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13-4429 #69

13-4429 #69

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Published by Equality Case Files
#69 - Motion for leave to file amicus brief: Survivors of Sexual Orientation Change Efforts
#69 - Motion for leave to file amicus brief: Survivors of Sexual Orientation Change Efforts

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Published by: Equality Case Files on Apr 18, 2014
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04/18/2014

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[1074235-1]
C
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N
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13-4429 UNITED STATES COURT OF APPEALS FOR THE THIRD CIRCUIT
TARA KING, ED.D., individually and on behalf of her patients, RONALD NEWMAN, PH.D., individually and on behalf of his patients, NATIONAL ASSOCIATION FOR RESEARCH AND THERAPY OF HOMOSEXUALITY (NARTH), and AMERICAN ASSOCIATION OF CHRISTIAN COUNSELORS (AACC),
Plaintiffs–Appellants,
 v. CHRISTOPHER J. CHRISTIE, Governor of the State of New Jersey, in his official capacity, ERIC T. KANEFSKY, Director of the New Jersey Department of Law and Public Safety: Division of Consumer Affairs, in his official capacity, MILAGROS COLLAZO, Executive Director of the New Jersey Board of Marriage and Family Therapy Examiners, in her official capacity, J. MICHAEL WALKER, Executive Director of the New Jersey Board of Psychological Examiners, in his official capacity; and PAUL JORDAN, President of the New Jersey State Board of Medical Examiners, in his official capacity,
 Defendants–Appellees,
and GARDEN STATE EQUALITY,
 Intervenor–Defendant–Appellee.
MOTION
 
FOR
 
LEAVE
 
TO
 
FILE
 
BRIEF
 
 AMICI 
 
CURIAE
 
OF
 
SURVIVORS
 
OF
 
SEXUAL
 
ORIENTATION
 
CHANGE
 
EFFORTS,
 
IN
 
SUPPORT
 
OF
 
DEFENDANTS-APPELLEES
 
URGING
 
AFFIRMANCE
Appeal From The United States District Court, District of New Jersey Civil Action No. 13-5038 The Honorable Freda L. Wolfson, District Judge ROSEN BIEN GALVAN & GRUNFELD LLP SANFORD JAY ROSEN – 062566 315 Montgomery Street, Tenth Floor San Francisco, California 94104-1823 Telephone: (415) 433-6830 Facsimile: (415) 433-7104
 Attorneys for Amici Curiae
 
Case: 13-4429 Document: 003111549928 Page: 1 Date Filed: 03/05/2014
 
 1
[1074235-1]
Pursuant to Rule 29 of the Federal Rules of Appellate Procedure, James Guay, Ryan Kendall, Peter Drake, John Metzidis-Drennan, and Maris Ehlers respectfully request leave to file the accompanying Brief of
 Amici Curiae
in support of the Defendants-Appellees, urging affirmance of the District Court’s decision granting Defendants-Appellees motion for summary judgment. Liberty Counsel, on behalf of Plaintiffs-Appellants, denied prospective
 Amici Curiae
 their consent to file this brief, thereby necessitating this Motion. This case addresses the State’s interest in protecting minors from the serious harms caused by sexual orientation change efforts (“SOCE”). As survivors of SOCE and the sister of a man of who was subjected to SOCE as a child and ultimately committed suicide, prospective
 Amici
have a substantial interest in ensuring that the Court is made aware of the severity of the risk that thousands of minors will suffer if A3371 is not upheld. Ryan Kendall testified before the New Jersey Assembly and Senate at hearings regarding A3371, and James Guay and Peter Drake also each testified before the California Legislature in support of SB 1172, the California bill that addressed these issues. Similarly, John Metzidis-Drennan and Maris Ehlers are also dedicated to protecting minors from exposure to these dangerous and discredited practices. If A3371 is not upheld, prospective
 Amici
’s interest in protecting others from the serious harms that they and their families suffered would be thwarted.
Case: 13-4429 Document: 003111549928 Page: 2 Date Filed: 03/05/2014
 
 2
[1074235-1]
Prospective
 Amici’s
 brief is both desirable and relevant to the disposition of this case because it provides an important perspective that would not otherwise be before the Court, as the Defendants-Appellees are not survivors of SOCE or their families. By recounting the stories of the serious harms that they and their families suffered as a result of their exposure to SOCE, prospective
 Amici’s
 brief will provide the Court with a more complete picture of the harmful consequences that are likely to result if A3371 is not upheld. For the foregoing reasons, prospective
 Amici
respectfully request that the Court grant them leave to file the accompanying brief. DATED: March 5, 2014 Respectfully submitted, ROSEN BIEN GALVAN & GRUNFELD LLP By:
s/ Sanford Jay Rosen
Sanford Jay Rosen Attorneys for
 Amici Curiae
 
Case: 13-4429 Document: 003111549928 Page: 3 Date Filed: 03/05/2014

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