Perry et al v. Schwarzenegger et al

Filing 558

MOTION to File Amicus Curiae Brief in Support of Plaintiffs filed by Unitarian Universalist Legislative Ministry California, et al.. (Isaacson, Eric) (Filed on 2/3/2010)

Perry et al v. Schwarzenegger et al

Doc. 558

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1 ERIC ALAN ISAACSON (120584) [e-mail] 2 STACEY M. KAPLAN (241989) [e-mail] 3 655 West Broadway, Suite 1900 San Diego, CA 92101 4 Telephone: [phone] (fax) 5 Attorneys for Amici Curiae Unitarian Universalist Legislative Ministry California; Unitarian 6 Universalist Legislative Ministry Action Network, CA; Unitarian Universalist Association; California Faith for Equality; California Council of Churches; California Council of Churches 7 Church IMPACT; Northern California Nevada Conference of the United Church of Christ; Southern California Nevada Conference of the United Church of Christ; General Synod of the 8 United Church of Christ; Universal Fellowship of Metropolitan Community Churches; Pacific Association of Reform Rabbis; and Progressive Jewish Alliance 9 10 11 UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA ) ) Plaintiffs, ) ) ­ and ­ ) ) CITY AND COUNTY OF SAN FRANCISCO, ) ) ) Plaintiff-Intervenor, ) ) vs. ) ) ARNOLD SCHWARZENEGGER, et al., ) ) Defendants, ) ) ­ and ­ ) PROPOSITION 8 OFFICIAL PROPONENTS ) DENNIS HOLLINGSWORTH, et al. ) ) Defendant-Intervenors. ) ) No. 09-cv-02292-VRW NOTICE OF MOTION AND MOTION FOR LEAVE TO FILE AMICI CURIAE BRIEF OF UNITARIAN UNIVERSALIST LEGISLATIVE MINISTRY CALIFORNIA; UNITARIAN UNIVERSALIST LEGISLATIVE MINISTRY ACTION NETWORK, CA; UNITARIAN UNIVERSALIST ASSOCIATION; CALIFORNIA FAITH FOR EQUALITY; CALIFORNIA COUNCIL OF CHURCHES; CALIFORNIA COUNCIL OF CHURCHES CHURCH IMPACT; NORTHERN CALIFORNIA NEVADA CONFERENCE OF THE UNITED CHURCH OF CHRIST; SOUTHERN CALIFORNIA NEVADA CONFERENCE OF THE UNITED CHURCH OF CHRIST; GENERAL SYNOD OF THE UNITED CHURCH OF CHRIST; UNIVERSAL FELLOWSHIP OF METROPOLITAN COMMUNITY CHURCHES; PACIFIC ASSOCIATION OF REFORM RABBIS; AND PROGRESSIVE JEWISH ALLIANCE, IN SUPPORT OF PLAINTIFFS DATE: TIME: JUDGE: LOCATION: To be determined To be determined Chief Judge Walker Courtroom 6, 17th Floor

12 KRISTIN M. PERRY, et al., 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

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NOTICE OF MOTION AND MOTION FOR LEAVE TO FILE BRIEF AS AMICI CURIAE TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD, PLEASE TAKE NOTICE

3 THAT as soon as the matter may be heard before the Honorable Vaughn R. Walker, in Courtroom 6 4 of the above-entitled Court, located at United States Courthouse, 450 Golden Gate Avenue, San 5 Francisco, California. 6 Universalist Action Network California, Unitarian Universalist Association, California Faith for 7 Equality, California Council of Churches, California Council of Churches Church IMPACT, 8 Northern California Nevada Conference of the United Church of Christ, Southern California Nevada 9 Conference of United Church of Christ (SCNC), General Synod of the United Church of Christ, 10 Universal Fellowship of Metropolitan Community Churches, Pacific Association of Reform Rabbis, 11 and Progressive Jewish Alliance respectfully seek leave to file the accompanying brief as amici 12 curiae. 13 As explained below, amici curiae have a profound interest both in honoring marriage as a 14 fundamental civil right that cannot be abrogated at the ballot box, and in restoring the freedom of 15 California's clergy, who choose to do so, to officiate at the legal marriages of members of their 16 congregations. While every faith tradition has the right to define its own doctrines concerning 17 religious rites of marriage, none should be able to impose those doctrines on others by law. 18 No party's counsel authored any part of the proposed brief. No one other than amici and 19 their counsel contributed money to fund the preparation or submission of the brief. 20 MEMORANDUM OF POINTS AND AUTHORITIES 21 I. 22 A. 23 The identities of proposed amici curiae, are as follows: 24 1. 25 CA) is a statewide justice ministry that cultivates and connects leaders and communities to empower 26 the public voice of those who share Unitarian Universalist values and Principles ­ upholding the 27 worth and dignity of every person, furthering justice, equity, and compassion, promoting democracy 28
MOTION FOR LEAVE TO FILE AMICUS CURIAE BRIEF - 09-cv-02292-VRW

The Unitarian Universalist Legislative Ministry California, Unitarian

IDENTITY AND INTEREST OF AMICI CURIAE Identity of Amici Curiae

Amicus curiae Unitarian Universalist Legislative Ministry California (UULM

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1 and religious freedom. Over 5,000 individuals and many of California's 76 Unitarian Universalist 2 congregations have affiliated with the UULM CA in order to advance the values of their faith. As 3 the General Assembly of the Unitarian Universalist Association, since 1970, has passed 24 4 resolutions urging support for lesbian, gay, bisexual and transgender ("LGBT") rights, including 5 support for civil marriage for same-sex couples, UULM CA places a high priority on organizing on 6 behalf marriage equality. Hundreds of same-sex couples were legally married by Unitarian 7 Universalist clergy in California between June 17, 2008, and November 4, 2008. 8 2. Amicus curiae Unitarian Universalist Legislative Ministry Action Network, CA,

9 and its UULM Action Network, CA PAC compose the UULM CA's 501(c)4 public advocacy arm, 10 organizing in support and/or opposition to ballot measures and legislation in order to support 11 Unitarian Universalist values of justice, equity, compassion, religious liberty, and sustainable living. 12 For the fiscal year ending June 2008, it had total revenues of $34,232 and assets of $17,759. For the 13 fiscal year ending June 2009 it had total revenues of $91,709 and total assets of $25,186. In 2008, 14 UULM Action Network PAC funded interfaith organizing against Proposition 8; its expenditures 15 opposing Proposition 8 were less than $60,000. 16 3. Amicus curiae Unitarian Universalist Association of Congregations (UUA) is a

17 denomination comprising more than 1,000 congregations nationwide, among them many of 18 19 20 21 22 rights for LGBT people, including the 1996 resolution in support of legal marriage between samesex couples. Clergy in Unitarian Universalist congregations officiated at the legal marriages of America's founding churches organized in the early 1600s, and has 76 congregations in the State of California. Since 1970, the UUA General Assembly has adopted 24 resolutions supporting equal

23 same-sex couples before Proposition 8's enactment, and wish to do so again. 24 4. Amicus curiae California Faith for Equality is a multi-faith coalition whose mission

25 is to educate, support and mobilize California's faith communities to promote equality for LGBT 26 people, many of whom have been deeply wounded by their own faith communities, and to safeguard 27 religious freedom. As a multi-faith organization, it respects and values the wisdom and perspectives 28
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1 of every faith tradition, several of which recognize same-sex marriage as a religious rite, but many of 2 which do not. Formed in 2005, California Faith for Equality formally incorporated in October 2009. 3 5. Amicus curiae California Council of Churches is an organization of California's

4 Christian churches representing the theological diversity in the state's mainstream and progressive 5 6 7 8 9 and Orthodox Christian communities, as well as allies from other faith traditions. Churches in two of those denominations, the United Church of Christ (Northern California Nevada Conference; communities of faith. Its membership includes over 4,000 California congregations, numbering more than 1.5 million members, drawn from 21 denominations spanning the mainstream Protestant

10 Southern California Nevada Conference), and the Universal Fellowship of Metropolitan 11 Community Churches (Region 1; Region 6) have endorsed same-sex marriages within their 12 religious liturgy, and generally opened their doors to same-sex couples to be legally married in 13 14 and pro-church autonomy. Joining an amicus brief in the Marriage Cases, the California Council of 15 16 Churches declared: "Our commitment to religious liberty for all and equal protection under the law religious rites of marriage. The Council's position on same-sex marriage is pro-religious freedom

17 leads us to assert that the State may not rely on the views of particular religious sects as a basis for 18 denying civil marriage licenses to same-gender couples." In re Marriage Cases, No. S147999, Brief 19 of the Unitarian Universalist Association of Congregations, et al., at xv-xvi (filed Sept. 26, 2007). 20 As a 501(c)3, the California Council of Churches devoted no resources at all to opposing 21 22 23 24 25 26 27 28 6. The California Council of Churches' public advocacy arm, amicus curiae California Church IMPACT, was incorporated as a separate 501(c)4 non-profit in 1996. California Church IMPACT advocates for social justice on behalf of the Council's member congregations and denominations, publishing an electronic ACTION ALERT, and formulating ballot-proposition recommendations based on the faith-based Legislative Principles set forth through the California Council of Churches. Church IMPACT's expenditure on its November 2008 ballotProposition 8.

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1 recommendations pamphlet, which covered Proposition 8 as just one of 12 measures on the ballot, 2 came to just $2,489.55 (which may be itemized as follows: $75.00 for graphic design/layout, 3 $675.00 for printing, $500 for mailing services, $1,187.24 for postage, and $52.31 for tax). Church 4 IMPACT also posted a ballot recommendation to its website urging a "No" vote on Proposition 8, 5 explaining that notwithstanding the "liturgical issues around same-sex marriage, we can be united in 6 supporting civil marriage as a secular right. No church would be forced to conduct a wedding that is 7 contrary to its beliefs, but no church or individual should be barred from the right to marry if they 8 choose to do so."1 Public records show that Church IMPACT's total revenues for the calendar year 9 2008 were $50,501, and that its net assets came to $4,450. It expended less than $3,000 opposing 10 Proposition 8. 11 7. Amicus curiae The Metropolitan Community Churches ("MCC"), with 43,000

12 adherents and 250 local congregations located in 23 countries around the world, is the largest 13 Christian denomination ministering primarily to lesbians and gays, among others. For almost four 14 decades, MCC has actively worked on behalf of marriage equality as an integral part of its spiritual 15 commitment to social justice. In 1969, MCC clergy performed the first public marriage between 16 persons of the same sex in the United States, and in 1970 MCC filed the first lawsuit seeking legal 17 recognition for marriages between persons of the same sex. Each year, MCC clergy perform 6,000 18 wedding ceremonies for same-sex couples. MCC believes these marriages are recognized and 19 blessed by God and a community of faith, and seeks State recognition of the ceremonies performed 20 at MCC churches. 21 8. Amicus curiae Northern California Nevada Conference United Church of Christ

22 is a manifestation of the Church of Jesus Christ and a constituting body of the United Church of 23 24 25 26
1 How Would Jesus Vote? The California 27 CouncilCalifornia Council of Churches Church IMPACT,2008 State Ballot Propositions. of Churches IMPACT Recommendations for the 28

Christ (UCC). Members of the Conference include 130 local churches in the state of California. Within the state of California the Conference extends from the Oregon border to the southern

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1 borders of Inyo, Tulare, Kings, and Monterey counties. Until Proposition 8 became law, clergy in 2 those churches solemnized legal marriages of same-sex couples in religious rites of marriage. 3 4 5 6 7 the SCNC is to be a united and uniting community of the people of God, covenanting together for mutual support and common mission. Until Proposition 8 became law, clergy in those churches 9. Amicus curiae Southern California Nevada Conference of the United Church of

Christ (SCNC) is a faith community gathered in over 130 diverse congregations. The purpose of

8 solemnized legal marriages of same-sex couples in religious rites of marriage. 9 10. Amicus curiae General Synod of the United Church of Christ is the representative

10 body of the national setting of the United Church of Christ (UCC) and is composed of delegates 11 12 Covenanted Ministries who have been elected by General Synod as described in the Bylaws of the 13 14 UCC, and of ex officio delegates. The UCC was formed in 1957, by the union of the Evangelical chosen by its Conferences from member churches, voting members of Boards of Directors of

15 and Reformed Church and The General Council of the Congregational Christian Churches of 16 the United States in order to express more fully the oneness in Christ of the churches composing it, 17 to make more effective their common witness in Christ, and to serve God's people in the world. The 18 UCC has 5,600 churches in the United States, with more than 200 in California. The General Synod 19 20 21 22 standing in solidarity with those who are marginalized, oppressed, and who suffer under the tyranny of injustice. For more than three decades, the General Synod of the UCC has set a clear course of of the UCC, various settings of the UCC, and its predecessor denominations, have a rich heritage of

23 welcome, inclusion, equality, and justice for lesbian, gay, bisexual, and transgender people. In 1975, 24 the General Synod pronounced its support for the full civil rights of gay and lesbian people. On July 25 4, 2005, the General Synod adopted a resolution affirming equal marriage rights for couples 26 27 28
MOTION FOR LEAVE TO FILE AMICUS CURIAE BRIEF - 09-cv-02292-VRW

regardless of gender and declared that the government should not interfere with couples, regardless

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1 of gender, who choose to marry and share fully and equally in the rights, responsibilities and 2 commitment of legally recognized marriage. 3 4 5 6 7 issues of peace, equality, diversity and justice. Founded in 1999 and with offices in Los Angeles and the San Francisco Bay Area, PJA serves as a vehicle connecting Jews to the critical social justice 11. Amicus curiae Progressive Jewish Alliance (PJA), is a non-profit, California-based

membership organization, with over 4,000 members, which educates, advocates and organizes on

8 issues of the day, to the life of the cities in which they live, and to the Jewish tradition of working for 9 tikkun olam (the repair of the world). As an integral part of its social justice agenda, PJA supports 10 equal access to civil marriage for all. Representing a people who have long known the sting of 11 12 couples. PJA's views on this subject are grounded in the Jewish legal tradition that the law should 13 14 be applied equally to all, citizen and stranger alike. When it comes to officiating at the weddings of marginalization and inferior citizenship, PJA opposes any efforts to discriminate against same-sex

15 same-sex couples, a multiplicity of views exists among and within Jewish denominations, with an 16 emphasis in the Conservative and Reform Movements upon the autonomy of individual rabbis and 17 their congregations.2 18 12. Amicus curiae PARR-the Pacific Association of Reform Rabbis is the Western

19 Region of the Central Conference of American Rabbis ("CCAR"). Dedicated to the principals of 20 Reform Judaism, PARR is the organization of over 350 Reform rabbis in 13 states, 1 province and 21 New Zealand. This includes all of California. It opposed Proposition 8 based on its beliefs and 22 23 24 See Central Conference of American Rabbis, "Resolution on Same Gender Officiation, March 2000," as found at: http://data.ccarnet.org/cgi-bin/resodisp.pl?file=gender&year=2000, 25 accessed on Feb. 3, 2010; and Rabbis Elliot N. Dorff, Daniel S. Nevins and Avram I. Reisner, & Halakhah: A Combined Responsum for the Committee on 26 "Homosexuality, Human Dignity December 2006" The Rabbinical Assembly as found Jewish Law and Standards, at: http://www.rabbinicalassembly.org/teshuvot/docs/20052010/ dorff_nevins_reisner_dignity.pdf 27 accessed on Feb. 3, 2010. 28
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1 resolutions. In 1996 the CCAR endorsed civil marriage for gay people and in 2000 it recognized the 2 right of Reform rabbis to perform religious marriage ceremonies for gay and lesbian Jews. 3 II. 4 ARGUMENT Amici respectfully request leave to file the accompanying amicus curiae brief, which

5 addresses issues raised by the arguments and evidence presented at trial in this case. 6 The Unitarian Universalist Legislative Ministry California (UULM CA); California Faith for

7 Equality, Progressive Jewish Alliance, and California Council of Churches are faith-based 8 organizations that support, and have organized on behalf of, religious freedom and access to civil 9 marriage for same-sex couples. The Northern California Nevada Conference and Southern 10 California Nevada Conference of the United Church of Christ; General Synod of the United Church 11 of Christ; and Universal Fellowship of Metropolitan Community Churches and Unitarian 12 Universalist Association represent faith traditions whose clergy were solemnizing legal marriages for 13 same-sex couples in their California congregations ­ until Proposition 8 passed. The California 14 Council of Churches' membership comprises more than 4,000 of California's Christian 15 congregations from 21 denominations, including both mainstream and progressive Protestant and 16 Orthodox Christian communities, two of which recognize same-sex marriage in their religious rites. 17 The Pacific Association of Reform Rabbis includes rabbis who solemnized legal marriages for same18 sex couples prior to the passing of Proposition 8. The Unitarian Universalist Legislative Ministry 19 Action Network, CA PAC and California Council of Churches Church IMPACT engaged in political 20 lobbying and together spent under $63,000 opposing Proposition 8. 21 Amici are united in believing that Proposition 8 impermissibly seeks to impose anti-

22 homosexual attitudes and doctrines of certain sects. They believe the accompanying brief may be 23 useful to the Court both in evaluating the testimony of Proponents' expert witness, Professor 24 Kenneth P. Miller, in considering the status and relative power in our society of gay and lesbian 25 citizens, and in weighing the religious-liberty interests at stake. 26 27 28
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1 III. 2

CONCLUSION For the foregoing reasons, leave to file the accompanying amicus curiae brief should be

3 granted. 4 DATED: February 3, 2010 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
MOTION FOR LEAVE TO FILE AMICUS CURIAE BRIEF - 09-cv-02292-VRW

Respectfully submitted,

s/ ERIC ALAN ISAACSON ERIC ALAN ISAACSON ERIC ALAN ISAACSON [e-mail] STACEY M. KAPLAN [e-mail] 655 West Broadway, Suite 1900 San Diego, CA 92101 Telephone: [phone] (fax) Attorneys for Amici Curiae Unitarian Universalist Legislative Ministry California; Unitarian Universalist Legislative Ministry Action Network, CA; Unitarian Universalist Association; California Faith for Equality; California Council of Churches; California Council of Churches Church IMPACT; Northern California Nevada Conference of the United Church of Christ; Southern California Nevada Conference of the United Church of Christ; General Synod of the United Church of Christ; Universal Fellowship of Metropolitan Community Churches; Pacific Association of Reform Rabbis; and Progressive Jewish Alliance

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CERTIFICATE OF SERVICE I hereby certify that on February 3, 2010, I electronically filed the foregoing with the Clerk

3 of the Court using the CM/ECF system which will send notification of such filing to the e-mail 4 addresses denoted on the attached Electronic Mail Notice List, and I hereby certify that I have 5 mailed the foregoing document or paper via the United States Postal Service to the non-CM/ECF 6 participants indicated on the attached Manual Notice List. 7 I certify under penalty of perjury under the laws of the United States of America that the

8 foregoing is true and correct. Executed on February 3, 2010. 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 s/ ERIC ALAN ISAACSON ERIC ALAN ISAACSON 655 West Broadway, Suite 1900 San Diego, CA 92101-3301 Telephone: [phone] (fax) E-mail: [e-mail]

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Mailing Information for a Case 3:09-cv-02292-VRW
Electronic Mail Notice List
The following are those who are currently on the list to receive e-mail notices for this case. College of Pediatricians [e-mail]
American

C. Baxter [e-mail]
Rosanne

Brianna Bernstein [e-mail],[e-mail]
Erin

J. Bettan [e-mail]
Richard

of Supervisors of Imperial County [e-mail]
Board

V. Bomse [e-mail],[e-mail],[e-mail],[e-mail]
Stephen

Bopp , Jr [e-mail]
James

Lynn Borelli [e-mail]
Tara

J. Boutrous , Jr [e-mail],[e-mail]
Theodore

J. Brosnahan [e-mail],[e-mail]
James

E. Bunim [e-mail]
David

R. Burke [e-mail],[e-mail]
Thomas

Bruce Burns [e-mail],[e-mail]
Gordon

A Campbell [e-mail],[e-mail]
James

L Carmichael [e-mail]
Holly

D Chandler [e-mail],[e-mail]
Timothy

Ricardo Chavez-Ochoa [e-mail]
Brian

Yeh Chou [e-mail],[e-mail]
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Mark

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Charles J. Cooper [e-mail],[e-mail],[e-mail]

of Imperial of the State of California [e-mail]
County

Warren Davidson [e-mail]
Jon

D. Dettmer [e-mail],[e-mail],[e-mail]
Ethan

Dean Dusseault [e-mail]
Christopher

Dixon Esseks [e-mail]
James Ethics

and Religious Liberty Commission of the Southern Baptist Convention [e-mail]

P. Flynn [e-mail],[e-mail]
Ronald

L Garlow [e-mail]
James

O. Gill [e-mail],[e-mail]
Elizabeth

Michael Goldman [e-mail],[e-mail],[e-mail]
Jeremy

John Gorman [e-mail],[e-mail]
Patrick

Grant [e-mail],[e-mail],[e-mail],[e-mail]
Eric

for Marriage and Public Policy [e-mail]
Institute

Franklin Kolm [e-mail],[e-mail],[e-mail],[e-mail]
Claude

A Kramer [e-mail],[e-mail]
Leslie

S LiMandri [e-mail]
Charles

Salvatore LiMandri [e-mail],[e-mail]
Charles

L. Llewellyn , Jr [e-mail]
David

W. Lorence [e-mail],[e-mail]
Jordan

Francisco Martinez [e-mail]
Manuel

Elizabeth McAlister [e-mail]
Mary Michael

James McDermott

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[e-mail] Dempsey McGill [e-mail]
Matthew

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McPherson [e-mail]
Miles

C. Mennemeier [e-mail],[e-mail],[e-mail],[e-mail],[e-mail]
Kenneth

Minter [e-mail]
Shannon

Antonio Monagas [e-mail],[e-mail],[e-mail]
Enrique

Lynn Monk [e-mail]
Jennifer

Hector Moreno , Jr [e-mail]
Jose

Center for Lesbian Rights [e-mail]
National

C. Nielson , Jr [e-mail]
Howard

R. Nimocks [e-mail]
Austin

B Olson [e-mail]
Theodore

Pachter [e-mail]
Tamar

Michael Panuccio [e-mail]
Jesse

A. Patterson [e-mail]
Peter

Elizabeth Piepmeier [e-mail],[e-mail],[e-mail]
Sarah

Carol Pizer [e-mail]
Jennifer

Perry Pugno [e-mail]
Andrew

W Raum [e-mail],[e-mail],[e-mail]
Brian

Cary Roth [e-mail],[e-mail]
Jerome

Schiller [e-mail]
Josh

Lawrence Schlosser [e-mail]
Alan

James Schweickert [e-mail]
Christopher

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Kevin Trent Snider [e-mail]

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Francis Stoll [e-mail]
Christopher

Walter Stroud [e-mail],[e-mail]
Andrew

Cameron Tayrani [e-mail]
Amir

Becket Fund for Religious Liberty [e-mail]
The

Christine Thompson [e-mail]
Angela

H. Thompson [e-mail],[e-mail]
David

Lee Thompson [e-mail]
Terry

Margaret Turner [e-mail],[e-mail]
Ilona

Henry Tyler [e-mail],[e-mail],[e-mail]
Robert

Hideyuki Uno [e-mail],[e-mail],[e-mail],[e-mail],[e-mail]
Theodore

Van Aken [e-mail],[e-mail],[e-mail],[e-mail],[e-mail]
Christine

Vargas [e-mail]
Isabel

Whitehurst [e-mail],[e-mail]
Judy

Manual Notice List
The following is the list of attorneys who are not on the list to receive e-mail notices for this case (who therefore require manual noticing). You may wish to use your mouse to select and copy this list into your word processing program in order to create notices or labels for these recipients.
David Boies Boies Schiller & Flexner LLP 333 Main Street Armonk, NY 10504 Thomas Brejcha Thomas More Society 29 S. La Salle Suite 440 Chicago, IL 60603 Richard E. Coleson 1 South 6th Street Terre Haute, IN 47807-3510 Christopher M. Gacek Family Research Council 801 G Street NW Washington, DC 20001 Kevin James Hasson 1350 Connecticut Avenue, NW

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Suite 605 Washington, DC 20036-1735 Theane Evangelis Kapur Gibson Dunn & Crutcher LLP 333 South Grand Avenue Los Angeles, CA 90071 Michael W. Kirk Cooper & Kirk, PLLC 1523 New Hampshire Avenue, NW Washington, DC 2003 Rena M Lindevaldsen Liberty Counsel 100 Mountainview Rd, Ste 2775 Lynchberg, VA 24502 Paul Benjamin Linton 921 Keystone Avenue Northbrook, IL 60062 Vincent P. McCarthy W. Chestnut Hill Road Lichfield, CT 06759 Michael James McDermott 7172 Regional #329 Dublin , CA 94568 National Legal Foundation P.O. Box 64427 Virginia Beach, VA 23467-4427 Kaylan L. Phillips 1 South 6th Street Terre Haute, IN 47807-3510 Tobias Barrington Wolff University of Pennsylvania Law School 3400 Chestnut Street Philadelphia, PA 19104-6204

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