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4:14-cv-00138 #13

4:14-cv-00138 #13

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Published by Equality Case Files
Doc 13 - Motion to Intervene as Defendant-Intervenor by Florida Family Action, Inc.
Doc 13 - Motion to Intervene as Defendant-Intervenor by Florida Family Action, Inc.

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Published by: Equality Case Files on Apr 03, 2014
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UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF FLORIDA TALLAHASSEE DIVISION
SLOAN GRIMSLEY and JOYCE ALBU;
 
)
Case No. 4:14-CV-00138-RH-CAS
BOB COLLIER and CHUCK HUNZIKER; ) LINDSAY MYERS and SARAH HUMLIE; ) ROBERT LOUPO and JOHN FITZGERALD; ) DENISE HUESO and SANDRA NEWSON; ) JUAN DEL HIERRO and THOMAS GANTT, ) JR.; CHRISTIAN ULVERT and CARLOS ) ANDRADE; RICHARD MILSTEIN and ) ERIC HANKIN; and SAVE FOUNDATION, ) INC., )
 
) Plaintiffs, ) v. ) ) RICK SCOTT, in his official capacity as ) Governor of Florida, and PAMELA BONDI, in ) her official capacity as Attorney General of ) Florida, JOHN H. ARMSTRONG, in his official ) capacity as Surgeon General and Secretary of ) Health for the State of Florida; and ) CRAIG J. NICHOLS, in his official capacity ) as the Agency Secretary for the Florida ) Department of Management Services, ) ) Defendants. ) ) FLORIDA FAMILY ACTION, INC. ) )
VERIFIED MOTION BY FLORIDA FAMILY ACTION, INC. FOR LEAVE TO INTERVENE AS A DEFENDANT AS OF RIGHT OR,
Intervenor-Defendant. )
 IN THE ALTERNATIVE, BY PERMISSION (PARTIALLY CONSENTED)
Florida Family Action, Inc., (“FFAI”), by and through counsel, respectfully moves this Court for leave to intervene as of right, pursuant to Fed. R. Civ. P. 24(a), or,
Case 4:14-cv-00138-RH-CAS Document 13 Filed 04/02/14 Page 1 of 7
 
2 alternatively, by permission under Fed. R. Civ. P. 24(b), as a Defendant, and in support thereof, states the following: 1.
 
Plaintiffs include same-sex couples who left Florida to obtain “marriages” under the laws of other states. Plaintiffs then returned to Florida and now expect Florida to reform its laws and redefine marriage so that they can obtain benefits and rights that the people of Florida and the Florida Constitution require to be given only to the union of one man and one woman. 2.
 
Plaintiffs are asking this Court to superimpose Plaintiffs’ will onto the will of the majority of Floridians and to judicially repeal Amendment 2 of the Florida Constitution, which was enacted by more than 60 percent of Florida voters on November 4, 2008, and was codified as Fla. Const. Art. I, §27: “Inasmuch as marriage is the legal union of only one man and one woman as husband and wife, no other legal union that is treated as marriage or the substantial equivalent thereof shall be valid or recognized.” 3.
 
Plaintiffs claim that memorializing the definition of marriage in the Florida Constitution, as well as in Florida Statutes §§741.212(1), (2), and (3), violates the United States Constitution because Plaintiffs want their relationships (or in the case of SAVE, the relationships of its members) to people of the same sex, which were sanctioned in other jurisdictions, to be validated in Florida. On that basis, Plaintiffs ask this Court to declare that the Florida Constitution and Section 741.212 violate the United States Constitution. 4.
 
Plaintiffs ask this Court to cast aside and invalidate the votes of almost five (5) million Floridians who by a large majority voted to reaffirm the definition of
Case 4:14-cv-00138-RH-CAS Document 13 Filed 04/02/14 Page 2 of 7
 
3 marriage as the union of one man and one woman,
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5.
 
FFAI is a non-profit 501(c)(4) cultural action organization with thousands of members throughout Florida, including in Tallahassee. and to redefine marriage to include at least same-sex unions that other states have recognized. 6.
 
FFAI’s mission is to inform, inspire and rally those who care deeply about the family to greater involvement in the moral, cultural and political issues that face our state. As part of this mission, FFAI works to preserve and protect marriage as a foundational social institution, to educate Floridians on the underlying social goods attendant to the institution of marriage, to strengthen marriages, and to promote a strong foundational basis for raising children and ensuring the future of society. 7.
 
FFAI’s members were instrumental in drafting Amendment 2, gathering signatures to place it on the ballot, defending it against legal challenges in Florida courts, including at the Florida Supreme Court, and educating and mobilizing voters to ultimately approve Amendment 2. 8.
 
After Amendment 2 was approved by the Florida Supreme Court and enacted by the people of Florida, FFAI’s members continued to work throughout Florida, including in Tallahassee, to preserve and protect marriage as an institution based upon societal norms that teach, form and transform individuals, and that create stable and optimal foundations for families and for the perpetuation of society. FFAI has worked to
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 The official results of the November 2008 General Election show that Amendment 2 received 4,890,883 “yes” votes (61.9 percent) and 3,008,026 “no” votes (38.1 percent). Florida Secretary of State, Division of Elections, November 8, 2008 General Election Results, available at http://election.dos.state.fl.us/elections/resultsarchive/Index.asp?ElectionDate=11/4/2008 (last visited February 20, 2014).
Case 4:14-cv-00138-RH-CAS Document 13 Filed 04/02/14 Page 3 of 7

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