Free Brief in Opposition to Motion - District Court of Colorado - Colorado

Case 1:04-cv-01126-MJW-PAC

Document 47-3

Filed 11/02/2005

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EXHIBIT 1 AFFIDAVIT OF WILLIAM SULZMAN

William Sulzman swears or affirms, after first being duly sworn, that his statement set forth below is true and correct to the best of his information and belief. 1. I was a Plaintiff in CPIS v. City of Colorado Springs. 2. I am a founder of a group known as Citizens for peace in Space (CPIS). 3. From its beginning to the present time CPIS has had no official members nor solicited any. It keeps no records of attendance and has no board of directors. It is not incorporated, nor does it have a 501©(3) status. 4. Therefore, Bill Durland has not been, nor is he now a member of CPIS. 5. I have known Bill Durland since 1980, during which time I am aware that he has been a member of organizations that have membership lists and boards of directors. He has also been an attorney for diverse groups across the political and religious spectrum. Bill 6. Durland is a local human and civil rights attorney who has provided legal advice and counsel pro bono or at modest legal fees to groups in need of legal representation in his areas of expertise, including CPIS (but not in the current CPIS v. City of Colorado Springs case). 7. I saw Bill Durland, with his wife, at the CPIS trial on July 6, but on no other days of the trial. He was with many persons who were spectators at the trial. He had no official or legal position in the litigation. 8. I saw Brian Hildenbrandt there as well, sitting with young children who may have been his. He was not with Bill Durland. He had no official or legal activity in the CPIS case.

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Case 1:04-cv-01126-MJW-PAC

Document 47-3

Filed 11/02/2005

Page 2 of 2

9. Those of us who later constituted the CPIS Plaintiffs gathered together at a location different from the general demonstration area of October 7 and 8, 2003. Neither Bill Durland nor Brian Hildenbrandt were with us at our location. FURTHER AFFIANT SAYETH NOT.

s/William Sulzman William Sulzman 817 1/2 S. Tejon St. Colorado Springs, CO 80903 Tel: 719-389-0644 STATE OF COLORADO COUNTRY OF EL PASO ) ) )

SWORN TO AND SUBSCRIBED by William Sulzman, this 31st day of October, 2005, before me. WITNESS my hand and official seal My commission expires: August 28, 2008

s/Sandra Dowda Notary Public Address: 431 W. Bijou Colorado Springs, CO 80905

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