State of Washington, et al v. Donald J. Trump, et al

Filing 68

Submitted (ECF) Amicus brief for review and filed Motion to become amicus curiae. Submitted by US Justice Fndn, Citizens United, Citizens United Fndn, English First Fndn, English First, Public Advocate of the US, Gun Owners Fndn, Gun Owners of America, Conservative Legal Defense and Education Fund, US Border Control Fndn & Policy Analysis Center. Date of service: 02/06/2017. [10304130] [17-35105] (Titus, Herbert) [Entered: 02/06/2017 02:48 PM]

IN THE
UNITED STATES COURT OF APPEALS
FOR THE NINTH CIRCUIT
________________________________________
)
STATE OF WASHINGTON, et al.,
)
)
Plaintiffs-Appellees,
)
)
v.
)
No. 17-35105
)
DONALD J. TRUMP,
)
President of the United States, et al.
)
)
Defendants-Appellants. )
________________________________________ )
MOTION FOR LEAVE TO FILE BRIEF AS AMICI CURIAE
Amici Curiae U.S. Justice Foundation, Citizens United, Citizens United
Foundation, English First Foundation, English First, Public Advocate of the
United States, Gun Owners Foundation, Gun Owners of America, Conservative
Legal Defense and Education Fund, U.S. Border Control Foundation, and Policy
Analysis Center hereby move for leave to file a brief amicus curiae in support of
the Defendants-Appellants’ Motion for Stay Pending Appeal. It is hereby stated
as follows:
1. All parties consent to the filing of this amicus brief.
2. As stated more fully in the attached brief, amici curiae have extensive
experience with respect to the issues presented by this case, and have an

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significant interest in the outcome of this case. Amici believe that this brief will
be of assistance to the Court in deciding the Motion for Stay Pending Appeal
WHEREFORE, we respectfully request that this Court grant leave to file
an amicus curiae brief in support of Defendants-Appellants’ Motion for Stay
Pending Appeal.
Respectfully submitted,

February 6, 2017

/s/ Herbert W. Titus
Herbert W. Titus
WILLIAM J. OLSON, P.C.
370 Maple Avenue West, Suite 4
Vienna, VA 22180-5615
[phone]
[phone] (fax)
[e-mail]
Attorneys for Amici Curiae U.S.
Justice Foundation, et al.

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CERTIFICATE OF COMPLIANCE WITH RULE 27(d)(2)(A)
IT IS HEREBY CERTIFIED:
1.

That the foregoing Motion for Leave to Brief as Amici Curiae

complies with the type-volume limitation of Rule 27(d)(2)(A), Federal Rules of
Appellate Procedure, because this motion contains 157 words, excluding the parts
of the brief exempted by Rule 32(f).
2.

This motion complies with the typeface requirements of Fed. R. App.

P. 32(a)(5) and the type style requirements of Fed. R. App. P. 32(a)(6) because this
brief has been prepared in a proportionally spaced typeface using WordPerfect
version 18.0.0.200 in 14-point Times New Roman.

/s/ Herbert W. Titus
Herbert W. Titus
Attorney for Amici Curiae
U.S. Justice Foundation, et al.
Dated: February 6, 2017

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CERTIFICATE OF SERVICE
IT IS HEREBY CERTIFIED that service of the foregoing Motion for Leave
to Brief as Amici Curiae, was made, this 6th day of February 2017, by the Court’s
Case Management/ Electronic Case Files system upon the attorneys for the parties.

/s/ Herbert W. Titus
Herbert W. Titus
Attorney for Amici Curiae
U.S. Justice Foundation, et al.