Counsel For Intervenor-Defendant: United States District Court For The Eastern District of Virginia - Norfolk Division

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Jordan W. Lorence, VA Bar No. 33655

M. Casey Mattox, VA Bar No. 47148
ALLIANCE DEFENDING FREEDOM
801 G Street N.W., Suite 509
Washington, D.C. 20001
Tel: (202) 393-8690
Fax: (480) 444-0028
jlorence@alliancedefendingfreedom.org
cmattox@alliancedefendingfreedom.org

Byron J. Babione,* AZ Bar No. 024320
Kenneth J. Connelly,* AZ Bar No. 025420
J. Caleb C. Dalton, VA Bar No. 83790
15100 N 90th Street
Scottsdale, Arizona 85260
Tel: (480) 444-0020
Fax: (480) 444-0028
bbabione@alliancedefendingfreedom.org
kconnelly@alliancedefendingfreedom.org
cdalton@alliancedefendingfreedom.org
* Pro Hac Vice Applications pending

Counsel for Intervenor-Defendant

UNITED STATES DISTRICT COURT FOR THE
EASTERN DISTRICT OF VIRGINIA NORFOLK DIVISION

TIMOTHY B. BOSTIC, et al.,
Plaintiffs,
v.
JANET M. RAINEY, in her official capacity
as State Registrar of Vital Records, et al.,
Defendants,
and
MICHLE B. MCQUIGG, in her official
capacity as Prince William County Clerk of
Circuit Court,
Proposed Intervenor-Defendant.
Civil Action No. 2:13-cv-395

MOTION TO INTERVENE

Case 2:13-cv-00395-AWA-LRL Document 72 Filed 12/20/13 Page 1 of 5 PageID# 619

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Proposed Intervenor-Defendant, Michle B. McQuigg, in her official capacity as Prince
William County Clerk of Circuit Court (hereinafter Proposed Intervenor McQuigg), by and
through her undersigned counsel, and pursuant to Rule 24(a)(2), or alternatively, Rule 24(b) of
the Federal Rules of Civil Procedure, and Rule 7 of the Rules of Practice and Procedure of the
United States District Court for the Eastern District of Virginia, files this Motion to Intervene of
Right, or in the Alternative, for Permissive Intervention (Motion), as defendant in this action.
In support of this Motion, Proposed Intervenor McQuigg sets forth that:
1. This motion is timely and will not prejudice the interests of the other parties.
2. Proposed Intervenor McQuigg seeks to intervene as Intervenor-Defendant to
oppose Plaintiffs and be conferred all of the rights of a party to participate fully in all aspects of
the above-captioned case.
3. Intervention by Proposed Intervenor McQuigg in this matter is necessary because
she has significant, distinct interests in this litigation and her ability to protect such interests may
be impaired by the disposition of this case.
4. Counsel for Defendant Rainey has consented to the Motion. Counsel for
Defendant Schaefer has stated that he has no objection to the Motion. Counsel for Plaintiffs are
opposed to the Motion.
5. In support of this Motion, Proposed Intervenor McQuigg relies on the Declaration
of Proposed Intervenor-Defendant, Prince William County Clerk of Circuit Court Michle B.
McQuigg, and Proposed Intervenor-Defendants Memorandum of Law filed contemporaneously
herewith.


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Respectfully submitted this the 20th day of December, 2013.

By: /s/
Tel: (202) 393-8690
Fax: (480) 444-0028

Tel: (202) 393-8690
Fax: (480) 444-0028

15100 N 90th Street
Tel: (480) 444-0020
Fax: (480) 444-0028



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CERTIFICATE OF SERVICE
I hereby certify that on December 20, 2013, I will electronically file the foregoing
document with the Clerk of Court using the CM/ECF system, which will then send a notification
of such filing (NEF) to the following participants:
David B. Oakley
doakley@poolemahoney.com
Jeffrey F. Brooke, Esq.
Poole Mahoney PC
860 Greenbrier Circle, Suite 401
Chesapeake, VA 23320

Attorneys for Defendant George E. Schaefer, III

Earle Duncan Getchell, Jr.
dgetchell@oag.state.va.us
Office of the Attorney General
900 E Main St
Richmond, VA 23219

Attorney for Defendant Janet M. Rainey
Thomas B. Shuttleworth
tshuttleworth@srgslaw.com
Robert E. Ruloff
rruloff@srgslaw.com
Charles B. Lustig
clustig@srgslaw.com
Andrew Mitchell Hendrick
ahendrick@srgslaw.com
Erik C. Porcaro
eporcaro@srgslaw.com
Shuttleworth, Ruloff, Swain, Haddad &
Morecock, P.C.
4525 South Blvd., Suite 300
Virginia Beach, VA 23452

Joshua Seth Lipshutz
jlipshutz@gibsondunn.com
Gibson, Dunn & Crutcher LLP
555 Mission St., Suite 3000
San Francisco, CA 94105-0921

Robert Brian Silver
rsilver@bsfllp.com
Joshua I. Schiller
jischiller@bsfllp.com
Boies, Schiller & Flexner LLP
575 Lexington Ave., 7th Floor
New York, NY 10022

Chantale Fiebig
cfiebig@gibsondunn.com
Amir C Tayrani
atayrani@gibsondunn.com
Theodore B Olson
tolson@gibsondunn.com
Matthew D McGill
mmcgill@gibsondunn.com
Gibson Dunn & Crutcher LLP
1050 Connecticut Ave, NW
Washington, DC 20036-5306

David Boies
dboies@bsfllp.com
Boies, Schiller & Flexner, LLP
333 Main St.
Armonk, NY 10504

Jeremy Michael Goldman
jgoldman@bsfllp.com
1999 Harrison St., Suite 900
Oakland, CA 94612


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Theodore J Boutrous, Jr
tboutrous@gibsondunn.com
Gibson, Dunn & Crutcher LLP (CANA)
333 South Grand Ave.
Los Angeles, CA 90071-3197

William Isaacson
wisaacson@bsfllp.com
Boies, Schiller & Flexner
5301 Wisconsin Ave, NW
Washington, DC 20015

Attorneys for Plaintiffs

/s/
Tel: (202) 393-8690
Fax: (480) 444-0028



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Tel: (202) 393-8690
Fax: (480) 444-0028

15100 N 90th Street
Tel: (480) 444-0020
Fax: (480) 444-0028



Plaintiffs,
v.
Defendants,
and
Circuit Court,

DECLARATION OF MICHLE B.
MCQUIGG IN SUPPORT OF MOTION
TO INTERVENE

Case 2:13-cv-00395-AWA-LRL Document 72-1 Filed 12/20/13 Page 1 of 3 PageID# 624

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I, Michle B. McQuigg, swear to the following facts under the penalty of perjury:
1. I have been the Clerk of Circuit Court in Prince William County, Virginia since
2008. By statute, my position and official responsibilities include enforcing Virginias Marriage
Laws. Specifically, my duties include ensuring that applicants for marriage licenses meet all the
statutory and constitutional requirements for marriage under state lawonly then am I legally
permitted to issue marriage licenses to prospective applicants.
2. As the Prince William County Circuit Court Clerk, an elected and independent
constitutional officer, I have significantly protectable interests that may be impaired in the
pending litigation, and that those interests will not be adequately represented by any other party
defendant.
3. I do not believe that State Registrar of Vital Records Janet M. Rainey will
adequately represent my interests going forward. The incoming Attorney General, Mark
Herring, who will be continuing the representation of Registrar Rainey, has explicitly stated that
he would work to change Virginias Marriage Laws. Given this statement, it is doubtful whether
he will provide a zealous defense of Virginias Marriage Laws, or whether he will appeal any
ruling adverse to those laws.
4. Nor do I believe that Clerk of Court for Norfolk Circuit Court George E.
Schaefer, III, will adequately represent my interests. While Clerk Schaefer has raised pertinent
issues, and has asserted some of the compelling and legitimate government interests furthered by
Virginias Marriage Laws in his brief, he neither raised all the interests and arguments previously
upheld by other courts, nor extensively developed or explained the asserted interests, as I would
have done. This creates the reasonable prospect that even if Clerk Schaefer were to appeal an
adverse ruling, he would not as zealously and comprehensively defend Virginia' s Marriage Laws
as I would to protect my interests as the Prince William County Circuit Court Clerk.
5. I am concerned that a statewide injunction against the enforcement of Virginia' s
Marriage Laws without my involvement as a party defendant would create significant confusion
and uncertainty for me in the performance of my legal duties regarding marriage. It is unclear to
me whether, in such a situation, 1 would have a duty to follow Virginia' s Marriage Laws or to
follow the ruling of this Court. Such confusion and uncertainty would materially disrupt and
impede the performance of my official duties relating to marriage.
I declare under penalty of perjury, under the laws of the Commonwealth of Virginia and
under the laws of the United States of America, that the foregoing facts are true and correct.
Dated: December 1.0, 2013
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Tel: (202) 393-8690
Fax: (480) 444-0028

15100 N 90th Street
Tel: (480) 444-0020
Fax: (480) 444-0028



Plaintiffs,
v.
Defendants,
and
Circuit Court,

PROPOSED ANSWER AND
AFFIRMATIVE DEFENSES OF
INTERVENOR-DEFENDANT
MICHLE B. MCQUIGG


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ANSWER AND AFFIRMATIVE DEFENSES
COMES NOW, Proposed Intervenor-Defendant, Michle B. McQuigg, in her official
capacity as Prince William County Clerk of Circuit Court (hereinafter Proposed Intervenor
McQuigg), by counsel, and files her Answer and Affirmative Defenses to Plaintiffs First
Amended Complaint for Declaratory, Injunctive and Other Relief as follows:
ANSWER TO COMPLAINT
1. Plaintiffs cite numerous marriage cases in Paragraph 1. These cases speak for
themselves and require no response. All remaining allegations of Paragraph 1 are DENIED.
2. The cases, Va. Const. Art. I, 15-A, and Va. Code 20-45.2, 20-45-3
(collectively referred to as Virginias Marriage Laws) cited by Plaintiffs in Paragraph 2 speak
for themselves and require no response. All remaining allegations of Paragraph 2 are DENIED.
3. The Virginia marriage statute cited by Plaintiffs speaks for itself and requires no
response. All remaining allegations of paragraph 3 are DENIED.
4. Proposed Intervenor McQuigg DENIES that Plaintiffs are entitled to the relief
they request in Paragraph 4. All remaining allegations are DENIED.
JURISDICTION AND VENUE
5. Plaintiffs advance federal constitutional claims, but Proposed Intervenor
McQuigg DENIES that they are entitled to any of the relief they seek.
6. Proposed Intervenor McQuigg ADMITS that venue is proper in this Court.
7. Proposed Intervenor McQuigg ADMITS that Plaintiffs have brought this suit
pursuant to 42 U.S.C. 1983 and that they seek declaratory and injunctive relief from Virginias
Marriage Laws, but DENIES that Plaintiffs are entitled to any of the relief requested in
Paragraph 7.

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8. Proposed Intervenor McQuigg is without knowledge or information sufficient to
admit or deny the allegations personal to Plaintiffs in Paragraph 8, and thus the allegations in
their entirety are DENIED. The legal conclusions advanced by Plaintiffs require no response,
but to the extent a response is required they are DENIED in their entirety.
admit or deny the allegations personal to Plaintiffs in Paragraph 9, and thus the allegations in
their entirety are DENIED. The legal conclusions advanced by Plaintiffs require no response,
but to the extent a response is required they are DENIED in their entirety.
10. Proposed Intervenor McQuigg ADMITS that Plaintiffs have brought this suit
pursuant to 42 U.S.C. 1983, that they seek declaratory and injunctive relief from Virginias
Marriage Laws, and that they seek to recover attorneys fees, costs, and expenses, but DENIES
that Plaintiffs are entitled to any of the relief whatsoever.
admit or deny the allegations in Paragraph 11, and thus the allegations in their entirety are
DENIED.
DENIED.
DENIED.

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DENIED.
15. The laws applicable to Defendant Schaefer speak for themselves and require no
response. The legal conclusions asserted by Plaintiffs in Paragraph 15 similarly require no
response. Proposed Intervenor McQuigg ADMITS that Defendant Schaefer is the Clerk of the
Circuit Court for the City of Norfolk. All other remaining allegations in Paragraph 15 are
DENIED.
16. The laws applicable to Defendant Rainey speak for themselves and require no
response. The legal conclusions asserted by Plaintiffs in Paragraph 16 similarly require no
response. Proposed Intervenor McQuigg ADMITS that Defendant Rainey is the State Registrar
of Vital Records. All other remaining allegations in Paragraph 16 are DENIED.
17. Proposed Intervenor McQuigg ADMITS that she, along with those under her
supervision, direction, or control, is bound by Virginia law in the performance of her official
duties, and states that upon information and belief that Defendants Rainey and Schaefer are also
so obligated. The remaining legal conclusions and the statement of relief asserted by Plaintiffs
require no response. All other allegations are DENIED.
DENIED.
19. The Virginia Marriage Laws cited by Plaintiffs in Paragraph 19 speak for
themselves and require no response. To the extent Plaintiffs draw legal conclusions from those
laws, no response is required. Similarly, Plaintiffs assertions based on United States v. Windsor,

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133 S. Ct. 2675 (2013), are legal conclusions and thus require no response. All remaining
allegations in Paragraph 19 are DENIED.
20. The Virginia Marriage Laws cited by Plaintiffs in Paragraph 20 speak for
themselves and require no response. All remaining allegations in Paragraph 20 are DENIED.
21. The conclusions of law proffered by Plaintiffs in Paragraph 21 require no
response. Proposed Intervenor McQuigg is without knowledge or information sufficient to admit
or deny the allegations asserted Paragraph 21 regarding federal marital privileges and benefits,
and thus those allegations are DENIED. All remaining allegations are DENIED.
22. The Virginia Marriage laws cited by Plaintiffs, along with United States v.
Windsor, speak for themselves and require no response. To the extent legal conclusions are
proffered by Plaintiffs, these too require no response. Proposed Intervenor McQuigg is without
knowledge or information sufficient to admit or deny the remaining allegations asserted in
Paragraph 22, and thus those allegations are DENIED.
23. The Virginia Marriage laws cited by Plaintiffs, along with United States v.
Windsor, speak for themselves and require no response. To the extent legal conclusions are
proffered by Plaintiffs, these too require no response. All remaining allegations asserted in
Paragraph 23 are DENIED.
24. The legal conclusions contained in Paragraph 24 require no response, and the
Virginia Marriage Laws cited by Plaintiffs speak for themselves. All remaining allegations in
Paragraph 24 are DENIED.
DENIED.

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DENIED.
admit or deny the allegations personal to plaintiffs, including the ability of Plaintiffs Bostic and
London to marry each other, and thus these allegations are DENIED in their entirety. The legal
conclusions asserted by Plaintiffs in Paragraph 27 require no response, but to the extent any
response is required, those allegations are DENIED.
DENIED.
DENIED.
30. The laws referenced by Plaintiffs speak for themselves and require no response.
Proposed Intervenor McQuigg is without knowledge or information sufficient to admit or deny
the remaining allegations in Paragraph 30, and thus the allegations in their entirety are DENIED.
DENIED.

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34. The legal conclusions asserted by Plaintiffs require no response. Proposed
Intervenor McQuigg is without knowledge or information sufficient to admit or deny the
remaining allegations in Paragraph 34, and thus the allegations in their entirety are DENIED.
35. The legal conclusions asserted by Plaintiffs require no response. Proposed
Intervenor McQuigg is without knowledge or information sufficient to admit or deny the
remaining allegations in Paragraph 35, and thus the allegations in their entirety are DENIED.
Proposed Intervenor McQuigg expressly DENIES that Plaintiffs are entitled to any of the relief
they seek.
COUNT 1
DUE PROCESS

36. Proposed Intervenor McQuigg incorporates here by reference Paragraphs 1
through 35 as if fully set forth herein.
37. Proposed Intervenor McQuigg DENIES the allegations in Paragraph 37.
COUNT II
EQUAL PROTECTION


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42. The Virginia Marriage Laws cited by Plaintiffs speak for themselves, and the
legal conclusions asserted by Plaintiffs require no response. To the extent a response is required,
all allegations in Paragraph 42 are DENIED.
43. The Virginia Marriage Laws cited by plaintiffs speak for themselves, and the
COUNT III
VIOLATION OF 42 U.S.C. 1983


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IRREPARABLE INJURY
admit or deny the allegations in Paragraph 51 regarding benefit entitlements, and thus those
allegations are DENIED. The Virginia Marriage Laws cited by Plaintiffs speak for themselves,
and the legal conclusions asserted by Plaintiffs require no response. To the extent a response is
required, all allegations in Paragraph 51 are DENIED.
53. Proposed Intervenor McQuigg DENIES that Plaintiffs are entitled to any relief on
any asserted theory.
54. All allegations not expressly admitted are DENIED.
AFFIRMATIVE DEFENSES
1. Plaintiffs fail to state a claim upon which relief can be granted.
2. Plaintiffs claims are barred by the Tenth Amendment.
3. Proposed Intervenor McQuigg is entitled to absolute and qualified immunity.
4. Some or all Plaintiffs lack standing to assert the claims presented in the
Complaint.
5. Some or all of Plaintiffs claims are not ripe for judicial determination by this
Court.

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Wherefore, Proposed Intervenor McQuigg, in her official capacity as Clerk of the Court
for Prince William County, Virginia, respectfully requests that Plaintiffs Amended Complaint
be dismissed with prejudice, that she be awarded costs and attorneys fees in this matter, and that
she be awarded such further relief as is deemed necessary and just.

By: /s/
Tel: (202) 393-8690
Fax: (480) 444-0028

Tel: (202) 393-8690
Fax: (480) 444-0028

15100 N 90th Street
Tel: (480) 444-0020
Fax: (480) 444-0028



11
David B. Oakley
Poole Mahoney PC


900 E Main St
Richmond, VA 23219

Robert E. Ruloff
rruloff@srgslaw.com
Charles B. Lustig
clustig@srgslaw.com
Erik C. Porcaro
Morecock, P.C.


Robert Brian Silver
rsilver@bsfllp.com
Joshua I. Schiller
New York, NY 10022

Chantale Fiebig
Amir C Tayrani
Theodore B Olson
Matthew D McGill

David Boies
dboies@bsfllp.com
333 Main St.
Armonk, NY 10504

jgoldman@bsfllp.com
Oakland, CA 94612


12

William Isaacson


/s/
Tel: (202) 393-8690
Fax: (480) 444-0028



1
Tel: (202) 393-8690
Fax: (480) 444-0028

15100 N 90th Street
Tel: (480) 444-0020
Fax: (480) 444-0028



Plaintiffs,
v.
Defendants,
and
Circuit Court,

PROPOSED INTERVENORS MOTION
FOR SUMMARY JUDGMENT AND
RESPONSE IN OPPOSITION TO
PLAINTIFFS MOTION FOR SUMMARY
JUDGMENT


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MOTION FOR SUMMARY JUDGMENT
COMES NOW Proposed Intervenor-Defendant, Michle B. McQuigg, in her official
capacity as Prince William County Clerk of Circuit Court (hereinafter Proposed Intervenor
McQuigg), by and through her undersigned counsel, and respectfully moves for summary
judgment pursuant to Federal Rule of Civil Procedure 56. For the reasons set forth below, she
requests that this Court grant this Motion for Summary Judgment and dismiss with prejudice all
claims in Plaintiffs Amended Complaint.
MEMORANDUM IN SUPPORT OF MOTION FOR SUMMARY JUDGMENT
In the interests of judicial economy, Proposed Intervenor McQuigg hereby incorporates
and adopts the arguments proffered by the defendants in their Memoranda in Support of Motions
for Summary Judgment (Dkt. No. 41 & Dkt. No. 44), their Memoranda in Opposition to
Plaintiffs Motion for Summary Judgment (Dkt. No. 57 & Dkt. No. 58), and Registrar Raineys
Reply to Plaintiffs Response to Motion for Summary Judgment (Dkt. No. 65). These briefs
establish that Plaintiffs are not entitled to any of the relief they seek, and Proposed Intervenor
McQuigg therefore respectfully requests that this Court dismiss Plaintiffs action with prejudice.


3

By: /s/
Tel: (202) 393-8690
Fax: (480) 444-0028

Tel: (202) 393-8690
Fax: (480) 444-0028

15100 N 90th Street
Tel: (480) 444-0020
Fax: (480) 444-0028



4
David B. Oakley
Poole Mahoney PC


900 E Main St
Richmond, VA 23219

Robert E. Ruloff
rruloff@srgslaw.com
Charles B. Lustig
clustig@srgslaw.com
Erik C. Porcaro
Morecock, P.C.


Robert Brian Silver
rsilver@bsfllp.com
Joshua I. Schiller
New York, NY 10022

Chantale Fiebig
Amir C Tayrani
Theodore B Olson
Matthew D McGill

David Boies
dboies@bsfllp.com
333 Main St.
Armonk, NY 10504

jgoldman@bsfllp.com
Oakland, CA 94612


5

William Isaacson


/s/
Tel: (202) 393-8690
Fax: (480) 444-0028



1
Tel: (202) 393-8690
Fax: (480) 444-0028

15100 N 90th Street
Tel: (480) 444-0020
Fax: (480) 444-0028



Plaintiffs,
v.
Defendants,
and
Circuit Court,

REQUEST FOR HEARING


2
PLEASE TAKE NOTICE that Proposed Intervenor-Defendant, Michle B. McQuigg,
requests that this Honorable Court schedule a hearing dateeither separately or at a time at
which this Court has already established a hearing date in this matteron which Proposed
Intervenor-Defendant may move this Court for entry of an Order granting Proposed Intervenor-
Defendants Motion to Intervene.
At the direction of the Clerk, Proposed Intervenor has attached the Pro Hac Vice
Applications of Byron J. Babione and Kenneth J. Connelly to the Motion to Intervene. Proposed
Intervenor requests that the Court permit the filing of these Applications and payment of required
fees and act on them in time for any scheduled hearing on this motion. In the alternative,
Proposed Intervenor requests the Court deem the Pro Hac Vice applicants admitted upon the
payment of the required fees in time for any scheduled hearing on this motion.


3

By: /s/
Tel: (202) 393-8690
Fax: (480) 444-0028

Tel: (202) 393-8690
Fax: (480) 444-0028

15100 N 90th Street
Tel: (480) 444-0020
Fax: (480) 444-0028



4
David B. Oakley
Poole Mahoney PC


900 E Main St
Richmond, VA 23219

Robert E. Ruloff
rruloff@srgslaw.com
Charles B. Lustig
clustig@srgslaw.com
Erik C. Porcaro
Morecock, P.C.


Robert Brian Silver
rsilver@bsfllp.com
Joshua I. Schiller
New York, NY 10022

Chantale Fiebig
Amir C Tayrani
Theodore B Olson
Matthew D McGill

David Boies
dboies@bsfllp.com
333 Main St.
Armonk, NY 10504

jgoldman@bsfllp.com
Oakland, CA 94612


5

William Isaacson


/s/
Tel: (202) 393-8690
Fax: (480) 444-0028


IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF VIRGINIA
IQ esetForm
Print Form
APPLICATION TO QUALIFY AS A FOREIGN ATTORNEY UNDER LOCAL CIVIL RULE 83.1(D) AND LOCAL
CRIMINAL RULE 57.4
In Case Number 2:1 3-cv-395 , Case Name Bostic v. Rainey

Party Represented by Applicant: _ln_t_erv_en_o_r_-D_e_fe_n_d_a_nt ____________ _
To: The Honorable Judges of the United States District Court for the Eastern District of Virginia
PERSONAL STATEMENT
FULL NAME (no initials, please) _B...;_ y_ro_n_J_e_ff_o_rd_s_B_a_b_io_n_e __________________________________________________ _
Bar Identification Number 024320 State AZ
-'-='-----------
Firm Name Alliance Defending Freedom
Firm Phone# 480-444-0020 Direct Dial# 480-388-8038 FAX# 480-444-0028

E-Mail Address bbabione@alliancedefendingfreedom.org
Office Mailing Address 15100 N. 90th Street, Scottsdale, AZ 85260
Name(s) offederal court(s) in which I have been admitted _S_ee __ att_a_c_h_e_d. ________________________________________ _
I certify that the rules of the federal court in the district in which I maintain my office extend a similar pro hac vice admission
privilege to members of the bar of the Eastern District of Virginia.
I have not been reprimanded in any court nor has there been any action in any court pertaining to my conduct or fitness as a
member of the bar.
I hereby certify that, within ninety (90) days before the submission of this application, I have read the Local Rules of this Court
and that my knowledge of the Federal Rules of Civil Procedure, the Federal Rules of Criminal Procedure, and the Federal Rules of
Evidence is current.
I, the undersigned, do certify that I am a member of the bar of this Court, not related to the ap cant; that I know the applicant
personally, that the said applicant possesses all of the qualifications required for admission to the bar of this Court; that I have
examined the applicant's personal statement. I affirm that his/her personal and professional character and standing are good, and
petition the court to admit the applicant pro hac vice.
s/M. Casey Mattox

(Date (Signature)
M, Casey Mattox
47148
(Trped or Printed Name) (VA Bar Number)
Court Use Only:
Clerk's Fee Paid _______ or Exemption Granted ______ _
The motion for admission is GRANTED _______ or DENIED ______ _
(Judge's Signature) (Date)
BYRON J. BABIONE
FEDERAL COURT ADMISSIONS

FEDERAL COURT DATE ADMITTED

District Court for the Eastern District of Virginia ..................................................... April 29, 1994

District Court for the Northern District of New York ............................................. J anuary 9, 1998

District Court for the Western District of New York ................................................... May 6, 2002

District Court for the Eastern District of Michigan ............................................... J anuary 12, 2007

District Court of Arizona ........................................................................................... April 30, 2007

United States Court of Appeals for the 4th Circuit .............................................. November 2, 1993

United States Court of Appeals for the 2nd Circuit ................................................... April 11, 2003

United States Court of Appeals for the 9th Circuit ................................................ February 8, 2005

United States Court of Appeals for the 6th Circuit .................................................... March 7, 2007

United States Court of Appeals for the 10thCircuit .................................................... April 1, 2008

United States Court of Appeals for the 1st

Circuit .................................................. August 18, 2010

Supreme Court of the United States....................................................................... J anuary 24, 2011
IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF VIRGINIA
Reset Form J l Print Form
APPLICATION TO QUALIFY AS A FOREIGN ATTORNEY UNDER LOCAL CIVIL RULE 83.l(D) AND LOCAL
CRIMINAL RULE 57.4
In Case Number 2:13-cv-395 , Case Name Bostic v. Rainey

Party Represented by Applicant:
To: The Honorable Judges of the United States District Court for the Eastern District of Virginia
PERSONAL STATEMENT
FULL NAME (no initials, please)
Bar Identification Number 025420 State AZ

Firm Name Alliance Defending Freedom
Firm Phone # 480-444-0020 Direct Dial # FAX # 480-444-0028
E-Mail Address kconnelly@alliancedefendingfreedom.org
Office Mailing Address 15100 N. 90th Street, Scottsdale, AZ 85260
Name(s) of federal court(s) in which I have been admitted
I certify that the rules of the federal court in the district in which I maintain my office extend a similar pro hac vice admission
privilege to members of the bar of the Eastern District of Virginia.
I have not been reprimanded in any court nor has there been any action in any court pertaining to my conduct or fitness as a
member of the bar.
I hereby certify that, within ninety (90) days before the submission of this application, I have read the Local Rules of this Court
and that my knowledge of the Federal Rules of Civil Procedure, the Federal Rules of Criminal Procedure, and the Federal Rules of
Evidence is current.
I am __ am a full-time employee of the United States of America, and if so, request exemption from the admission fee.

I, the undersigned, do certify that I am a member of the bar of this Court, not related to the applicant; that I know the applicant
personally, that the said applicant possesses all of the qualifications required for admission to the bar of this Court; that I have
examined the applicant's personal statement. I affirm that his/her personal and professional character and standing are good, and
petition the court to admit the applicant pro hac vice.
s/M. Casey Mattox
(Signature)
M, Casey Mattox
(Txped or Printed Name)
Court Use Only:
Clerk's Fee or Exemption
The motion for admission is GRANTED
(Judge's Signature) (Date)
I )-11{ h
(Date)
47148
(VA Bar Number)

Counsel For Intervenor-Defendant: United States District Court For The Eastern District of Virginia - Norfolk Division

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Jordan W. Lorence, VA Bar No. 33655

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