MOTION FOR LEAVE TO FILE
BRIEF AS AMICUS CURIAE
David Boyle (hereinafter, “Amicus”) respectfully
moves for leave to file the attached brief as amicus
curiae. Amicus’ interest in the instant case follows
on his two previous “Muslim ban” amicus briefs and
his desire for completeness, seeing that the issue is
not resolved yet.
Petitioners have granted blanket permission to
amicae/i to write briefs. As for Respondents, their
counsel has not granted permission. (Amicus found
that interesting, in that Respondents’ counsel
evokes, in layanan of his clients, the value of
inclusiveness, i.e., not unnecessarily excluding
people from the community; ideally, this value
should apply to amicae/i as well! especially since
they are trying to help Respondents’ case.)
So, Amicus asked counsel for consent to this
motion: Petitioners replied that their blanket
consent also constitutes consent to a motion for leave
to file; Respondents, too, consented to the motion.
I. BACKSTORY, “BRIEF BRIEFS”, AND
BREADTH; OR, “MARCH MUSENESS 2018”
Respondents expressed interest, Amicus may
have heard, in not overtaxing the Court with too
many filings, maybe even encouraging their amicae/i
to consolidate their filings by having multiple people
contributing to one single brief, when possible,
rather than submitting many separate briefs.
However, Amicus told Respondents that his brief
would be only one page long. Amicus did not think a
one-page brief would take too much of the Court’s time to read; indeed, the present Motion is longer
than the brief itself. Nevertheless, Respondents for
some reason did not grant permission (although,
again, they did consent to the instant Motion). Now
the Court must read several pages instead of just
one, ironically enough. After all that, it isn’t much of a stretch to submit
haiku in an actual Court brief. (Especially if said
poem tries to evoke pithily the threatening substrata
and real-life events surrounding and adding
meaning to the bare legal text of the “Muslim ban”.)