Declaration Of Andrew B. Stephens In

Summary

Andrew B. Stephens submits a declaration in support of Plaintiffs’ Motion for Class Certification in Case No. 4:21-cv-01236-O in the Northern District of Texas. Stephens states that he is a partner at Hacker Stephens LLP, a law firm in Austin, Texas, and that the firm is co-counsel in the case with First Liberty Institute. He states that he and his law partner Heather Hacker have represented plaintiffs and defendants as lead trial and appellate counsel in numerous civil litigation matters, including class action lawsuits. The declaration says counsel are fully prepared to prosecute the matter on behalf of the Named Plaintiffs and the proposed class and subclasses, and it shows /s/ Andrew B. Stephens, dated the 25th day of January, 2022.

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UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF TEXAS
FORT WORTH DIVISION

U.S. NAVY SEALs 1-3, on behalf of
themselves and all others similarly situated;
U.S. NAVY EXPLOSIVE ORDNANCE
DISPOSAL TECHNICIAN 1, on behalf of
himself and all others similarly situated; U.S.
NAVY SEALS 4-26; U.S. NAVY SPECIAL
WARFARE COMBATANT CRAFT
CREWMEN 1-5; and U.S. NAVY DIVERS
1-3,

Plaintiffs,

v.

LLOYD J. AUSTIN, III, in his official
capacity as United States Secretary of
Defense; UNITED STATES
DEPARTMENT OF DEFENSE; CARLOS
DEL TORO, in his official capacity as
United States Secretary of the Navy,

Defendants.

Case No. 4:21-cv-01236-O

DECLARATION OF ANDREW B. STEPHENS IN
SUPPORT OF MOTION FOR CLASS CERTIFICATION

I, ANDREW B. STEPHENS, declare under penalty of perjury pursuant to 28 U.S.C.
§ 1746 that the following is true and correct:
1.
I am submitting this Declaration in support of Plaintiffs’ Motion for Class
Certification.
2.
I am a lawyer licensed to practice in the States of Texas and New York, federal
district courts for the Northern District of Texas, the Western District of Texas, the Southern
District of Texas, the Eastern District of Texas, the District of North Dakota, the Fifth Circuit
Court of Appeals, and the United States Supreme Court.
Case 4:21-cv-01236-O   Document 90-1   Filed 01/25/22    Page 1 of 3   PageID 2782
Case 4:21-cv-01236-O   Document 90-1   Filed 01/25/22    Page 1 of 3   PageID 2782

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3.
I am a partner at Hacker Stephens LLP, a law firm in Austin, Texas. My law partner
Heather Hacker and I focus our practice on civil litigation in state and federal courts, with a
particular focus on complex civil cases involving constitutional and statutory claims in federal
courts. Before founding Hacker Stephens LLP, Ms. Hacker and I worked for the Texas Attorney
General and litigated a number of significant cases in state and federal courts on behalf of the State
of Texas. I previously worked as a litigator at Shearman & Sterling LLP in New York, NY and
Ms. Hacker was a trial and appellate litigator for a nonprofit religious liberty organization. We are
co-counsel in this case with First Liberty Institute, a nonprofit public interest law firm that focuses
on protecting religious liberties for all Americans.
4.
We have represented plaintiffs and defendants as lead trial and appellate counsel in
numerous civil litigation matters in state and federal courts, including class action lawsuits. I have
represented the State of Texas at trial in several federal class actions involving complex
constitutional and statutory claims, including M.D. v. Abbott, No. CIV.A. C-11-84 (S.D. Tex.),
and Steward v. Janek, No. 5:10-cv-1025-OLG (W.D. Tex.). Recently, our firm has served as lead
trial and appellate counsel in cases defending the constitutionality of the Texas Heartbeat Act in
state and federal district courts, the Fifth Circuit Court of Appeals, and the United States Supreme
Court. We are lead counsel in several federal cases involving constitutional and statutory claims
in the Northern District of Texas: Planned Parenthood of Greater Texas Surgical Health Services
v. City of Lubbock, Cause No. 5:21-cv-00114-H; and United States ex rel. Doe, et al. v. Planned
Parenthood Federation of America, et al., Cause No. 2:21-cv-00022-Z.
5.
We are knowledgeable about the applicable law involved in this case and are
assisted by the considerable resources of First Liberty Institute, a non-profit organization with
Case 4:21-cv-01236-O   Document 90-1   Filed 01/25/22    Page 2 of 3   PageID 2783
Case 4:21-cv-01236-O   Document 90-1   Filed 01/25/22    Page 2 of 3   PageID 2783

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extensive experience litigating cases involving religious liberties and religious rights under the
First Amendment and Religious Freedom Restoration Act.
6.
We have spent many hours researching the claims, compiling and analyzing
relevant facts and information, and researching and developing the legal claims alleged in the First
Amended Class Action Complaint. We are fully prepared to prosecute this matter on behalf of the
Named Plaintiffs and the proposed class and subclasses.
7.
Counsel understands the nature and magnitude of the expenses involved in
litigating complex class action lawsuits and has sufficient resources to vigorously prosecute this
action.
Dated this  25th  day of January, 2022

/s/ Andrew B. Stephens

ANDREW B. STEPHENS

Case 4:21-cv-01236-O   Document 90-1   Filed 01/25/22    Page 3 of 3   PageID 2784
Case 4:21-cv-01236-O   Document 90-1   Filed 01/25/22    Page 3 of 3   PageID 2784

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