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Jordan W. Lorence, VA Bar No. 33655M. Casey Mattox, VA Bar No. 47148ALLIANCE DEFENDING FREEDOM801 G Street N.W., Suite 509Washington, D.C. 20001

Tel: (202) 393-8690Fax: (480) [email protected]@alliancedefendingfreedom.org

Byron J. Babione,* AZ Bar No. 024320Kenneth J. Connelly,* AZ Bar No. 025420J. Caleb C. Dalton, VA Bar No. 83790ALLIANCE DEFENDING FREEDOM15100 N 90th StreetScottsdale, Arizona 85260

Tel: (480) 444-0020Fax: (480) [email protected]@[email protected]*Pro Hac Vice Applications pending

Counsel for Intervenor-Defendant

UNITED STATES DISTRICT COURT FOR THE

EASTERN DISTRICT OF VIRGINIA NORFOLK DIVISION

TIMOTHY B. BOSTIC, et al.,

Plaintiffs,

v.

JANET M. RAINEY, in her official capacityas State Registrar of Vital Records, et al.,

Defendants,

andMICHLE B. MCQUIGG, in her officialcapacity as Prince William County Clerk ofCircuit Court,

Proposed Intervenor-Defendant.

Civil Action No. 2:13-cv-395

MOTION TO INTERVENE

Case 2:13-cv-00395-AWA-LRL Document 72 Filed 12/20/13 Page 1 of 5 PageID# 619

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Proposed Intervenor-Defendant, Michle B. McQuigg, in her official capacity as Prince

William County Clerk of Circuit Court (hereinafter Proposed Intervenor McQuigg), by and

through her undersigned counsel, and pursuant to Rule 24(a)(2), or alternatively, Rule 24(b) of

the Federal Rules of Civil Procedure, and Rule 7 of the Rules of Practice and Procedure of the

United States District Court for the Eastern District of Virginia, files this Motion to Intervene of

Right, or in the Alternative, for Permissive Intervention (Motion), as defendant in this action.

In support of this Motion, Proposed Intervenor McQuigg sets forth that:

1. This motion is timely and will not prejudice the interests of the other parties.2.

Proposed Intervenor McQuigg seeks to intervene as Intervenor-Defendant to

oppose Plaintiffs and be conferred all of the rights of a party to participate fully in all aspects of

the above-captioned case.

3. Intervention by Proposed Intervenor McQuigg in this matter is necessary becauseshe has significant, distinct interests in this litigation and her ability to protect such interests may

be impaired by the disposition of this case.

4. Counsel for Defendant Rainey has consented to the Motion. Counsel forDefendant Schaefer has stated that he has no objection to the Motion. Counsel for Plaintiffs are

opposed to the Motion.

5. In support of this Motion, Proposed Intervenor McQuigg relies on the Declarationof Proposed Intervenor-Defendant, Prince William County Clerk of Circuit Court Michle B.

McQuigg, and Proposed Intervenor-Defendants Memorandum of Law filed contemporaneously

herewith.


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Respectfully submitted this the 20th day of December, 2013.

By: /s/

M. Casey Mattox, VA Bar No. 47148ALLIANCE DEFENDING FREEDOM801 G Street N.W., Suite 509Washington, D.C. 20001Tel: (202) 393-8690Fax: (480) [email protected]

Counsel for Intervenor-DefendantJordan W. Lorence, VA Bar No. 33655ALLIANCE DEFENDING FREEDOM

801 G Street N.W., Suite 509Washington, D.C. 20001Tel: (202) 393-8690Fax: (480) [email protected]

Byron J. Babione,* AZ Bar No. 024320Kenneth J. Connelly,* AZ Bar No. 025420J. Caleb C. Dalton, VA Bar No. 83790ALLIANCE DEFENDING FREEDOM15100 N 90th Street

Scottsdale, Arizona 85260Tel: (480) 444-0020Fax: (480) [email protected]@[email protected]*Pro Hac Vice Applications pending



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CERTIFICATE OF SERVICE

I hereby certify that on December 20, 2013, I will electronically file the foregoing

document with the Clerk of Court using the CM/ECF system, which will then send a notification

of such filing (NEF) to the following participants:

David B. [email protected] F. Brooke, Esq.Poole Mahoney PC860 Greenbrier Circle, Suite 401Chesapeake, VA 23320

Attorneys for Defendant George E. Schaefer, III

Earle Duncan Getchell, [email protected] of the Attorney General900 E Main StRichmond, VA 23219

Attorney for Defendant Janet M. Rainey

Thomas B. [email protected] E. [email protected] B. [email protected] Mitchell [email protected] C. [email protected], Ruloff, Swain, Haddad &Morecock, P.C.4525 South Blvd., Suite 300Virginia Beach, VA 23452

Joshua Seth [email protected], Dunn & Crutcher LLP555 Mission St., Suite 3000San Francisco, CA 94105-0921

Robert Brian [email protected] I. [email protected], Schiller & Flexner LLP575 Lexington Ave., 7th FloorNew York, NY 10022

Chantale [email protected] C [email protected] B [email protected] D [email protected] Dunn & Crutcher LLP1050 Connecticut Ave, NWWashington, DC 20036-5306

David [email protected], Schiller & Flexner, LLP333 Main St.Armonk, NY 10504

Jeremy Michael [email protected], Schiller & Flexner LLP1999 Harrison St., Suite 900Oakland, CA 94612


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Theodore J Boutrous, [email protected], Dunn & Crutcher LLP (CANA)333 South Grand Ave.Los Angeles, CA 90071-3197

William [email protected], Schiller & Flexner5301 Wisconsin Ave, NWWashington, DC 20015

Attorneys for Plaintiffs

/s/




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UNITED STATES DISTRICT COURT FOR THEEASTERN DISTRICT OF VIRGINIA NORFOLK DIVISION


Plaintiffs,

v.


Defendants,

and

MICHLE B. MCQUIGG, in her officialcapacity as Prince William County Clerk ofCircuit Court,



DECLARATION OF MICHLE B.MCQUIGG IN SUPPORT OF MOTIONTO INTERVENE

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I, Michle B. McQuigg, swear to the following facts under the penalty of perjury:

1. I have been the Clerk of Circuit Court in Prince William County, Virginia since2008. By statute, my position and official responsibilities include enforcing Virginias Marriage

Laws. Specifically, my duties include ensuring that applicants for marriage licenses meet all the

statutory and constitutional requirements for marriage under state lawonly then am I legally

permitted to issue marriage licenses to prospective applicants.

2. As the Prince William County Circuit Court Clerk, an elected and independentconstitutional officer, I have significantly protectable interests that may be impaired in the

pending litigation, and that those interests will not be adequately represented by any other partydefendant.

3. I do not believe that State Registrar of Vital Records Janet M. Rainey willadequately represent my interests going forward. The incoming Attorney General, Mark

Herring, who will be continuing the representation of Registrar Rainey, has explicitly stated that

he would work to change Virginias Marriage Laws. Given this statement, it is doubtful whether

he will provide a zealous defense of Virginias Marriage Laws, or whether he will appeal any

ruling adverse to those laws.

4. Nor do I believe that Clerk of Court for Norfolk Circuit Court George E.Schaefer, III, will adequately represent my interests. While Clerk Schaefer has raised pertinent

issues, and has asserted some of the compelling and legitimate government interests furthered by

Virginias Marriage Laws in his brief, he neither raised all the interests and arguments previously

upheld by other courts, nor extensively developed or explained the asserted interests, as I would

have done. This creates the reasonable prospect that even if Clerk Schaefer were to appeal an


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adverse ruling, he would not as zealously and comprehensively defend Virginia s Marriage Lawsas I would to protect my interests as the Prince William County Circuit ourt Clerk.

5 I am concerned that a statewide injunction against the enforcement of Virginia sMarriage Laws without my involvement as a party defendant would create significant confusionand uncertainty for me in the performance of my legal duties regarding marriage. t is unclear tome whether, in such a situation, 1 would have a duty to follow Virg inia s Marriage Laws or tofollow the ruling of this Court. Such confusion and uncertainty would materially disrupt andimpede the performance ofmy official duties relating to marriage.

I declare under penalty of perjury, under the laws of the Commonwealth of Virginia andunder the laws of the United States of America, that the foregoing facts are true and correct.

Dated: December1 2013

3


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UNITED STATES DISTRICT COURT FOR THEEASTERN DISTRICT OF VIRGINIA NORFOLK DIVISION


Plaintiffs,

v.


Defendants,




PROPOSED ANSWER ANDAFFIRMATIVE DEFENSES OFINTERVENOR-DEFENDANTMICHLE B. MCQUIGG


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ANSWER AND AFFIRMATIVE DEFENSES

COMES NOW, Proposed Intervenor-Defendant, Michle B. McQuigg, in her official

capacity as Prince William County Clerk of Circuit Court (hereinafter Proposed Intervenor

McQuigg), by counsel, and files her Answer and Affirmative Defenses to Plaintiffs First

Amended Complaint for Declaratory, Injunctive and Other Relief as follows:

ANSWER TO COMPLAINT

1. Plaintiffs cite numerous marriage cases in Paragraph 1. These cases speak forthemselves and require no response. All remaining allegations of Paragraph 1 are DENIED.

2. The cases, Va. Const. Art. I, 15-A, and Va. Code 20-45.2, 20-45-3(collectively referred to as Virginias Marriage Laws) cited by Plaintiffs in Paragraph 2 speak

for themselves and require no response. All remaining allegations of Paragraph 2 are DENIED.

3. The Virginia marriage statute cited by Plaintiffs speaks for itself and requires noresponse. All remaining allegations of paragraph 3 are DENIED.

4. Proposed Intervenor McQuigg DENIES that Plaintiffs are entitled to the reliefthey request in Paragraph 4. All remaining allegations are DENIED.

JURISDICTION AND VENUE

5. Plaintiffs advance federal constitutional claims, but Proposed IntervenorMcQuigg DENIES that they are entitled to any of the relief they seek.

6. Proposed Intervenor McQuigg ADMITS that venue is proper in this Court.7. Proposed Intervenor McQuigg ADMITS that Plaintiffs have brought this suit

pursuant to 42 U.S.C. 1983 and that they seek declaratory and injunctive relief from Virginias

Marriage Laws, but DENIES that Plaintiffs are entitled to any of the relief requested in

Paragraph 7.


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8. Proposed Intervenor McQuigg is without knowledge or information sufficient toadmit or deny the allegations personal to Plaintiffs in Paragraph 8, and thus the allegations in

their entirety are DENIED. The legal conclusions advanced by Plaintiffs require no response,

but to the extent a response is required they are DENIED in their entirety.

9. Proposed Intervenor McQuigg is without knowledge or information sufficient toadmit or deny the allegations personal to Plaintiffs in Paragraph 9, and thus the allegations in

their entirety are DENIED. The legal conclusions advanced by Plaintiffs require no response,

but to the extent a response is required they are DENIED in their entirety.

10.

Proposed Intervenor McQuigg ADMITS that Plaintiffs have brought this suitpursuant to 42 U.S.C. 1983, that they seek declaratory and injunctive relief from Virginias

Marriage Laws, and that they seek to recover attorneys fees, costs, and expenses, but DENIES

that Plaintiffs are entitled to any of the relief whatsoever.

11. Proposed Intervenor McQuigg is without knowledge or information sufficient toadmit or deny the allegations in Paragraph 11, and thus the allegations in their entirety are

DENIED.


DENIED.


DENIED.


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DENIED.

15. The laws applicable to Defendant Schaefer speak for themselves and require noresponse. The legal conclusions asserted by Plaintiffs in Paragraph 15 similarly require no

response. Proposed Intervenor McQuigg ADMITS that Defendant Schaefer is the Clerk of the

Circuit Court for the City of Norfolk. All other remaining allegations in Paragraph 15 are

DENIED.

16.

The laws applicable to Defendant Rainey speak for themselves and require noresponse. The legal conclusions asserted by Plaintiffs in Paragraph 16 similarly require no

response. Proposed Intervenor McQuigg ADMITS that Defendant Rainey is the State Registrar

of Vital Records. All other remaining allegations in Paragraph 16 are DENIED.

17. Proposed Intervenor McQuigg ADMITS that she, along with those under hersupervision, direction, or control, is bound by Virginia law in the performance of her official

duties, and states that upon information and belief that Defendants Rainey and Schaefer are also

so obligated. The remaining legal conclusions and the statement of relief asserted by Plaintiffs

require no response. All other allegations are DENIED.


DENIED.

19. The Virginia Marriage Laws cited by Plaintiffs in Paragraph 19 speak forthemselves and require no response. To the extent Plaintiffs draw legal conclusions from those

laws, no response is required. Similarly, Plaintiffs assertions based on United States v. Windsor,


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133 S. Ct. 2675 (2013), are legal conclusions and thus require no response. All remaining

allegations in Paragraph 19 are DENIED.

20. The Virginia Marriage Laws cited by Plaintiffs in Paragraph 20 speak forthemselves and require no response. All remaining allegations in Paragraph 20 are DENIED.

21. The conclusions of law proffered by Plaintiffs in Paragraph 21 require noresponse. Proposed Intervenor McQuigg is without knowledge or information sufficient to admit

or deny the allegations asserted Paragraph 21 regarding federal marital privileges and benefits,

and thus those allegations are DENIED. All remaining allegations are DENIED.

22.

The Virginia Marriage laws cited by Plaintiffs, along with United States v.

Windsor, speak for themselves and require no response. To the extent legal conclusions are

proffered by Plaintiffs, these too require no response. Proposed Intervenor McQuigg is without

knowledge or information sufficient to admit or deny the remaining allegations asserted in

Paragraph 22, and thus those allegations are DENIED.

23. The Virginia Marriage laws cited by Plaintiffs, along with United States v.Windsor, speak for themselves and require no response. To the extent legal conclusions are

proffered by Plaintiffs, these too require no response. All remaining allegations asserted in

Paragraph 23 are DENIED.

24. The legal conclusions contained in Paragraph 24 require no response, and theVirginia Marriage Laws cited by Plaintiffs speak for themselves. All remaining allegations in

Paragraph 24 are DENIED.


DENIED.


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DENIED.

27. Proposed Intervenor McQuigg is without knowledge or information sufficient toadmit or deny the allegations personal to plaintiffs, including the ability of Plaintiffs Bostic and

London to marry each other, and thus these allegations are DENIED in their entirety. The legal

conclusions asserted by Plaintiffs in Paragraph 27 require no response, but to the extent any

response is required, those allegations are DENIED.

28.

Proposed Intervenor McQuigg is without knowledge or information sufficient toadmit or deny the allegations in Paragraph 28, and thus the allegations in their entirety are

DENIED.


DENIED.

30. The laws referenced by Plaintiffs speak for themselves and require no response.Proposed Intervenor McQuigg is without knowledge or information sufficient to admit or deny

the remaining allegations in Paragraph 30, and thus the allegations in their entirety are DENIED.


DENIED.




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34. The legal conclusions asserted by Plaintiffs require no response. ProposedIntervenor McQuigg is without knowledge or information sufficient to admit or deny the

remaining allegations in Paragraph 34, and thus the allegations in their entirety are DENIED.

35. The legal conclusions asserted by Plaintiffs require no response. ProposedIntervenor McQuigg is without knowledge or information sufficient to admit or deny the

remaining allegations in Paragraph 35, and thus the allegations in their entirety are DENIED.Proposed Intervenor McQuigg expressly DENIES that Plaintiffs are entitled to any of the relief

they seek.

COUNT 1DUE PROCESS

36. Proposed Intervenor McQuigg incorporates here by reference Paragraphs 1through 35 as if fully set forth herein.

37. Proposed Intervenor McQuigg DENIES the allegations in Paragraph 37.38. Proposed Intervenor McQuigg DENIES the allegations in Paragraph 38.39. Proposed Intervenor McQuigg DENIES the allegations in Paragraph 39.

COUNT IIEQUAL PROTECTION


41. Proposed Intervenor McQuigg DENIES the allegations in Paragraph 41.


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42. The Virginia Marriage Laws cited by Plaintiffs speak for themselves, and thelegal conclusions asserted by Plaintiffs require no response. To the extent a response is required,

all allegations in Paragraph 42 are DENIED.

43. The Virginia Marriage Laws cited by plaintiffs speak for themselves, and thelegal conclusions asserted by Plaintiffs require no response. To the extent a response is required,



all allegations in Paragraph 44 are DENIED.45. The Virginia Marriage Laws cited by plaintiffs speak for themselves, and the

legal conclusions asserted by Plaintiffs require no response. To the extent a response is required,






COUNT IIIVIOLATION OF 42 U.S.C. 1983



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IRREPARABLE INJURY


51. Proposed Intervenor McQuigg is without knowledge or information sufficient toadmit or deny the allegations in Paragraph 51 regarding benefit entitlements, and thus those

allegations are DENIED. The Virginia Marriage Laws cited by Plaintiffs speak for themselves,and the legal conclusions asserted by Plaintiffs require no response. To the extent a response is

required, all allegations in Paragraph 51 are DENIED.

52. Proposed Intervenor McQuigg DENIES the allegations in Paragraph 52.53. Proposed Intervenor McQuigg DENIES that Plaintiffs are entitled to any relief on

any asserted theory.

54. All allegations not expressly admitted are DENIED.AFFIRMATIVE DEFENSES

1. Plaintiffs fail to state a claim upon which relief can be granted.2. Plaintiffs claims are barred by the Tenth Amendment.3. Proposed Intervenor McQuigg is entitled to absolute and qualified immunity.4. Some or all Plaintiffs lack standing to assert the claims presented in the

Complaint.

5. Some or all of Plaintiffs claims are not ripe for judicial determination by thisCourt.


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Wherefore, Proposed Intervenor McQuigg, in her official capacity as Clerk of the Court

for Prince William County, Virginia, respectfully requests that Plaintiffs Amended Complaint

be dismissed with prejudice, that she be awarded costs and attorneys fees in this matter, and that

she be awarded such further relief as is deemed necessary and just.


By: /s/M. Casey Mattox, VA Bar No. 47148ALLIANCE DEFENDING FREEDOM801 G Street N.W., Suite 509

Washington, D.C. 20001Tel: (202) 393-8690Fax: (480) [email protected]

Counsel for Intervenor-DefendantJordan W. Lorence, VA Bar No. 33655ALLIANCE DEFENDING FREEDOM801 G Street N.W., Suite 509Washington, D.C. 20001Tel: (202) 393-8690

Fax: (480) [email protected]

Byron J. Babione,* AZ Bar No. 024320Kenneth J. Connelly,* AZ Bar No. 025420J. Caleb C. Dalton, VA Bar No. 83790ALLIANCE DEFENDING FREEDOM15100 N 90th StreetScottsdale, Arizona 85260Tel: (480) 444-0020Fax: (480) [email protected]@[email protected]*Pro Hac Vice Applications pending



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/s/




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Plaintiffs,

v.


Defendants,




PROPOSED INTERVENORS MOTION

FOR SUMMARY JUDGMENT AND

RESPONSE IN OPPOSITION TO

PLAINTIFFS MOTION FOR SUMMARY

JUDGMENT


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MOTION FOR SUMMARY JUDGMENT

COMES NOW Proposed Intervenor-Defendant, Michle B. McQuigg, in her official

capacity as Prince William County Clerk of Circuit Court (hereinafter Proposed Intervenor

McQuigg), by and through her undersigned counsel, and respectfully moves for summary

judgment pursuant to Federal Rule of Civil Procedure 56. For the reasons set forth below, she

requests that this Court grant this Motion for Summary Judgment and dismiss with prejudice all

claims in Plaintiffs Amended Complaint.

MEMORANDUM IN SUPPORT OF MOTION FOR SUMMARY JUDGMENT

In the interests of judicial economy, Proposed Intervenor McQuigg hereby incorporatesand adopts the arguments proffered by the defendants in their Memoranda in Support of Motions

for Summary Judgment (Dkt. No. 41 & Dkt. No. 44), their Memoranda in Opposition to

Plaintiffs Motion for Summary Judgment (Dkt. No. 57 & Dkt. No. 58), and Registrar Raineys

Reply to Plaintiffs Response to Motion for Summary Judgment (Dkt. No. 65). These briefs

establish that Plaintiffs are not entitled to any of the relief they seek, and Proposed Intervenor

McQuigg therefore respectfully requests that this Court dismiss Plaintiffs action with prejudice.


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By: /s/








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/s/




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Plaintiffs,

v.


Defendants,

and

MICHLE B. MCQUIGG, in her officialcapacity as Prince William County Clerk ofCircuit Court,



REQUEST FOR HEARING


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PLEASE TAKE NOTICE that Proposed Intervenor-Defendant, Michle B. McQuigg,

requests that this Honorable Court schedule a hearing dateeither separately or at a time at

which this Court has already established a hearing date in this matteron which Proposed

Intervenor-Defendant may move this Court for entry of an Order granting Proposed Intervenor-

Defendants Motion to Intervene.

At the direction of the Clerk, Proposed Intervenor has attached the Pro Hac Vice

Applications of Byron J. Babione and Kenneth J. Connelly to the Motion to Intervene. Proposed

Intervenor requests that the Court permit the filing of these Applications and payment of required

fees and act on them in time for any scheduled hearing on this motion. In the alternative,Proposed Intervenor requests the Court deem the Pro Hac Vice applicants admitted upon the

payment of the required fees in time for any scheduled hearing on this motion.


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By: /s/








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/s/




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IN THE UNITED STATES DISTRICT COURTFOR THE EASTERN DISTRICT OF VIRGINIA

IQ esetForm Print Form

APPLICATION TO QUALIFY AS A FOREIGN ATTORNEY UNDER LOCAL CIVIL RULE 83.1(D) AND LOCALCRIMINAL RULE 57.4In Case Number 2:1 3-cv-395 , Case Name Bostic v. RaineyParty Represented by Applicant: _ln_t_erv_en_o_r_ D_e_fe_n_d_a_nt

To: The Honorable Judges of the United States District Court for the Eastern District of VirginiaPERSONAL STATEMENT

FULL NAME (no initials, please) _B _y_o_n_J_e_f_o_d_s_B_a_b_o_n_______________________ _____________________________Bar Identification Number 024320 State AZ=Firm Name Alliance Defending FreedomFirm Phone 480-444-0020 Direct Dial 480-388-8038 FAX 480-444-0028~ ~ ~ ~E-Mail Address [email protected] ailing Address 15100 N 90th Street, Scottsdale, AZ 85260Name(s) offederal court(s) in which I have been admitted _S_ee _tt_a_c_h_e_d.________________________________________ _I certify that the rules of the federal cour t in the district in which I maintain my office extend a similar pro hac vice admissionprivilege to members of the bar of the Eastern District of Virginia.I have not been reprimanded in any court nor has there been any action in any court pertaining to my conduct or fitness as amember of the bar.I hereby certify that, within ninety (90) days before the submission of this application, I have read the Local Rules of this Courtand that my knowledge of the Federal Rules of Civil Procedure, the Federal Rules of Criminal Procedure, and the Federal Rules oEvidence is current.

I, the undersigned, do certify that I am a member of the bar of this Court, not related to the ap cant; that I know the applicantpersonally, that the said applicant possesses all of the qualifications required for admission to the bar of this Court; that I haveexamined the applicant s personal statement. I affirm that his/her personal and professional character and standing are good, andpetition the court to admit the applicant pro hac vice

s/M. Casey Mattox t J - f ~ L 3(DateSignature)M Casey Mattox 47148(Trped or Printed Name) (VA Bar Number)

Court Use Only:Clerk's Fee Paid _______ or Exemption Granted _______The motion for admission is GRANTED or DENIED _______

(Judge s Signature) (Date)


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BYRON J. BABIONE

FEDERAL COURT ADMISSIONS

FEDERAL COURT DATE ADMITTED

District Court for the Eastern District of Virginia ..................................................... April 29, 1994

District Court for the Northern District of New York ............................................. January 9, 1998

District Court for the Western District of New York ................................................... May 6, 2002

District Court for the Eastern District of Michigan ............................................... January 12, 2007

District Court of Arizona ........................................................................................... April 30, 2007

United States Court of Appeals for the 4th Circuit .............................................. November 2, 1993

United States Court of Appeals for the 2nd Circuit ................................................... April 11, 2003

United States Court of Appeals for the 9th Circuit ................................................ February 8, 2005

United States Court of Appeals for the 6th Circuit .................................................... March 7, 2007

United States Court of Appeals for the 10thCircuit .................................................... April 1, 2008

United States Court of Appeals for the 1stCircuit .................................................. August 18, 2010

Supreme Court of the United States....................................................................... January 24, 2011


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IN THE UNITED STATES DISTRICT COURTFOR THE EASTERN DISTRICT OF VIRGINIA

Reset Form l Print Form

APPLICATION TO QUALIFY AS A FOREIGN ATTORNEY UNDER LOCAL CIVIL RULE 83.l D) AND LOCALCRIMINAL RULE 57.4

In Case Number 2:13-cv-395 , Case Name Bostic v. RaineyParty Represented by Applicant: _ l n _ t _ e r v ~ e n _ o _ r _ - D _ e _ f e _ n _ d _ a _ n t ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ -

To: The Honorable Judges of the United States District Court for the Eastern District of VirginiaPERSONAL STATEMENT

FULL NAME (no initials, please) ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~Bar Identification Number 025420 State AZ = ~ ~ ~ ~Firm Name Alliance Defending FreedomFirm Phone 480-444-0020 Direct Dial , _ 4 8 0 - - - 3 8 : : : . : : 8 < . . : - 8 , . , 0 - 1 - - 3 ~ ~ ~ ~ ~ ~ - FAX 480-444-0028E-Mail Address [email protected] ailing Address 15100 N 90th Street, Scottsdale, AZ 85260Name(s) of federal court(s) in which I have been admitted : : : : - = - = : _ ~ ~ ~ ~ ~ ~I certify that the rules of the federal court in the district in which I maintain my office extend a similar pro hac vice admissionprivilege to members of the bar of the Eastern District of Virginia.I have not been reprimanded in any court nor has there been any action in any court pertaining to my conduct or fitness as amember of the bar.I hereby certify that, within ninety (90) days before the submission of this application, I have read the Local Rules of this Courtand that my knowledge of the Federal Rules of Civil Procedure, the Federal Rules of Criminal Procedure, and the Federal Rules oEvidence is current.I am am a full-time employee of the United States of America, and if so, request exemption from the admission fee.

A p p l i ~ )I, the undersigned, do certify that I am a member of the bar of this Court, not related to the applicant; that I know the applicantpersonally, that the said applicant possesses all of the qualifications required for admission to the bar of this Court; that I haveexamined the appl icant's personal statement. I affirm that his/her personal and professional character and standing are good, andpetition the court to admit the applicant pro hac vice

s/M. Casey Mattox(Signature)M Casey Mattox

(Txped or Printed Name)Court Use Only:Clerk's Fee P a i d or Exemption r a n t e d ~ ~ ~The motion for admission is GRANTED ~ ~ o r E N I E

(Judge 's Signature) (Date)

-11{(Date)47148(VA Bar Number)


2:13-cv-00395 #72

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