Case 17-1512, Document 72-1, 09/25/2017, 2133032, Page1 of 1

UNITED STATES COURT OF APPEALS FOR THE SECOND CIRCUIT

Thurgood Marshall U.S. Courthouse 40 Foley Square, New York, NY 10007 Telephone: 212-857-8500

MOTION INFORMATION STATEMENT

Docket Number(s): 17-1512-ag Caption [use short title]

Motion for: Leave to File Brief as Amici Curiae in Jaen v. Sessions

Support of Levy Alberto Jaen's Petition for Review
of a Decision of the Board of Immigration Appeals
Set forth below precise, complete statement of relief sought:

Professors of Family Law (listed in Appendix to

Amicus Brief) seek leave to file a brief as
amicus curiae in support of Levy Alberto Jaen's
Petition for Review of a Decision of the Board
of Immigration Appeals

MOVING PARTY: Proposed Amici OPPOSING PARTY: Jefferson Sessions, Attorney General
Plaintiff Defendant
Appellant/Petitioner Appellee/Respondent

MOVING ATTORNEY: Shailee Diwanji Sharma OPPOSING ATTORNEY: Rachel L. Browning

[name of attorney, with firm, address, phone number and e mail]

Covington & Burling LLP U.S.D.O.J. Civil Division, Office of Immigration Litigation

620 Eighth Ave., New York, NY 10018 P.O. Box 878, Ben Franklin Station, Washington D.C., 20044

212.841.1176; ssharma@cov.com 202.532.4526; rachel.l.browning@usdoj.gov

Court Judge/Agency appealed from: Board of Immigration Appeals
Please check appropriate boxes: FOR EMERGENCY MOTIONS, MOTIONS FOR STAYS AND
INJUNCTIONS PENDING APPEAL:
Has movant notified opposing counsel (required by Local Rule 27.1): Has request for relief been made below? Yes No
✔ Yes No (explain): Has this relief been previously sought in this Court? Yes No
Requested return date and explanation of emergency:
Opposing counsel’s position on motion:
✔ Unopposed Opposed Don’t Know
Does opposing counsel intend to file a response:
Yes ✔ No Don’t Know

Is oral argument on motion requested? Yes ✔ No (requests for oral argument will not necessarily be granted)

Has argument date of appeal been set? Yes ✔ No If yes, enter date:

Signature of Moving Attorney:

/s/ Shailee Diwanji Sharma Date: Sep. 25, 2017 Service by: ✔ CM/ECF Other [Attach proof of service]

Form T-1080 (rev. 12-13)

 Case 17-1512, Document 72-2, 09/25/2017, 2133032, Page1 of 3

17-1512-ag
IN THE UNITED STATES COURT OF APPEALS
FOR THE SECOND CIRCUIT

LEVY ALBERTO JAEN,

Petitioner,
v.
JEFFERSON SESSIONS III,
Respondent.

On Appeal from the Board of Immigration Appeals

MOTION OF AMICI CURIAE FAMILY LAW PROFESSORS FOR LEAVE

TO FILE BRIEF AS AMICUS CURIAE IN SUPPORT OF PETITIONER

Shailee Diwanji Sharma

Andrew A. Ruffino
COVINGTON & BURLING LLP
The New York Times Building
620 Eighth Avenue
New York, NY 10018
(212) 841-1000

Counsel to Family Law Professors

 Case 17-1512, Document 72-2, 09/25/2017, 2133032, Page2 of 3

Pursuant to Federal Rule of Appellate Procedure 29, amici curiae—19

family law professors—respectfully request that they be granted leave to file the

Brief of Amici Curiae Family Law Professors in Support of Petitioner, attached

hereto as Exhibit A. 1

Amici curiae are family law professors with substantial knowledge of, and

experience with, the contours of the parent-child relationship, as defined by the

laws of New York and other states, particularly with respect to the presumption of

legitimacy of a child born in wedlock. Amici request permission to file a brief

explaining how the Board of Immigration Appeals’ unsubstantiated decision to

name Petitioner’s biological father, rather than his mother’s husband at the time of

his birth, as the “parent” for the purposes of Petitioner’s deportation proceeding is

inconsistent with the longstanding and widely recognized “presumption that a child

born to a marriage is the legitimate child of both parents.” Wendy G-M. v. Erin G-

M., 45 Misc. 3d 574, 577 (N.Y. Sup. Ct. 2014).

Amicus participation by family law professors is desirable because they can

shed light on how the Board of Immigration Appeals’ ruling, if left standing,

would impact the legal definition of “parent” and the resulting family relationships

more broadly. The attached brief provides information that would assist the Court

1
Amici curiae notified both parties of their intent to file this brief. Petitioner
consented to the filing of this brief; Respondent takes no position on the filing of
this brief.
1
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in evaluating the Board of Immigration Appeals’ decision in the context of the

principles of family law.

For these reasons, amici curiae family law professors therefore respectfully

request that the court grant their unopposed motion to file their amici curiae brief.

Respectfully submitted,

/s/ Shailee Diwanji Sharma

Shailee Diwanji Sharma
Andrew A. Ruffino
COVINGTON & BURLING LLP
The New York Times Building
620 Eighth Avenue
New York, NY 10018
Telephone: (212) 841-1000
Facsimile: (212) 841-1010
aruffino@cov.com

Counsel to Family Law Professors

2
 Case 17-1512, Document 72-3, 09/25/2017, 2133032, Page1 of 19

17-1512-ag
IN THE UNITED STATES COURT OF APPEALS
FOR THE SECOND CIRCUIT

LEVY ALBERTO JAEN,

Petitioner,
v.
JEFFERSON SESSIONS III,
Respondent.

On Appeal from the Board of Immigration Appeals

BRIEF OF AMICI CURIAE FAMILY LAW PROFESSORS IN SUPPORT

OF PETITIONER

Shailee Diwanji Sharma

Andrew A. Ruffino
COVINGTON & BURLING LLP
The New York Times Building
620 Eighth Avenue
New York, NY 10018
(212) 841-1000

Counsel to Family Law Professors

 Case 17-1512, Document 72-3, 09/25/2017, 2133032, Page2 of 19

TABLE OF CONTENTS

TABLE OF AUTHORITIES .................................................................................... ii

INTEREST OF AMICUS CURIAE........................................................................... 1

ARGUMENT ............................................................................................................ 2

I. New York Law and Public Policy Establish a Presumption That a Child
Born to a Married Couple is the Legitimate Child of the Married Couple. ... 3

II. Public Policy Weighs in Favor of Defining the Parent-Child Relationship

Broadly to Advance the Best Interests of the Child. ...................................... 7

CONCLUSION ....................................................................................................... 10

APPENDIX ............................................................................................................. 11

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TABLE OF AUTHORITIES

Page(s)

Cases
Abreu v. Colvin,
152 F. Supp. 3d 166 (S.D.N.Y. 2015) .................................................................. 6

Barbara S. v. Michael I.,

24 A.D.3d 451 (2d Dept. 2005) ............................................................................ 5

Brooke S.B. v. Elizabeth A.C.C.,

28 N.Y.3d 1 (2016) .......................................................................................7, 8, 9

Ghaznavi v. Gordon,
163 A.D.2d 194 (1st Dept. 1990) ......................................................................... 6

In re Alison D.,
77 N.Y.2d 651 (1991) ........................................................................................... 8

In re Ariel G.,
133 A.D.2d 749 (2d Dept. 2015) .......................................................................... 5

In re: Commissioner of Social Services ex. rel. N.Q.

147 A.D.3d 1 (1st Dept. 2016) ............................................................................. 6

In re Estate of Fay,
44 N.Y.2d 137 (1978) ........................................................................................... 4

In re Findlay,
253 N.Y. 1 (1930) ................................................................................................. 4

In re Jacob,
86 N.Y.2d 651 (1995) ........................................................................................... 8

In re Paternity Proceeding L.M.,

6 Misc. 3d 151 (N.Y. Fam. Ct. 2004) ............................................................... 6, 7

In re Shondel J.,
7 N.Y.3d 320 (2006) ......................................................................................... 8, 9

Joan G. v. Robert W.,

83 A.D.2d 838 (2d Dept. 1981) ........................................................................ 4, 5
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Johnson v. Jones,
247 A.D.2d 617 (2d Dept. 1998) .......................................................................... 5

Kelly S. v. Farah M.,

139 A.D.3d 90 (2d Dept. 2016) ........................................................................ 5, 6

McLaughlin v. Jones, No. CV-16-0266-PR,

2017 WL 4126939, at *2 (Ariz. Sept. 19, 2017) ................................................. 9

Michael H. v. Gerald D.,

491 U.S. 110 (1989) (plurality opinion by Scalia, J.) ....................................... 2, 9

Miller-Jenkins v. Miller-Jenkins,
180 Vt. 441 (2006) ................................................................................................ 4

Richard B. v. Sandra B.B.,

209 A.D. 2d 139 (1st Dept. 1995) .................................................................... 5, 6

Wendy G-M. v. Erin G-M.,

45 Misc. 3d 574 (N.Y. Sup. Ct. 2014) .........................................................passim

Statutes
N.Y. Dom. Rel. Law § 24(1) (McKinney 2008) ...............................................2, 3, 4

N.Y. Family Ct. Act § 417 (McKinney 2010) ....................................................... 2, 3

N.Y. Family Ct. Act § 517 (McKinney 2010) ........................................................... 7

Legislative History and Commentary

McKinney’s 1962 Sessions Laws of New York, Vol. II (1962) ............................... 3

Notes, Assembly No. 5376 (1969)............................................................................. 3

Sobie, Practice Commentaries, N.Y. Family Ct. Act § 517 ...................................... 7

State of New York Law Revision Commission, Memorandum in

Support of Assembly No. 5376 (1968) ................................................................. 3

Other Authorities

41 Am. Jur. 2d Illegitimate Children § 8 ................................................................... 9

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46 N.Y. Jur. 2d Dom. Rel. § 893 ............................................................................... 7

Presumption of Legitimacy of a Child Born in Wedlock, Note, 33

Harv. L. Rev. 306 (1919) ...................................................................................... 2

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INTEREST OF AMICI CURIAE

Amici curiae listed in the Appendix are professors of family law with

particular expertise in the parent-child relationship, as defined by the laws of New

York and other states.1 Amici have a professional interest in ensuring that the Court

is fully and accurately informed of the import of the presumption of legitimacy of a

child born in wedlock and the close bond between parent and child.

1
No party’s counsel authored this brief in whole or in part, and no person or entity
other than amici curiae and their counsel made a monetary contribution to the
preparation or submission of this brief.
1
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ARGUMENT

The founding principle of American family law is the institution of the

“family,” which “is deeply rooted in this Nation’s history and tradition.” See

Michael H. v. Gerald D., 491 U.S. 110, 123-4 (1989) (plurality opinion by Scalia,

J.). The sanctity accorded to the family unit gives rise to the presumption that when

two people are married, and one of them has a child, they are both the legal and

legitimate parents of that child. Id. at 124-25; see also Presumption of Legitimacy

of a Child Born in Wedlock, Note, 33 Harv. L. Rev. 306, 306 (1919). This belief is

a core tenet of New York law and public policy. See, e.g., N.Y. Dom. Rel. Law §

24(1) (McKinney 2008); N.Y. Family Ct. Act § 417 (McKinney 2010); Wendy G-

M. v. Erin G-M., 45 Misc. 3d 574, 577 (N.Y. Sup. Ct. 2014) (“New York’s public

policy strongly favors the legitimacy of children, and that the presumption that a

child born to a marriage is the legitimate child of both parents is one of the strongest

and most persuasive known to law.”).

In the decision below, the Board of Immigration Appeals rejected this

fundamental rule, and concluded instead that the child’s biological father, not his

mother’s husband at the time of his birth, is his “parent” for purposes of acquired

United States citizenship. Amici respectfully disagree.

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I. New York Law and Public Policy Establish a Presumption That a

Child Born to a Married Couple is the Legitimate Child of the
Married Couple.
Although the presumption of legitimacy of a child born during wedlock has

been a mainstay of family and domestic relations law in New York for decades, the

State codified the presumption in its current form in the 1960s. In 1962, New York

revamped the adjudication of family law matters through the Family Court Act

(“FCA”). The Act “establishes the new court and defines its jurisdiction and

procedures.” McKinney’s 1962 Sessions Laws of New York, Vol. II (1962).

Section 417 of the FCA states that “[a] child born of parents who at any time prior

or subsequent to the birth of said child shall have entered into a ceremonial marriage

shall be deemed the legitimate child of both parents . . . regardless of the validity of

such marriage.” N.Y. Family Ct. Act § 417 (McKinney 2010).

At that time, New York’s Domestic Relations Law (“DRL”) already

“legitimatize[d] a child born out of wedlock . . . .” State of New York Law Revision

Commission, Memorandum in Support of Assembly No. 5376 (1968) (describing

former § 24). In 1969, the legislature amended the provision to its current form to

recognize the “legitimacy of children of void or annulled marriages.” Notes,

Assembly No. 5376 (1969). Section 24(1) of the DRL today states that

[a] child . . . born of parents who prior or subsequent to

the birth of such child shall have entered into a civil or
religious marriage, or shall have consummated a
common-law marriage where such marriage is

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recognized as valid, in the manner authorized by the law

of the place where such marriage takes place, is the
legitimate child of both birth parents notwithstanding that
such marriage is void or voidable or shall have been or
shall hereafter be annulled or judicially declared void.

N.Y. Dom Rel. Law § 24(1) (McKinney 2008).

New York courts have repeatedly confirmed this presumption. See, e.g., In

re Estate of Fay, 44 N.Y.2d 137, 141-42 (1978) (“There is an established legal

presumption that every person is born legitimate. . . . It has often been described as

‘one of the strongest and most persuasive (presumptions) known to the law.’”). The

presumption remains valid and effective even in situations where the married spouse

is unlikely to be biologically related to the child. See, e.g., In re Findlay, 253 N.Y.

1, 8 (1930) (“If husband and wife are living together in conjugal relation, legitimacy

will be presumed though the wife has harbored an adulterer.”); Wendy G-M., 45

Misc. 3d at 596 (holding that the non-biological spouse is a parent of the child); see

also Miller-Jenkins v. Miller-Jenkins, 180 Vt. 441, 465-66 (2006) (holding that a

partner with no biological connection to the child is a parent if there was a valid legal

union at the time of the child’s birth).

For example, in Joan G. v. Robert W., 83 A.D.2d 838 (2d Dept. 1981), a

husband and wife were separated when the wife conceived and gave birth to the

child. 83 A.D.2d at 838. The court nevertheless stated that “there existed a strong

presumption that the subject child was born legitimately of petitioner’s marriage,

4
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even though petitioner was separated from her husband.” Id. at 839. In Kelly S. v.

Farah M., 139 A.D.3d 90 (2d Dept. 2016), the court relied on California law, which,

like New York, has codified the presumption of legitimacy, to conclude that the

same-sex spouse who did not give birth to the child, a non-biological spouse, “is

presumed to be the natural parent of [the children] by virtue of the parties’ [registered

domestic partnership and subsequent] marriage pursuant to California” law. 139

A.D.3d at 100-01, 104; accord Wendy G-M, 45 Misc. 3d at 575.

This presumption of legitimacy, “while rebuttable, ‘will not fail unless

common sense and reason are outraged by a holding that it abides.’” Richard B. v.

Sandra B.B., 209 A.D. 2d 139, 142 (1st Dept. 1995). And even then, it must “be

rebutted by clear and convincing evidence that either excludes the [non-biological

spouse] as the [parent] or otherwise tends to disprove legitimacy.” In re Ariel G.,

133 A.D.2d 749, 750 (2d Dept. 2015). This is a fact intensive inquiry in which courts

weigh the parties’ actions and testimony along with the results of any blood or DNA

tests. See, e.g., Barbara S. v. Michael I., 24 A.D.3d 451, 452-53 (2d Dept. 2005)

(holding that the presumption was not rebutted when the husband did not testify to

non-access to his spouse during the child’s conception, even where a divorce

judgment indicated that there were no children born of the marriage); Johnson v.

Jones, 247 A.D.2d 617, 617 (2d Dept. 1998) (holding that the presumption was not

rebutted despite the separation of the married couple and a DNA test where the

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putative biological father denied having sexual relations with the mother during the

relevant time frame); Ghaznavi v. Gordon, 163 A.D.2d 194, 195-96 (1st Dept. 1990)

(holding that the presumption was not rebutted where no blood test excluding the

husband as the father no testimony of non-access by the husband was presented,

even where the putative biological father initially acknowledged paternity).

Generally, the child, a putative legal or biological parent, or an individual or

entity standing in their stead must petition the court to rebut the presumption of

legitimacy. See, e.g., In re: Commissioner of Social Services ex. rel. N.Q., 147

A.D.3d 1, 2-3 (1st Dept. 2016) (petition by the Commissioner of Social Services on

behalf of the biological parent who had applied for and received Medicaid assistance

for the child for an order directing the former spouse to provide health insurance for

the child); Kelly S., 139 A.D.2d at (petition by biological parent to deny parental

rights to non-biological former spouse); Richard B., 209 A.D.2d at 141 (petition by

non-biological former spouse to deny parentage); In re Paternity Proceeding L.M.,

6 Misc. 3d 151, at 152 (N.Y. Fam. Ct. 2004) (petition by married biological parent

to declare the unmarried biological parent as a “parent” instead of the non-biological

former spouse); cf. Abreu v. Colvin, 152 F. Supp. 3d 166, 175-76 (S.D.N.Y. 2015)

(reversing the Commissioner of Social Security’s denial of benefits to the deceased

non-biological spouse’s children who were born during the course of his marriage

to their biological mother, even where DNA evidence confirmed their non-biological

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relationship). Moreover, such a petition may only be brought until the child reaches

the age of twenty-one. N.Y. Family Ct. Act § 517 (McKinney 2010).2

II. Public Policy Weighs in Favor of Defining the Parent-Child

Relationship Broadly to Advance the Best Interests of the Child.

The presumption of legitimacy is grounded in longstanding core American

values and public policy principles emphasizing the family unit. The institution of

marriage, which is at the center of many family units, “involv[es] the highest

interests of society.” Wendy G-M, 45 Misc. 3d at 590. “[A]lthough people enter

into marriage for many reasons, creating familial bonds is one of the most significant

reasons, particularly for the benefit of their children.” Id. And society has

“[r]ecognized the many advantages that flow[] to children from having two parents.”

Id. at 577; see also Brooke S.B. v. Elizabeth A.C.C., 28 N.Y.3d 1, 22-23 (2016)

(predicating an appropriate test for “parent” on the “interest of insuring that ‘each

child begins life with two parents’”). Consequently, “[i]t has always been the policy

of the State of New York to prevent the legal process from being used to render

children” without a second parent. L.M., 6 Misc. 3d at 154.

2
Before 1985, when the present section was enacted, proceedings to establish the
paternity of a child had to commenced within two years of the birth of the child.
See Sobie, Practice Commentaries, N.Y. Family Ct. Act § 517. The only exception
to this statute of limitations is when the father has acknowledged paternity in
writing or by furnishing support. N.Y. Family Ct. Act § 517. Birth certificates,
however, are only prima facie evidence of parentage and are not considered an
acknowledgement of parentage. See Wendy G-M., 45 Misc. 3d at 576 fn. 2; 46
N.Y. Jur. 2d Dom. Rel. § 893.
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With this emphasis on the welfare of the child, in recent decades, the New

York Court of Appeals has liberalized the definition of the parent-child relationship.

In 1995, the Court permitted the unmarried partner—whether male or female—of a

child’s biological mother to adopt that child because doing so would be in “the

child’s best interest.” See Brooke S.B., 28 N.Y.3d at 21; In re Jacob, 86 N.Y.2d 651,

636 (1995). More recently, “appl[ying] a similar analysis,” the Court held that a

“man who has mistakenly represented himself as a child’s father may be estopped

from denying paternity, . . . when the child justifiably relied on the man’s

representation of paternity, to the child’s detriment.” Brooke S.B., 28 N.Y.3d at 21;

In re Shondel J., 7 N.Y.3d 320, 330-32 (2006). The Court “based [its] decision on

the best interests of the child, emphasizing the potential damage to a child’s psyche

caused by suddenly ending established parental support.” Brooke S.B., 28 N.Y.3d

at 21 (internal quotation marks omitted).

Last year, the Court of Appeals overruled precedent that required an

individual to have a biological or adoptive relationship with a child to be termed a

“parent” with standing to seek visitation or custody. Brooke S.B., 28 N.Y.3d at 26

(overruling In re Alison D., 77 N.Y.2d 651 (1991)). The Court noted that, “In the

years that followed [its decision in Alison D.], lower courts applying Alison D. were

‘forced to . . . permanently sever strongly formed bonds between children and adults

with whom they have parental relationships.’” Id. at 24. It recognized that “[b]y

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‘limiting their opportunity to maintain bonds that may be crucial to their

development,’ the rule of Alison D. has ‘fallen hardest on the children.’” Id.

It is this emphasis on the welfare of the child, that has led most—if not all—

states, like New York, to recognize the “principle that a child conceived or born

during wedlock is presumed to be legitimate.” See, e.g., Michael H., 491 U.S. at

124-27; McLaughlin v. Jones, No. CV-16-0266-PR, 2017 WL 4126939, at *2, *6-7

(Ariz. Sept. 19, 2017); generally, 41 Am. Jur. 2d Illegitimate Children § 8. “While

the word ‘legitimate’ may be somewhat archaic, the intent of [the] statutes and the

common law presumption is unambiguous: a child born in a marriage is the child of

the couple.” Wendy G-M, 45 Misc. 3d at 579.

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CONCLUSION

For the reasons stated above, the judgment of the Board of Immigration

appeals should be reversed.

Respectfully submitted,

/s/ Shailee Diwanji Sharma

Shailee Diwanji Sharma
Andrew A. Ruffino
COVINGTON & BURLING LLP
The New York Times Building
620 Eighth Avenue
New York, NY 10018
Telephone: (212) 841-1000
Facsimile: (212) 841-1010
aruffino@cov.com

Counsel to Family Law Professors

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APPENDIX

LIST OF AMICI CURIAE3

Jamie R. Abrams
Associate Professor
University of Louisville Brandeis School of Law

Susan Frelich Appleton

Lemma Barkeloo & Phoebe Couzins Professor of Law
Washington University School of Law

Barbara A. Atwood
Mary Anne Richey Professor of Law Emerita
Co-Director, Child and Family Law Certificate Program
University of Arizona Rogers College of Law

Margaret B. Drew
Associate Professor of Law
University of Massachusetts School of Law

Ann E. Freedman
Associate Professor of Law
Rutgers Law School

Philip M. Genty
Everett B. Birch Clinical Professor in Professional Responsibility
Director, Incarceration and the Family Clinic
Columbia Law School

Cynthia Godsoe
Associate Professor of Law
Brooklyn Law School

Martin Guggenheim
Fiorello LaGuardia Professor Clinical Law
New York University School of Law

3
Affiliations are provided for identification purposes only.
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Leslie Harris
Dorothy Kliks Fones Professor
University of Oregon School of Law

Susan Hazeldean
Assistant Professor of Law
Brooklyn Law School

Deseriee Kennedy
Associate Dean of Diversity & Inclusion
Touro Law Center

Theo Liebmann
Clinical Professor & Director of Clinical Programs
Maurice A. Deane School of Law at Hofstra University

Solangel Maldonado
Eleanor Bontecou Professor of Law
Seton Hall Law School

Carlin Meyer
Professor of Law, Emerita
New York Law School

Catherine J. Ross
Fred C. Stevenson Research Professor
George Washington University Law School

Elizabeth Scott
Harold R. Media Professor of Law
Columbia Law School

Barbara J. Stark
Professor of Law and Hofstra Research Fellow
Maurice A. Deane School of Law at Hofstra University

Edward Stein
Professor of Law
Director, Gertrud Mainzer Program in Family Law, Policy, and Bioethics
Cardozo School of Law
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David B. Thronson
Professor of Law
Associate Dean for Experiential Education
Michigan State University College of Law

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CERTIFICATE OF COMPLIANCE

Pursuant to Federal Rules of Appellate Procedure 29(a)(4)(G), 29(a)(5), and

32(a) and Cir. Rules 29.1(c) and 32.1(a), the attached amicus brief is proportionally

spaced, has a typeface of 14-point Times New Roman font and contains 2,123 words.

This certificate was prepared in reliance on the word count option in the tools menu

of the Microsoft Office Word 2016 word-processing software program that was used

to prepare this brief.

/s/ Shailee Diwanji Sharma

Shailee Diwanji Sharma
 Case 17-1512, Document 72-4, 09/25/2017, 2133032, Page1 of 1

CERTIFICATE OF SERVICE

I hereby certify that I electronically filed the foregoing motion with the

Clerk of the Court for the United States Court of Appeals for the Second Circuit by

using the appellate CM/ECF system on September 25, 2017.

Participants in the case are registered CM/ECF users and will be served by

the appellate CM/ECF system.

Dated: September 25, 2017

/s/ Shailee Diwanji Sharma

Shailee Diwanji Sharma

Counsel to Amici Curiae Family Law

Professors