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No. 09-285IN THE
 Supreme Court of the United States Supreme Court of the United States Supreme Court of the United States Supreme Court of the United States
 __________  __________  __________  __________ 
In re C
HRYSLER
LLC, Debtor
 __________  __________  __________  __________ 
I
NDIANA 
S
TATE
P
OLICE
P
ENSION
T
RUST
,
 et al.
,
 Petitioners,
v.C
HRYSLER
LLC,
 et al.
,
 Respondents.
 On Petition for a Writ of CertiorariTo the United States Court of AppealsFor the Second Circuit__________MOTION FOR LEAVE TO FILE BRIEF ANDBRIEF OF WASHINGTON LEGAL FOUNDATION,ALLIED EDUCATIONAL FOUNDATION,THE CATO INSTITUTE, ANDTODD J. ZYWICKI AS
 AMICI CURIAE
IN SUPPORT OF PETITIONERS 
Daniel J. PopeoCory L. AndrewsRichard A. Samp(Counsel of Record) Washington Legal Foundation2009 Massachusetts Ave., NW  Washington, DC 20036(202) 588-0302Date: October 5, 2009
 
M
OTION OF
 W 
 ASHINGTON
L
EGAL
F
OUNDATION
,
 
 A
LLIED
E
DUCATIONAL
F
OUNDATION
,
 
T
HE
C
 ATO
I
NSTITUTE
,
AND
T
ODD
J.
 
Z
 YWICKIFOR
L
EAVE
T
O
F
ILE
B
RIEF AS
 A
MICI
C
URIAE IN
S
UPPORT OF
P
ETITIONERS
Pursuant to Rule 37.2 of the Rules of this Court,the Washington Legal Foundation (WLF), AlliedEducational Foundation (AEF), the Cato Institute, andTodd J. Zywicki respectfully move for leave to file theattached brief as
amici curiae
in support of Petitioners.Counsel for Petitioners signed a letter consenting to thefiling of this brief. Counsel for Respondents the UnitedStates, Chrysler LLC, Chrysler Financial Services Americas LLC, and UAW signed letters consenting onbehalf of their clients to the filing of this brief. Counselfor the remaining Respondents, Fiat S.p.A. and NewCarCo Acquisition LLC, the Official Committee of Unsecured Creditors, Export Development of Canada,the Ad Hoc Committee of Consumer Victims of Chrysler,and Patricia Pascale, did not respond to requests forconsent. Accordingly, this motion for leave to file isnecessary. WLF is a public interest law and policy centerheadquartered in Washington, DC, with supporters inall 50 states. WLF devotes a substantial portion of itsresources to defending and promoting free enterprise,individual rights, and a limited and accountablegovernment. WLF regularly publishes monographs andother publications on these and other related topics. WLF has appeared as
amicus curiae
in numerous casesbefore this Court involving issues of public importance,including other bankruptcy cases.
See, e.g.
,
 Assocs.Commercial Corp. v. Rash
, 520 U.S. 953 (1997);
 Pennsylvania Dep’t. Of Public Welfare v. Davenport
, 495U.S. 552 (1990).
 
 AEF is a non-profit charitable and educationalfoundation based in Englewood, New Jersey. Foundedin 1964, AEF is dedicated to promoting education indiverse areas of study, and has appeared as
amicus curiae
in this Court on a number of occasions.The Cato Institute was established in 1977 as a nonpartisan public policy research foundation dedicatedto advancing the principles of individual liberty, freemarkets, and limited government. Cato’s Center forConstitutional Studies was established in 1989 to helprestore the principles of limited constitutionalgovernment that are the foundation of liberty. Towardthose ends, the Cato Institute publishes books andstudies, conducts conferences and forums, and filesamicus briefs with the courts. Cato’s amicus brief program is coordinated by Ilya Shapiro, a senior fellowin constitutional studies and editor-in-chief of theannual
Cato Supreme Court Review
. Cato’s concern inthis case is that the government violated propertyrights, subverted the bankruptcy process, and otherwisetook actions that exceeded its constitutional authority.Todd J. Zywicki is George Mason UniversityFoundation Professor of Law at George MasonUniversity School of Law, where he also serves as SeniorScholar of the Mercatus Center. He regularly teaches inthe areas of bankruptcy law, consumer credit, andcorporate lending. Editor of the
Supreme Court Economic Review
, Professor Zywicki is the author of more than 70 articles in leading law reviews and peer-reviewed economic journals, including 
 Is Forum-Shopping Corrupting America’s Bankruptcy Courts?
, 94G
EORGETOWN
L.J. 1141 (2006);
 Institutions, Incentives,and Consumer Bankruptcy Reform
, 62 W 
 ASHINGTON
&L
EE
L.
 
R
EV 
. 1071 (2005); and
 An Economic Analysis of the Consumer Bankruptcy Crisis
, 99 N
ORTHWESTERN
L.R
EV 
.
 
1071 (2005).
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