Motion Of The America First Policy Institute

Source document: Motion Of The America First Policy Institute; document type: Motion for Leave to File Brief Amicus Curiae.

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UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF TEXAS
FORT WORTH DIVISION

U.S. NAVY SEALs 1-26;

U.S. NAVY SPECIAL WARFARE
COMBATANT CRAFT CREWMAN 1-5;

U.S. NAVY EXPLOSIVE ORDNANCE
DISPOSAL TECHNICIAN 1; and

U.S. NAVY DIVERS 1-3,

Plaintiffs,

v.

JOSEPH R. BIDEN, JR., in his official
capacity as President of the United States of
America; LLOYD J. AUSTIN, III,
individually and in his official capacity as
United States Secretary of Defense;
UNITED STATES DEPARTMENT OF
DEFENSE; CARLOS DEL TORO,
individually and in his official capacity as
United States Secretary of the Navy,

Defendants.
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Civil Action No. 4:21-cv-01236-O

MOTION OF THE AMERICA FIRST POLICY INSTITUTE
FOR LEAVE TO FILE BRIEF AMICUS CURIAE
In accordance with Local Rule 7.2(b), the America First Policy Institute (“AFPI”)
respectfully moves for leave to appear as amicus curiae for the purpose of filing the attached
brief supporting Plaintiffs.
As explained in the attached brief, AFPI “is a 501(c)(3) non-profit, non-partisan research
institute. AFPI exists to conduct research and develop policies that put the American people first.
Our guiding principles are liberty, free enterprise, national greatness, American military
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superiority, foreign-policy engagement in the American interest, and the primacy of American
workers,
families,
and
communities
in
all
we
do.”
AFPI,
About,
https://americafirstpolicy.com/about/ (last visited Nov. 21, 2021).
AFPI consists of many former senior leaders of the United States government. Lieutenant
General Keith Kellogg, United States Army (Retired), serves as AFPI’s Co-Chairman of the
Center for American Security and previously served as the National Security Advisor to former
Vice President Mike Pence and Chief of Staff and Executive Secretary of the National Security
Council. The Honorable John Ratcliffe serves as Co-Chairman of the Center for American
Security and previously served as the sixth Director of National Intelligence. Dr. Jacob Olidort is
Director of the Center for American Security and recently served in the Office of the Vice
President.
Amicus seeks to bring this experience and expertise to bear in assisting this Court in
resolving the question before it of whether religious servicemembers should be forced to violate
their deeply-held religious beliefs or face punitive or involuntary administrative separation. In
particular, amicus seeks to illuminate the negative effects on American national security of a
ruling against Plaintiffs.
In accordance with Local Rules 7.1(a) and 7.1(c), amicus certifies that it has been able to
confer with attorneys for Plaintiffs but has not been able to confer with attorneys for Defendants
regarding the relief requested in this motion, as a docket search shows that attorneys for
Defendants have not yet made an appearance in this matter. Plaintiffs consent to the filing of this
brief.

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Respectfully submitted this 22nd day of November, 2021.

/s/ Jessica Hart Steinmann
Pamela Jo Bondi
Florida Bar Number 0886440*
Jessica Hart Steinmann
Texas Bar Number 24067647
James Baehr
Louisiana Bar Number 35431*
Joshua J. Campbell
Georgia Bar Number 720007*
Rachel Jag
Missouri Bar Number 70674*
1635 Rogers Road
Fort Worth, TX 76107
(571) 348-1802
jsteinmann@americafirstpolicy.com
jbaehr@americafirstpolicy.com
jcampbell@americafirstpolicy.com
rjag@americafirstpolicy.com
Attorneys for Amicus Curiae

* Application to be Admitted/Admitted Pro
Hac Vice Forthcoming

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CERTIFICATE OF SERVICE
I hereby certify that on November 22, 2021, this Motion of the America First Policy
Institute for Leave to File Brief Amicus Curiae was filed through the Electronic Court Filing
system and will be sent electronically to all parties as identified in the Notice of Electronic
Filing.
/s/ Jessica Hart Steinmann
Pamela Jo Bondi
Florida Bar Number 0886440*
Jessica Hart Steinmann
Texas Bar Number 24067647
James Baehr
Louisiana Bar Number 35431*
Joshua J. Campbell
Georgia Bar Number 720007*
Rachel Jag
Missouri Bar Number 70674*
1635 Rogers Road
Fort Worth, TX 76107
(571) 348-1802
jsteinmann@americafirstpolicy.com
jbaehr@americafirstpolicy.com
jcampbell@americafirstpolicy.com
rjag@americafirstpolicy.com
Attorneys for Amicus Curiae

* Application to be Admitted/Admitted Pro
Hac Vice Forthcoming
Case 4:21-cv-01236-O   Document 10   Filed 11/22/21    Page 4 of 4   PageID 113
Case 4:21-cv-01236-O   Document 10   Filed 11/22/21    Page 4 of 4   PageID 113

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