in

24 your writing. And would you define what you mean by
25 that?
00095:01 A- Culturally propagated hostility. In other words, I
02 don't classify it as an emotion, I classify it as a
03 cultural source.
04 571Q-And I take it you would agree that there is what you
05 referred to as culturally propagated hostility
06 towards gay people?
07 A- There is some, yes.
08 572Q-And would it be your opinion that, historically,
09 there was a great deal of culturally propagated
10 hostility towards gay people?
11 A- Yes.
17. PAGE 95:15 TO 96:22 (RUNNING 00:01:59.431)

15 573Q-Are you familiar with the term "gay bashing"?

16 A- Yes.
17 574Q-And what does that term refer to?
18 A- Attacks... physical attacks on gay people or at
19 least perceived gay people.
20 575Q-That is, sometimes people are attacked because they
21 are perceived as gay people, even if they're not.
22 A- Yes.
23 576Q-But they are attacks that are directed... physical
24 attacks that are directed against people who are
25 perceived by the attackers to be gay?
00096:01 A- Yes, as in the case of Matthew Shepard.
02 577Q-Yes. And would you define for the record who
03 Matthew Shepard was?
04 A- He was a student in - where was it? - Wisconsin who
05 was attacked by some people who saw him coming out
06 of a bar... a gay bar, and killed him. He was left
07 impaled on a fence.
08 578Q-And when did that happen?
09 A- That could have been seven (7) or eight (8) years
10 ago.
11 579Q-We talked about how there were religions that
12 supported gay marriage and there were religions that
13 believed that homosexual activity was a sin, and
14 there were religions that supported Proposition 8
15 and there were religions that opposed Proposition 8,
16 remember that?
17 A- Yes.
18 580Q-Now, is it true that the religions that supported
19 Proposition 8, that sought to ban gay marriage were
20 much larger than the religions that supported gay
21 marriage?

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22 A- Yes.
18. PAGE 99:08 TO 99:13 (RUNNING 00:00:24.208)

08 595Q-And the religions that supported Proposition 8 and

09 opposed gay marriage contributed many more
10 volunteers to the campaign effort than the religions
11 that supported gay marriage and opposed Proposition
12 8, correct?
13 A- Yes.
19. PAGE 102:03 TO 102:08 (RUNNING 00:00:30.041)

03 608Q-Let me ask you a question about hostility to gay

04 people, and I'll refer to it as gay bashing; do you
05 believe that the teaching of certain religions that
06 homosexual relations are a sin and an abomination
07 contributes to gay bashing?
08 A- Yes.
20. PAGE 102:24 TO 103:05 (RUNNING 00:00:43.921)

24 613Q-... is it your opinion that the primary cause of

25 culturally propagated hostility is religious
00103:01 teaching?
02 A- I... that might be a complex answer. Let me start
03 by saying that in a direct sense, yes, but I think
04 that religious hostility to homosexual behaviour, in
05 turn, has roots other than religion.
21. PAGE 108:12 TO 109:09 (RUNNING 00:01:07.215)

12 648Q-With respect to Black, was religion or religious

13 doctrine used to justify the prejudice against
14 Black?
15 MR. PETER A. PATTERSON:
16 I object, this is outside of the scope of this
17 expert report.
18 A- Yes.
19 MR. DAVID BOIES:
20 649Q-And did the defenders of the prejudice or
21 stereotypes against Blacks argue that the
22 discrimination was somehow protective of the family?
23 A- Yes.
24 650Q-And was religion or religious doctrine used to
25 justify the prejudice against women?
00109:01 MR. PETER A. PATTERSON:
02 I object, again outside the scope of the
03 report.
04 MR. DAVID BOIES:
05 651Q-Yes. And did the defenders of the prejudice or
06 stereotypes against women argue that the
07 discrimination against women was important to
08 protect in the family?
09 A- Yes.

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