Concerning Secretary Sam Reed's request of the Court to avoid answering questions under oath and under the penalty of perjury, here are the questions:

Request for Admission #1: Admit or deny that the Secretary of State's Office released Referendum 71 petitions with the names, addresses and/or signatures of petitioners to third parties.
Response for #1:

Request for Admission #2: Admit or deny that State law and regulations adopted by the Secretary of State prohibit disclosure of lists of individuals for commercial purposes. RCW 42.56.070(9) and WAC 434-12A-110.
Response For #2:

Request for Admission #3: Admit or deny that the Secretary of State's Office does not ask public record act requestors if they intend to use public records for commercial purposes.
Response for #3:

Request for Admission #4: Admit or deny that the Secretary of State's Office has released the personal signatures, home addresses and names of over one million petitioners to the public.
Response for #4:

Request for Admission #5: Admit or deny that the Secretary of State's Office does not redact from public records releases the personal signatures of petitioners on qualified ballot initiative and referendum petitions.
Response for #5:

Request for Admission #6: Admit or deny that the Secretary of State's Office has no identity theft prevention program.
Response for #6:

Request for Admission #7: Admit or deny that the Secretary of State has no written advice from the Attorney General's Office stating that the names, home addresses and signatures are public records.
Response for #7:

Request for Admission #8: Admit or deny that Secretary Reed worked as an assistant to former Secretary of State Ludlow Kramer
Response for #8:

Request for Admission #9: Admit or deny that when a citizen signs an initiative or referendum petition they are exercising their First Amendment rights.
Response for #9:

Request for Admission #10: Admit or deny that when a citizen signs an initiative or referendum petition they are exercising their political free speech rights under the state and federal constitutions.
Response for #10:

Request for Admission #11: Admit or deny that the Secretary of State's initiative and referendum signature verification process is secret.
Response for #11:

Request for Admission #12: Admit or deny that if the Secretary of State's initiative and referendum signature verification process determines that an initiative has insufficient signatures, the petitions are destroyed.
Response for #12:

Request for Admission #13: Admit or deny that when a citizen signs an initiative or referendum petition they are exercising their liberty interests.
Response for #13:

Request for Admission #14: Admit or deny that the Secretary of State's policy of releasing the signatures, names and home addresses of petitioners may chill a citizen's right to petition government
Response for #14:

Request for Admission #15: Admit or deny that the Secretary of State's Office does not have a records retention policy.
Response for #15:

Request for Admission #16: Admit or deny that policies that chill a citizen's right to petition via the initiative and referendum process hinders exercise of that power.
Response for #16:

Request for Admission #17: Admit or deny that disclosure of voter signatures is prohibited by law.
Response for #17:

Request for Admission #18: Admit or deny that disclosure of voter signatures could facilitate identity theft.
Response for #18:

Request for Admission #19: Admit or deny that disclosure of voter names could facilitate identity theft.
Response for #19:

Request for Admission #20: Admit or deny that disclosure of voter home addresses could facilitate identity theft.
Response for #20:

Request for Admission #21: Admit or deny that Referendum 71 petitions filed with your office have been released to the public by employees or agents of your office.
Response for #21:

Request for Admission #22: Admit or deny that the Public Records Act imposes an affirmative duty on the Secretary of State to publish procedures.
Response for #22:

Request for Admission #23: Admit or deny that the Secretary of State's office has failed to publish any rules governing the public release of documents showing the names, personal signatures or home addresses of citizens who signed initiative or referendum petitions.
Response for #23:

Request for Admission #24: Admit or deny that when a citizen signs an initiative or referendum petition, their names, signatures and home addresses should be released to persons who will use them for commercial purposes.
Response for #24:

Request for Admission #25: Admit or deny that when a citizen signs an initiative or referendum petition, their name, signature and home address should be released to persons who will post them on the internet.
Response for #25:

Request for Admission #26: Admit or deny that from 1/1/1912 - 1/31/2005, the Secretary of State's office never released the names, signatures, and home addresses on initiative or referendum petitions to the public.
Response for #26:

Request for Admission #27: Admit or deny that the first time the office of Secretary of State turned over the names, signatures and home addresses on initiatives or referendum petitions to the public was in 2006.
Response for #27:

Request for Admission #28: Admit or deny that there are only two AGO opinions on the topic of names, signatures, and home addresses on initiative and referendum petitions and both of them advised not to release citizens personal information.
Response for #28:

Request for Admission #29: Admit or deny that in 1973, then Secretary of State Lud Kramer's policy was to not violate the privacy of citizen signers of initiative and referendum petitions.
Response for #29:

Request for Admission #30: Admit or deny that in 1973, Sam Reed worked for Secretary of State Lud Kramer.
Response for #30:

Request for Admission #31: Admit or deny that in 1973, Judge Hewitt Henry upheld Lud Kramer's privacy policy on the names, signatures, and home addresses on initiative and referendum petitions. Chaney v. Kramer, Thurston Co. Cause No. 48733 (1973).
Response for #31:

Request for Admission #32: Admit or deny that Sam Reed collaborated with Secretary of State Lud Kramer on the office policy denying disclosure of the names, home address and signatures of petitioners on initiative and referendum petitions.
Response for #32:

Request for Admission #33: Admit or deny that the Secretary of State's Office contracts out imaging services to a private firm to make a digital (electronic) copy of each petition sheet.
Response for #33:

Request for Admission #34: Admit or deny that the Secretary of State's Office has no written confidentiality agreement with that contractor concerning use or release of the electronic copies.
Response for #34:

Request of Admission #35: Admit or deny that when Mr. Brian Murphy submitted his request for digital images of all R-71 petition sheets, he was not asked if the lists would be used for commercial purposes.
Response for #35:

Request of Admission #36: Admit or deny that when Mr. Arthur West submitted his request for digital images of all R-71 petition sheets, he was not asked if the lists would be used for commercial purposes.
Response for #36:

Request of Admission #37: Admit or deny that when Mr. Brian Spencer submitted his request for digital images of all R-71 petition sheets, he was not asked if the lists would be used for commercial purposes.
Response for #37:

Request of Admission #38: Admit or deny that when Mr. Bryan Wahl submitted his request for digital images of all petition sheets for the 11 initiatives (I-722; I-745; I-747; I-776; I-900; I-912; I-917; I-920; I-960; I-985 and I-1033), he was not asked if the lists would be used for commercial purposes.
Response for #38:

Request of Admission #39: Admit or deny that when Mr. Arthur West submitted his request for digital images of all petition sheets for the 11 initiatives (I-722; I-745; I-747; I-776; I-900; I-912; I-917; I-920; I-960; I-985 and I-1033), he was not asked if the lists would be used for commercial purposes.
Response for #39:

Request of Admission #40: Admit or deny that this Secretary of State has never asked anyone seeking lists of citizens who signed petitions if the lists would be used for commercial purposes.
Response for #40:

Request for Admission #41: Admit or deny that the position of the Secretary of State's office under Ludlow Kramer, Bruce Chapman and Ralph Munro was that petitions were public records but that the personal information on them -- the names, signatures, and home addresses of citizens who signed them -- must be redacted to comply with the Public Records Act
Response for #41:

Request for Admission #42: Admit or deny that Don Whiting's sworn declaration filed with plaintiffs' Motion for Temporary Restraining Order says that Secretary of State Ralph Munro's policy was to redact the names, signatures, and home addresses on initiative and referendum petitions.
Response for #42:

Request for Admission #43: Admit or deny that during the verification process of signatures on ballot measures submitted from 1999 through 2009, the office of Secretary of State has found zero instances of verified forgeries or fraud during that time.
Response for #43:

Request for Admission #44: Admit or deny that the Secretary of State did not ask for or receive an AGO opinion in the 90's on the topic of names, signatures, and home addresses on initiative and referendum petitions.
Response for #44:

Request for Admission #45: Admit or deny that in 2006, the Secretary of State's practice of releasing the names, signatures and home addresses on initiative and referendum petitions changed without following the rulemaking procedures of the Administrative Procedures Act.
Response for #45:

Request for Admission #46: Admit or deny that Mr. Whiting's sworn declaration is correct.
Response for #46:

Request for Admission #47: Admit or deny that the Secretary of State's Office 2006-2009 policy of releasing the personal information on initiative and referendum petitions is contrary to the practices of every other Secretary of State.
Response for #47:

Request for Admission #48: Admit or deny that citizens will be less likely to sign initiative and referendum petitions because of your policy of releasing citizen' signers' names, signatures, and home addresses to anyone for any reason
Response for #48:

Request for Admission #49: Admit or deny that when a citizen votes for or against an initiative or referendum on the ballot, that citizen is acting as a citizen legislator.
Response for #49:

Request for Admission #50: Admit or deny that when a citizen votes for or against an initiative or referendum on the ballot, the people have a right to know how that citizen voted.
Response for #50:

Request for Admission #51: Admit or deny that when a citizen signs an initiative or referendum petition, that citizen is acting as a citizen legislator.
Response for #51:

Request for Admission #52: Admit or deny that when a citizen signs an initiative or referendum petition, the people have a right to know that citizen signer's name, signature, and home address.
Response for #52:

Request for Admission #53: Admit or deny that state law and regulations cannot violate the U.S. Constitution and Washington state Constitution.
Response for #53:

Request for Admission #54: Admit or deny that the Public Records Act is narrowly tailored to allow the release of the names, signatures, and home addresses of citizens who sign initiative and referendum petitions.
Response for #54:

Request for Admission #55: Admit or deny that you could change your policy on the release of personal information on initiative and referendum petitions without a court order.
Response for #55:

Request for Admission #56: Admit or deny that some citizens sign initiative and referendum petitions to get it on the ballot and not because they support the proposed policy.
Response for #56:

Request for Admission #57: Admit or deny that representatives from your office have already released the names, signatures, and home addresses of the citizens who signed Referendum 71 petitions.
Response for #57:

Request for Admission #58: Admit or deny that representatives from your office released the names, signatures, and home addresses of the citizens who signed Referendum 71 petitions because it was believed that the court would rule such a release was acceptable.
Response for #58:

Request for Admission #59: Admit or deny that the private contractor who prepared the digital (electronic) copy of the R-71 petitions sent it to non-governmental third parties.
Response for #59:

Request for Admission #60: Admit or deny that your counsel, James Pharris, sent the following email to Judge Hick's Judicial Assistant, Debbie Requa, on October 19, 2009 at 2:45 pm:

Ms. Requa:
Please be advised that we definitely intend to continue with tomorrow's hearing. Our understanding is that Justice Kennedy's order specifically reflects the information (which we gave the Supreme Court) that Judge Hicks would be asked to rule on our motion tomorrow. In light of the possibility that Judge Hicks would dissolve or modify the TRO before Justice Kennedy had a chance to review the briefing and materials he has, Justice Kennedy entered a temporary order to preserve the status quo. In effect, Justice Kennedy is waiting to hear Judge Hicks' ruling before he rules on the motion before him.
So, we do not want to strike or delay tomorrow's hearing. Our hope is that Judge Hicks will modify his order along the lines of our motion, so that Justice Kennedy can then decide whether to extend or dissolve his temporary order "staying the stay" the Ninth Circuit entered.
Response for #60:

Request for Admission #61: Admit or deny that your counsel, James Pharris, sent the following email to Plaintiffs' counsel (Newman) in response to the above quoted email and asking if Mr. Pharris "communicated with Kennedy via some response?" and "If so, please forward."

My information is based on a phone call from Danny Bickell of the Supreme Court Clerk's office this morning, just a few minutes before the order went out.
Response for #61:

Request for Admission #62: Admit or deny that Mr. Bickell did not say that Justice Kennedy is waiting to hear Judge Hick's ruling before he rules on the motion before him.
Response for #62:

Request for Admission #63: Admit or deny that voter records maintained by the Secretary of State's Office contain voters' personal signature, address and name.
Response for #63:

Request for Admission #64: Admit or deny that initiative petition files maintained by the Secretary of State contain voter's personal signature, address and name.
Response for #64:

Request for Admission #63: Admit or deny that your policy is to redact from public record releases the personal signature from the voter record.
Response for #63:

Request for Admission #64: Admit or deny that your policy is to NOT redact, from public records releases, the personal signatures from qualified ballot initiative petitions.
Response for #64:

Request for Admission #65: Admit or deny that there is no bona-fide public use of "personal signatures."
Response for #65:

Request for Admission #66: Admit or deny that the Secretary of State's Office contracts with Image Source to digitize petitions.
Response for #66:

Request for Admission #67: Admit or deny that Image Source is able to provide a searchable scan of petitioner names, signatures and home addresses.
Response to #67:

Request for Admission #68: Admit or Deny that Secretary Reed on TVW "The Impact" (aired on 10/21) stated that the office advises people making public records requests that they cannot use the record for commercial purposes.
Response to #68:

Request for Admission #69: Admit or Deny that Secretary Reed on TVW "The Impact" (aired on 10/21) stated that the office has forwarded concerns about commercial use of public records for prosecution.
Response to #69:

Request for Admission #70: Admit or deny that a person's signature on an initiative or referendum petition is, in fact, a part of the ballot process with respect of that particular initiative petition.
Response to #70:

Request for Admission #71: Admit or deny that a person's signature on an initiative or referendum petition is, in fact, only necessary in so far as it is a valid signature of a Washington voter and has no other significance.
Response to #71:

DATED: 10/22/09 By: ______________________________
Shawn Timothy Newman
Attorney at Law, Inc. P.S. WSBA No. 14193
Attorney for the Plaintiffs Eyman and Fagan

-- END --

These are relevant questions to the lawsuit but also are of interest to the general public and to the press. He should swear under penalty of perjury that his answers to the questions above are the truth, the whole truth, and nothing but the truth so help me God.

Tell Sam Reed to stop stonewalling and answer the questions under oath: email him at: sreed@secstate.wa.gov -- make sure to 'cc' me: tim_eyman@comcast.net

Help us keep the pressure on.