Plantiff's Motion to Compel Production of Documents - The DADT ...

Case 2:04-cv-08425-VAP-E Document 130 Filed 03/19/10 Page 42 of 83 Page ID #:824
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be. Would it be anything more than somebody making a written
complaint and would it be something that the United States
Department of Defense would know?
EXCEPTIONAL REPORTING SERVICES, INC
42
MR. WOODS: Well, your Honor, there are studies and
reports of the experience of these other countries. We have
been able to locate some of them but the United States Defense
Department is in a much better position than we are to know
what reports and studies exist and what reports and studies do
not exist. In this regard, your Honor, the Government is again
simply trying to evade its obligations when the Chairman of the
Joint Chiefs of Staff discussed this very issue at a Senate
Hearing on February 2nd and said he had talked to the military
leaders of some of these other countries.
THE COURT: Well I understand and hear your using the
words not of President Obama but another government individual.
MR. WOODS: Well actually we're not. These were sent
out before the statements by Admiral Mullen.
misunderstood.
words?
THE COURT: Oh, you're not? I'm sorry, I
MR. WOODS: Yeah.
THE COURT: So documented adverse impact are your
MR. WOODS: Yes.
THE COURT: All right.
MR. WOODS: But the -- what I was try --