No.

14-1341
_________________________________________
IN THE UNITED STATES COURT OF APPEALS
FOR THE SIXTH CIRCUIT
__________________________________________
APRIL DEBOER; JANE ROWSE, individually and as parent and next friend of
N.D.-R, R.D.-R and J.D.-R, minors,

PLAINTIFFS-APPELLEES;
v.
RICHARD SNYDER, in his official capacity as Governor of the State of
Michigan; BILL SCHUETTE, in his official capacity as Michigan Attorney
General,
DEFENDANTS-APPELLANTS.
____________________________________________

ON APPEAL FROM THE UNITED STATES DISTRICT COURT FOR THE
EASTERN DISTRICT OF MICHIGAN, SOUTHERN DIVISION, CASE NO. 12-
CV-10285 (HONORABLE BERNARD A. FRIEDMAN)
___________________________________________

MOTION OF AMICUS CURIAE DAVID BOYLE FOR LEAVE TO FILE
REPLY BRIEF SUPPORTING DEFENDANTS-APPELLANTS AND
SUPPORTING REVERSAL
___________________________________________

David Boyle
P.O. Box 15143
Long Beach, CA 90815
(734) 904-6132
dbo@boyleslaw.org
Pro se Counsel for Amicus Curiae David Boyle

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INTRODUCTION/STATEMENT OF INTEREST
The present amicus curiae, David Boyle (hereinafter, “Amicus”), respectfully
submits, under Sixth Circuit Rule 46(a)(1)(d), this Motion for Leave to File Reply
Brief in Support of Defendants-Appellants (Richard Snyder and Bill Schuette) and
Supporting Reversal in DeBoer v. Snyder, No. 14-1341 (No. 12-CV-10285, 2014
U.S. Dist. LEXIS 37274 (E.D. Mich. Mar. 21, 2014)). Amicus contacted the
parties’ counsel, both of whom told him they do not object to this Motion and
accompanying Brief. There are some serious issues that need to be cleared up, or at
least partially cleared up. So, although reply amicus briefs are usually disfavored:
in this case, Amicus believes it would be appropriate to allow a reply brief.
ARGUMENT
The most important function of the reply amicus brief here is to address some
potentially-material, if doubtlessly unintentional and well-meant, omissions or
possibly-misleading information in the Brief of Amicus Curiae Gary J. Gates in
Support of Plaintiffs/Appellees and Affirmance (June 16, 2014) in the instant case.
Without overly repeating the lengthy discussion of this issue in the Reply Brief
itself: Gates, in his brief, supra, claims that “[a]vailable studies on places where
same-sex marriage has been legalized find no evidence that allowing same-sex
couples to marry reduces the rate of different-sex marriages”, see id. at 25; and
cites, at n.67, “Mircea Trandafir, The effect of same-sex marriage laws on
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2

different-sex marriage: Evidence from the Netherlands, 51 Demography 317, 337-
38 (2014)”, id. However, that Trandafir report actually admits some (if
insignificant) downward movement in marriages following same-sex-marriage
legalization, see id. at 3; and more importantly, a 2009 report by Trandafir, of
exactly the same name as the 2014 report, reports downward movement in
marriages following same-sex-marriage legalization, but without calling it
“insignificant”, see 2009 Trandafir Rep. passim. In fact, he even claims evidence
shows a “rather significant” decline in marriages, id. at 24 (p. 25 of PDF available
at http://www.iza.org/conference_files/TAM2010/trandafir_m6039.pdf).
Thus, if Amicus did not tell the Court about Trandafir’s reports and what they
say, the Court might falsely think that there has never been any evidence that
same-sex marriages can hurt diverse-sex marriages; but the 2009 Trandafir report,
and to a lesser extent the 2014 one, both record some damage or decline to diverse-
sex marriages from, or following, same-sex marriage legalization. It need hardly be
said that this is a crucial issue, about which Amicus wants to let the Court, parties,
amicae/i, and the public know. (Again, Mr. Gates is presumed completely guiltless
here.)
Amicus, since he is writing a reply brief at all, also discusses some other issues,
including recent news items, which may help add further understanding of the
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complex issues at hand. This all should help a fair resolution of this controversial
and important case, and related cases.
CONCLUSION
Amicus respectfully asks the Court to allow the filing of a reply amicus brief
expanding on the issues herein and helping clear up some serious confusion; and
humbly thanks the Court for its time and consideration.
July 3, 2014 Respectfully submitted,
s/David Boyle
P.O. Box 15143
Long Beach, CA 90815
(734) 904-6132
dbo@boyleslaw.org
Pro se Counsel for Amicus Curiae David Boyle










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CERTIFICATE OF SERVICE

The undersigned certifies that he electronically filed the foregoing Motion of
Amicus Curiae David Boyle for Leave to File Reply Brief in Support of
Defendants-Appellants and Supporting Reversal, in No. 14-1341, with personnel
of the Clerk of the Court for the United States Court of Appeals for the Sixth
Circuit by e-mail on July 3, 2014.
He also certifies that he has been informed that all parties or their counsel of
record will be served through the CM/ECF system if they are registered CM/ECF
users.
Thank you for your time,
July 3, 2014 Respectfully submitted,
s/David Boyle
P.O. Box 15143
Long Beach, CA 90815
(734) 904-6132
dbo@boyleslaw.org
Pro se Counsel for Amicus Curiae David Boyle




Case: 14-1341 Document: 176 Filed: 07/03/2014 Page: 5

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