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UNITED STATES DISTRICT COURT
FOR THE MIDDLE DISTRICT OF GEORGIA
MACON DIVISION
AIR FORCE OFFICER, on behalf of herself
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and all others similarly situated,
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Case No. 5:22-cv-00009-TES
Plaintiff,
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v.
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LLOYD J. AUSTIN, III, in his
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official capacity as Secretary of Defense;
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FRANK KENDALL, III, in his
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official capacity as Secretary of the Air Force; and )
ROBERT I. MILLER, in his
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official capacity as Surgeon General of the
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Air Force,
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Defendants.
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DECLARATION OF ADAM HOCHSCHILD
IN SUPPORT OF MOTION FOR CLASS CERTIFICATION
I, Adam Hochschild, declare under penalty of perjury pursuant to 28 U.S.C. § 1746 that
the following is true and correct:
1.
I am over the age of eighteen and am competent to make this declaration.
2.
I am submitting this declaration in support of Plaintiff’s Motion for Class
Certification.
3.
I am one of Plaintiff’s attorneys in this case.
4.
I am a lawyer licensed to practice in the State of Vermont, the State of Missouri,
the United States District Court for the District of Vermont, the United States District Court for
the Eastern District of Missouri, and the United States Court of Appeals for the Second Circuit.
5.
Since December 2018, I have owned and operated my own law firm based in
Vermont, Hochschild Law Firm, LLC. I maintain a national practice, representing clients in a
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variety of matters, primarily litigation, including complex commercial litigation and complex
civil rights and constitutional litigation.
6.
Since 2019, through my firm I have served on certain matters—including this
one—as Special Counsel for the Thomas More Society, a not-for-profit, national public interest
law firm dedicated to restoring respect in law for life, family, and religious liberty. The Thomas
More Society provides pro bono legal representation to plaintiffs and defendants involved in
complex civil rights and constitutional litigation nationwide.
7.
The Thomas More Society and its attorneys have a substantial record of raising
and diligently pursuing legal challenges to incursions on First Amendment and other civil rights.
8.
For example, a team of Thomas More Society attorneys (including myself and
Stephen Crampton and Michael McHale who are also attorneys of record in this case) recently
obtained a victory on appeal, after rehearing by the Second Circuit panel. In a case involving the
First Amendment rights of pro-life sidewalk counselors in the context of the federal Freedom of
Access to Clinic Entrances Act (FACE) and a similar state law and city ordinance, the District
Court for the Eastern District of New York denied the State of New York’s motion for
preliminary injunction against our clients. The State appealed, and a panel of the Second Circuit
Court of Appeals first reversed the denial of the preliminary injunction, but then granted our
clients’ petition for rehearing and vacated its own reversal of, and affirmed, the District Court’s
decision. New York by James v. Griepp, 11 F.4th 174 (2d Cir. 2021).
9.
Prior to joining the Thomas More Society in 2019, I practiced law at
RUNNYMEDE law group (2016-2018), Clark & Sauer, LLC (2013-2015), Bryan Cave LLP
(now known as Bryan Cave Leighton Paisner LLP) (2010-2013), and Husch Blackwell Sanders,
LLP (now known as Husch Blackwell LLP) (2000-2010) and represented clients across the
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nation. As an attorney at each of these firms, I represented clients—including Fortune 500
companies—primarily in complex commercial litigation, including in the fields of securities,
telecommunications, and tax, among others.
10.
I have represented clients in several class action cases, including in Bachman v.
A.G. Edwards, Inc., No. 22052-01266 (Circuit Court of the City of St. Louis, Missouri)
(securities); Merrick v. Stifel Fin. Corp., No. 4:08CV1167–HEA (E.D.Mo.) (securities); City of
University City v. Sprint-Nextel, No. 01-CC-004454 (Circuit Court of the County of St. Louis,
Missouri) (telecommunications and tax); and City of O’Fallon v. CenturyLink, Inc., No. 12SL-
CC01723 (Circuit Court of the County of St. Louis, Missouri) (telecommunications and tax). In
Bachman, for example, I successfully argued before the Missouri Court of Appeals, Eastern
District, in favor of affirming the trial court’s order approving settlement. Bachman v. A.G.
Edwards, Inc., 344 S.W.3d 260 (Mo. Ct. App. 2011).
11.
The Thomas More Society is an entire law firm of specialists in the laws
applicable in this case, including RFRA and the First Amendment. Our team has expended
considerable effort already in connection with the preliminary injunction [Doc. 51] and
formulating and presenting the legal issues before the Court in the First Amended Class Action
Complaint. We are fully prepared to prosecute this matter on behalf of the Plaintiff and the
proposed class.
12.
I and co-counsel and other Thomas More Society attorneys have been contacted,
both before and during the current action, by many putative class members with interests similar
to Plaintiff’s.
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13.
I understand the nature and magnitude of the expenses involved in litigating class
action lawsuits and, as attorneys associated with Thomas More Society, counsel have sufficient
resources to vigorously prosecute this action.
Dated this 28th day of February 2022.
/s/ Adam Hochschild
Adam Hochschild
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